1 | Building Technologies Program 

BUILDING TECHNOLOGIES PROGRAM

Energy Conservation Standards Notice of Proposed Rulemakingfor Fluorescent Lamp Ballasts

Tina KaarsbeDepartment of EnergyEnergy Efficiency & Rballasts.rulemaking@

May 10, 2011
2 | Building Technologies Program 

9:00 – 9:10 am Welcome, Introductions, Opening Statements

9:10 – 10:00 am Overview, Statute, Context, Market and Techn

Assessment, Screening Analysis

10:00 – 10:45 am Engineering Analysis10:45 – 11:00 am Break11:00 – 11:30 am Energy Use, Markup Analysis, Life-Cycle Cost 

Period Analysis

11:30 am – 12:00 pm Shipments, National Impact Analysis12:00 pm – 1:00 pm Lunch1:00 – 1:30 pm Manufacturer Impact Analysis1:30 – 2:00 pm Utility Impact Analysis, Employment Impact An

Environmental Assessment, Regulatory Impac

2:00 – 2:15 pm Break2:15 – 2:45 pm Proposed Standard2:45 – 3:00 pm Closing Remarks

Public Meeting Agenda
3 | Building Technologies Program 

Purpose of the Public Meeting

• Purpose

– To invite comment on proposed energy conservation standa– To present methodologies and characterize results of the ru

analyses;

– To discuss specific issues related to each analysis;– To seek input from interested parties on methodologies, ass

data sources, and results from the analyses; and

– To describe next steps in the rulemaking.

• Comments from Participants

– Participants are invited to provide summary comments or sta

and raise additional issues for discussion. 

– NOPR comment period closes Friday, June 10, 2011.
4 | Building Technologies Program 

Issue for Discussion

Issue Box: DOE welcomes comments, data, and informconcerning its NOPR for fluorescent lamp ballasts. Issuecorrespond to those raised in DOE’s published material numbered in accordance with that material. This presenalso includes some new issues not specifically mentionethe published material, and those have been labeled as Whether invited by an issue box or not, comments are welcome on any part of DOE’s analysis.

Issue box numbering corresponds to the list of issues published at the NOPR, available at: http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/flballasts_nopr_fr_n
5 | Building Technologies Program 

• In all correspondence, include all of the following:

– Energy Conservation Standards for Fluorescent Lamp Ballasts– Docket Number: EERE-2007–BT–STD–0016– Regulatory Identification Number (RIN):1904–AB50

• Contact Information

Comment period closes: Friday, June 10, 2011, midnight EDT

Postal Mail: 

Ms. Brenda EdwardsU.S. Department of EnergyBuilding Technologies ProgramMailstop EE-2J1000 Independence Avenue, S.W.Washington, DC 20585-0121

Courier: 

Ms. Brenda EdwardsU.S. Department of EneBuilding Technologies P950 L’Enfant Plaza, S.W

Washington, DC 20024 Telephone: (202) 586-29

DOE Seeks Comments on its Proposal

Email: ballasts.rulemaking@ee.doe.gov
6 | Building Technologies Program 

Public Meeting Agenda

234

Background and Legal Authority

5

2 Market & Tech; Screening; Engineering3 Energy Use; Markup Analysis

41 Overview5

Life-Cycle Cost and Payback Period Analysis

National Impact Analysis

6 MIA; NOPR Analyses
7 | Building Technologies Program 

Authority and Rulemaking History of Fluorescent Lamp Ballasts

• National Appliance Energy Conservation Amendment

(NAECA 1988) amended the Energy Policy and Conseof 1975 by:

− Adding fluorescent lamp ballasts as covered products;− Requiring development of a test procedure;− Setting minimum efficiency standards; and− Requiring DOE to review those standards twice.

• In September 2000, DOE published an energy conserv

standard final rule as the first revision of standards re

the statute. 65 FR 56740.

• The Energy Policy Act of 2005 (EPACT 2005) mandate

energy conservation standards for ballasts that operasaver” lamps.
8 | Building Technologies Program 

Active Mode Test Procedure
9 | Building Technologies Program 

Fluorescent Lamp Ballasts Rulemaking History/Schedule

Milestone Da

Framework Document Janua

Notice of Public Meeting and Availability of the Preliminary Technical Support Document Marc

Notice of Proposed Rulemaking (NOPR) Ap

Final Rule (Consent Decree) 

Compliance Date (projected) 

2007 2008 2009 2010 2011 2012 2013 2014 

Framework Document NOPM and Prelim. TSD NOPR Final Rule Co
10 | Building Technologies Program 

The Energy Policy and Conservation Act (EPCA)

Factor Analysis

1. Economic impact on consumers and 

manufacturers

Life-cycle cost analysisManufacturer impact analy

2. Lifetime operating cost savings Life-cycle cost analysis3. Total projected energy savings National impact analysis4. Impact on utility and performance Screening analysis;

Engineering analysis

5. Impact of any lessening of 

competition

Manufacturer impact analy

6. Need for national energy 

conservation

National impact analysis

7. Other factors the Secretary 

considers relevant

Environmental assessmenUtility impact analysis;Employment impact analys

• EPCA directs DOE to consider seven factors when setting 

conservation standards.
11 | Building Technologies Program 

Proposed Energy Conservation Standard Equation

• DOE is proposing that fluorescent lamp ballast manufactu

the following equation to determine whether their equipme(has BLE greater than or equal to) the proposed Trial StanLevel 3 (TSL 3)

BLE = Coefficient * ln(Total Lamp Arc Power) + 

75.080.085.090.095.0

100.0

0.0 50.0 100.0 150.0
12 | Building Technologies Program 

Proposed Energy Conservation Standards

• DOE is proposing TSL 3 for fluorescent lamp ballasts.

Product Class Equation

IS and RS ballasts that operate

4-foot MBP lamps8-foot slimline lamps 1.32 * ln(total lamp arc po

PS ballasts that operate

4-foot MBP lamps4-foot MiniBP SO lamps4-foot MiniBP HO lamps

1.79 * ln(total lamp arc po

IS and RS ballasts that operate

8-foot HO lamps 1.49 * ln(total lamp arc po

PS ballasts that operate

8-foot HO lamps 1.46 * ln(total lamp arc po

Ballasts that operate

8-foot HO lamps in cold 

temperature outdoor signs 1.49 * ln(total lamp arc po
13 | Building Technologies Program 

Proposed Energy Conservation Standards: Examples

Starting Method Lamp Type # of Lamps Ballast 

Factor

Arc Pow

(typical

Instant Start (IS) F32T8 Two 0.84 48.7 

IS F32T8 Four 0.88 102.1 IS F32T8 (res) Two 0.87 50.3 IS F96T8 Two 0.86 98.2 

Programmed Start (PS) F32T8 Two 0.91 52.6 

PS F32T8 Four 0.91 105.6 PS F28T5 Two 1.08 59.9 PS F54T5 Two 0.95 101.8 

IS F96T8HO Two 0.78 133.6 

Rapid Start (RS) F96T12HO Four 0.62 249.8 
14 | Building Technologies Program 

Summary of Proposed Rule Impacts

• Energy

– 12% average energy efficiency improvement in fluorescent b

(baseline compared to proposed standard).

– Cumulative energy savings (over 2014 - 2043) 

– Saves 3.7- 6.3 quadrillion Btus (quads) – Avoids need for 4.4 – 7.2 GW (gigawatt) new generating 

• Cost Savings

– Net Present Value (NPV), discount rate (DR)– Cumulative NPV = $11.4 billion (7% DR), $24.7 billion (3% 

Existing Technologies, Shift Scenario

– Cumulative NPV = $8.13 billion (7% DR), $16.5 billion (3% 

Emerging Technologies, Roll-Up Scenario
15 | Building Technologies Program 

Opening Remarks and Comments

• Opening Remarks

At this time, DOE welcomes opening remarks from intereson the NOPR for fluorescent lamp ballasts. 

Issue 14: DOE specifically invites comment on the propostandard levels for fluorescent lamp ballasts.

Issue 2: DOE seeks comments on the appropriateness oestablishing efficiency standards using an equation depenon lamp-arc power.
16 | Building Technologies Program 

Public Meeting Agenda

234

Background and Legal Authority

5

2 Market & Tech; Screening; Engineering3 Energy Use; Markup Analysis

41 Overview5

Life-Cycle Cost and Payback Period Analysis

National Impact Analysis

6 MIA; NOPR Analyses
17 | Building Technologies Program 

Framework

Document

Preliminary

Analysis

NOPR Final Rule

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use & End Use LoadCharacterization

ShipmentsAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Manufacturer Impact Analysis

NOPRRulemaking Stage
18 | Building Technologies Program 

• Fluorescent lamp ballast means a device which is u

start and operate fluorescent lamps by providing a svoltage and current and limiting the current during noperation. 42 U.S.C. 6291(29)(a)

• Fluorescent lamp ballasts that are currently subject 

standards (in terms of BEF) include ballasts that op

Number of Lamps Lamp Type

1 or 2 F40T121 or 2 F34T12

2 F96T122 F96T12/ES2 F96T12HO2 F96T12HO/ES

Scope of Coverage: Current
19 | Building Technologies Program 

• DOE considered additional fluorescent lamp ballast

coverage according to the directive in 42 U.S.C. 

6295(g)(7)(B).

• DOE used the following criteria when determining w

additional ballasts to include in coverage:

– Potential for significant energy savings– Technological feasibility– Economic justification

Scope of Coverage: Criteria
20 | Building Technologies Program 

• DOE’s proposed scope of coverage includes ballasts 

operate:

– 4-foot medium bipin (MBP) lamps in the commercial sector– 4-foot MBP lamps in the residential sector– 4-foot miniature bipin (MiniBP) standard output (SO) lamps– 4-foot MiniBP high output (HO) lamps– 8-foot single pin (SP) slimline lamps– 8-foot recessed double contact (RDC) HO lamps– 8-foot RDC HO lamps in cold temperature outdoor signs

• DOE is not proposing to include additional dimming b

in the scope of coverage.

Scope of Coverage: Proposed
21 | Building Technologies Program 

• Issue

− Magnetic ballasts are needed in certain applications that a

sensitive to electromagnetic interference (EMI) but would beliminated by the proposed standards.

− Methods to reduce EMI:

− inline filters− special lenses− grounding cages− fixture design− other external filters

− Unable to determine whether these methods would be suff

• Proposal

− Because DOE is unable to determine whether these metho

be sufficient, DOE proposes to exempt T8 magnetic ballas

− Designed and labeled for use in EMI-sensitive environ− Shipped in packages containing not more than 10 ball

Scope of Coverage: Exemption for EMI-Sensitive Applications
22 | Building Technologies Program 

Issue for Discussion

Issue 1: DOE invites comment on the appropriateness creating an exemption for T8 magnetic ballasts as a solthe problems caused by excessive EMI from electronic in EMI sensitive environments.
23 | Building Technologies Program 

• DOE establishes separate energy conservation stand

each product class.

• DOE divides covered product into classes by: 

– the type (gas, electric) of energy used; – the capacity of the equipment; and– any other performance-related features that require differen

levels, such as features affecting consumer utility. (42 USC 6295(q))

Product Classes: Criteria
24 | Building Technologies Program 

• In general, as lamp arc power increases, BLE increase

– Fixed losses of a ballast become proportionally less significa

lamp arc power as I2R losses begin to dominate.

• DOE empirically developed a relationship between BL

natural logarithm of lamp arc power. 

• Using an equation has several benefits over the prelim

analysis approach for determining product classes

– Simplifies the product class structure– Reduces the amount of scaling required

Product Classes: Power-Efficiency Relationship

Lamp Arc Power

PowerEfficiency Relationship

~ BLE
25 | Building Technologies Program 

• Establish a separate product class for PS ballasts v

and RS ballasts:

Impact on Efficiency

• PS ballasts have lower BLEs than IS and RS ballasts 

electrode heating.

Consumer Utility

• Occupancy sensors are predominantly used with PS b

rather than IS or RS ballasts.

• IS ballasts are common replacements for RS ballasts. 

Product Classes: PS Starting Method
26 | Building Technologies Program 

• Establish a separate product class for ballasts that 

8-foot HO lamps:

Impact on Efficiency

• Compared to 8-foot slimline ballasts, DOE found that 

ballasts exhibited lower BLEs although they at operatelamp power.

Consumer Utility

• “Lumen package” refers to the quantity of light provide

lamp-and-ballast system. 

• Consumers use systems with different lumen package

different applications: high output systems may be useceiling or outdoor applications. 

Product Classes: 8-foot HO Ballasts
27 | Building Technologies Program 

• Establish a separate product class for ballasts that 

8-foot HO lamps in cold temperature outdoor signs:

Impact on Efficiency

• Sign ballasts have lower BLEs than comparable ballas

operate 8-foot HO lamps.

Consumer Utility 

• Regular 8-foot HO ballasts cannot always serve as su

for sign ballasts due to their lack of moisture seals and limited load specifications.

Product Classes: Sign Ballasts
28 | Building Technologies Program 

NOPR Product Classes

Description Product Class Num

IS and RS ballasts that operate

4-foot MBP lamps*8-foot slimline lamps 1

PS ballasts that operate

4-foot MBP lamps*4-foot MiniBP SO lamps4-foot MiniBP HO lamps

2

IS and RS ballasts that operate

8-foot HO lamps 3

PS ballasts that operate

8-foot HO lamps 4

Ballasts that operate

8-foot HO lamps in cold 

temperature outdoor signs 5

*Includes both commercial and residential ballasts
29 | Building Technologies Program 

Issues for Discussion

Issue 3: DOE seeks comment on the appropriateness ocombining several product classes from the preliminary In particular, DOE requests feedback on the decision to include several IS and RS ballasts (IS and RS ballasts toperate 4-foot MBP and 8-foot slimline lamps) and PS bin the same product class (PS ballasts that operate 4-fooand 4-foot T5 lamps).

Issue 2: DOE seeks comments on the appropriateness establishing efficiency standards using an equation depeon lamp-arc power.
30 | Building Technologies Program 

Issues for Discussion

Issue 5: DOE seeks comment on the appropriateness oestablishing a separate product class for ballasts that op8-foot HO lamps.

Issue 4: DOE seeks comments on the appropriateness including residential ballasts in the same product class athose that operate in the commercial sector.
31 | Building Technologies Program 

NOPR Rulemaking Stage

Framework

Document

Preliminary

Analysis

NOPR Final Rule

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use & End Use LoadCharacterization

ShipmentsAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Manufacturer Impact Analysis
32 | Building Technologies Program 

Õ Choose product classes and ballast types to be 

the engineering and life-cycle cost analysis. 

Õ Define characteristics of baseline models in each 

representative product class.

Õ Develop efficiency levels (ELs) that span the ran

efficiency from baseline to maximum technologicfeasible. 

Õ Determine manufacturer selling prices (MSP) for 

ballasts and their higher BLE substitutes.

Õ Scale results to product classes not analyzed.

Choose 

Representative 

Product Classes

Scale to Product 

Classes Not 

Analyzed

Define Baseline 

Models

Develop MSPs

Engineering Analysis:Methodology

Develop 

Efficiency Levels
33 | Building Technologies Program 

• DOE chose representative product classes and ballast 

Representative Product Classes and Ballast Types

PS Product Class

Sign Ballast 

Product Class

Two-lamp 4-ft MBP (Comm.) Two-lamp 4-ft MBP (Comm.)

Two-lamp 4-ft MBP (Res.) Two-lamp 4-ft MBP (Res.)

Four-lamp 4-ft 

Four-lamp 4-ft 

Two-lamp 8

Two-lamp 8

Two-lamp 8-ft HO Two-lamp 8-ft HO

Two-lamp 4-ft MBP Two-lamp 4-ft MBP

Four-lamp 4-ft MBP Four-lamp 4-ft MBP

Two-lamp 

Two-lamp 

Two-lamp 

Two-lamp 

4-lamp 8-ft HO 4-lamp 8-ft HO

IS and RS 

Product Class

8-ft HO IS and 

RS Product 

Class
34 | Building Technologies Program 

• A baseline ballast just meets the existing en

conservation standard or represents the moslowest BLE ballast for that ballast type.

• DOE selected multiple baseline ballasts fo

ballast types to ensure consideration of thassociated consumer economics. 

– For example, for ballasts that operate two 4-fo

lamps, DOE selected two baselines: T12, RS 

T8, IS ballasts.

Baseline Models

Choose 

Representative 

Product Classes

Scale to Product 

Classes Not 

Analyzed

Define Baseline 

Models

Develop MSPs

Develop 

Efficiency Levels
35 | Building Technologies Program 

• DOE plotted BLE versus total lamp arc pow

both standard- and high-efficiency product multiple manufacturers. 

• After regression analysis, DOE found that a 

logarithm relationship best modeled the obstrend between total lamp arc power and BL

• DOE plotted curves that aligned with natura

in BLE in the data using the following equat

Selection of Efficiency Levels

BLE = coefficient * ln (total lamp arc power) 

Choose 

Representative 

Product Classes

Scale to Product 

Classes Not 

Analyzed

Define Baseline 

Models

Develop MSPs

Develop 

Efficiency Levels
36 | Building Technologies Program 

Efficiency Levels: IS and RS Product Class

75.080.085.090.095.0

100.0

0.0 50.0 100.0 150.

Average measured lamp arc power (W)

BLE(%)

EEE
37 | Building Technologies Program 

Efficiency Levels:PS Product Class

80.085.090.095.0

100.0

0.0 50.0 100.0 150.0 200.0

Average measured lamp arc power (W)

BLE(%)
38 | Building Technologies Program 

• Tested multiple manufacturers, multiple product lines

• Sample Size

– Tested 5 samples for each representative unit

• All 5 samples in a given category tested at the same lab

• EL equations initially developed based on average test

• EL equation adjusted based on measurement variation 

– 0.8% reduction for measurement variation overall

• 0.6% reduction for lab to lab variation• 0.2% reduction for compliance equation

Efficiency Levels: Testing
39 | Building Technologies Program 

• Lab to lab variation affects reported efficiency:

– The same set of ballast samples tested at two different labo

have two different average BLEs. 

– 0.6 percent average difference in efficiency between data co

the two laboratories used by DOE

Measurement Variation: Lab to Lab
40 | Building Technologies Program 

• Manufacturing Variation

– Representative unit purchasing

• 3 samples in early 2009 • 2 samples in late 2010

• Compliance requirements affect reported efficiency:

– Manufacturers must report the lower of either the sample av

value calculated by an equation intended to account for varithe sample set.

– Reported value is on average 0.2 percent less than the aver

samples included in testing.

Measurement Variation: Sampling and Compliance Equation
41 | Building Technologies Program 

Representative Units

EL Lamp Type Starting Method Ballast Input Power BF BLE Min

Re

Baseline T12 RS 60.7 0.80 78.3% 

EL1/

Baseline T8 IS 61.1 0.90 85.8% 

EL2 T8 IS 58.1 0.90 90.2% EL3 T8 IS 52.8 0.84 92.2% 

• IS and RS ballasts that operate two 4-foot MBP lamps: 
42 | Building Technologies Program 

Efficiency Levels

Representative Product Class

Efficiency 

Level BLE

IS and RS ballasts that operate

4-foot MBP lamps8-foot slimline lamps

EL1 2.98 * ln(total lamp arc powEL2 2.48 * ln(total lamp arc powEL3 1.32 * ln(total lamp arc pow

PS ballasts that operate

4-foot MBP lamps4-foot MiniBP SO lamps4-foot MiniBP HO lamps

EL1 2.48 * ln(total lamp arc powEL2 2.48 * ln(total lamp arc powEL3 1.79 * ln(total lamp arc pow

IS and RS ballasts that operate

8-foot HO lamps

EL1 1.49 * ln(total lamp arc powEL2 1.49 * ln(total lamp arc powEL3 1.49 * ln(total lamp arc pow

Ballasts that operate

8-foot HO lamps in cold 

temperature outdoor signs

EL1 1.49 * ln(total lamp arc pow
43 | Building Technologies Program 

Issue for Discussion

Issue 7: DOE requests comment on the appropriateness of the ef

levels DOE considered for fluorescent ballasts.
44 | Building Technologies Program 

• DOE has determined the highest efficiency levels are 

maximum technologically feasible for a sufficient dive

products (spanning several ballast factors, number of per ballast, and types of lamps operated).

• However, DOE is still considering whether an even hig

efficiency level is technologically feasible and presentanalysis of this higher EL in the TSD. 

Max-Tech Levels
45 | Building Technologies Program 

Advanced Technology Scenario

75.080.085.090.095.0

100.0

0.0 50.0 100.0 150.0

Average measured lamp arc power (W)

BLE(%)

Adv

EL3EL2EL1
46 | Building Technologies Program 

Issue for Discussion

Issue 8: DOE requests comment on the selection of the maximum 

technologically feasible level and whether it is technologically feasibthese higher efficiencies for the full range of instant start (IS) ballastSpecifically, DOE seeks quantitative information regarding the potein efficiency, the design options employed, and the associated chanAny design option that DOE considers to improve efficiency must mcriteria outlined in the screening analysis: 

(1) technological feasibility; (2) practicability to manufacture, install, and service; (3) adverse impacts on product or equipment utility to consu

availability; and 

(4) adverse impacts on health or safety. 

DOE also requests comments on any technological barriers to an imin efficiency above TSL 3 for all or certain types of ballasts.
47 | Building Technologies Program 

• DOE developed prices using four different 

– Teardown data– Distributor list prices (blue book)– Retail prices from online distributors– Aggregated manufacturer-supplied prices

Prices

Choose 

Representative 

Product Classes

Scale to Product 

Classes Not 

Analyzed

Define Baseline 

Models

Develop MSPs

Develop 

Efficiency Levels

6.007.008.009.00

10.0011.0012.0013.00

MSP ($)

2‐lamp MBP IS and RS
48 | Building Technologies Program 

• The following table shows the MSP associated with each 

ballasts that operate two-lamp 4-foot MBP lamps:

Manufacturer Selling Price:Two 4-foot MBP Lamps

EL Lamp Type BF BE MSP ($2009)

Baseline T12 0.80 78.3% $8.41

EL1/

Baseline T8 0.90 85.8% $6.94

EL2 T8 0.90 90.2% $8.85EL3 T8 0.84 92.2% $9.27

Issue 6: DOE requests comments on the method used to 

manufacturer selling prices.
49 | Building Technologies Program 

• DOE analyzed test data to determine the 

relationship between ballasts that have dstarting methods.

• DOE focused its effort on extensive test 

ballasts that operate 4-foot MBP lamps

• DOE found this average IS to PS reducti

2% and therefore applied this scaling facthe 8-foot HO IS and RS ELs to calculate foot HO PS ELs.

Scaling ELs: 8-foot HO PS

Choose 

Representative 

Product Classes

Scale to Product 

Classes Not 

Analyzed

Define Baseline 

Models

Develop MSPs

Develop 

Efficiency Levels
50 | Building Technologies Program 

Trial Standard Levels

Representative Product Class TSL 1 TSL 2 

IS and RS ballasts that operate

4-foot MBP lamps8-foot slimline lamps

EL1 EL2 

PS ballasts that operate

4-foot MBP lamps4-foot MiniBP SO lamps4-foot MiniBP HO lamps 

EL1 EL2 

IS and RS ballasts that operate

8-foot HO lamps EL1 EL2 

Ballasts that operate

8-foot HO lamps in cold temperature outdoor signs 

EL1 EL1 
51 | Building Technologies Program 

Public Meeting Agenda

234

Background and Legal Authority

5

2 Market & Tech; Screening; Engineering3 Energy Use; Markup Analysis

41 Overview5

Life-Cycle Cost and Payback Period Analysis

National Impact Analysis

6 MIA; NOPR Analyses
52 | Building Technologies Program 

Framework

Document

Preliminary

Analysis

NOPR Final Rule

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use & End Use LoadCharacterization

ShipmentsAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Manufacturer Impact Analysis

NOPRRulemaking Stage
53 | Building Technologies Program 

• Annual energy consumption (kWh) 

= system input power x annual operating hours

• DOE updated annual operating hours with data from DO

surveys (LMC, CBECS, MECS, RECS).

• DOE’s assumed annual operating hours capture variatio

across census divisions and large States, building typeslighting applications.

Energy Use Calculation 

Sector

Average Annual

Operation

(hrs/yr)

Commercial 3,886

Commercial (PS)* 2,720

Industrial 4,747

Residential 789

* PS ballasts operating 4-foot MBP lamps on occupancy sensors.
54 | Building Technologies Program 

• DOE developed markups to relate manufacturer selling price

end-user ballast prices.

• DOE estimated percentage of shipments for distribution cha

(columns 1, 2 & 3), MSPs, and used current company balan(SEC form 10-K) for markups analysis.

• DOE added a (home improvement) retailer distribution chan

3) and investigated actual markups for NOPR.

Markups Analysis

Via OEMs Via Wholesalers Via Retailers

Baseline Incremental Baseline Incremental Baseline Incr

OEM FixtureManufacturer 1.50 1.17 --- --- 1.50 ElectricalWholesaler 1.23 1.05 1.23 1.05 --- Home Improvement Retailer

--- --- --- --- 1.51 

Contractor 1.13 1.13 1.13 1.13 --- Sales Tax 1.07 1.07 1.07Estimated %of Shipments 63 37 100Weighted OverallBaseline Markup 1.96 2.43Weighted OverallIncremental Markup 1.41 1.43
55 | Building Technologies Program 

Public Meeting Agenda

234

Background and Legal Authority

5

2 Market & Tech; Screening; Engineering3 Energy Use; Markup Analysis

41 Overview5

Life-Cycle Cost And Payback Period Analysis

National Impact Analysis

6 MIA; NOPR Analyses
56 | Building Technologies Program 

Framework

Document

Preliminary

Analysis

NOPR Final Rule

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use & End Use LoadCharacterization

ShipmentsAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Manufacturer Impact Analysis

NOPRRulemaking Stage
57 | Building Technologies Program 

• Economic evaluation from the end-user perspective.• Results are expressed as LCC savings (baseline minus 

standard level).

• Simple payback period (PBP) is also calculated and rep

this analysis.

Life-Cycle Cost andPayback Period Analysis

Combine 

Changes 

in Costs

LC

First Cost (End-User Price + Installation Cost)

Operating Expenses

Convert to 

Present 

Value
58 | Building Technologies Program 

• In general, LCC savings were strongly positive at TSL3• Exceptions – where T8 ELs compared to T8 baseline E

negative:

– PC1 (two 4-foot MBP lamps, residential)– PC3 (two 8-foot HO lamps)

• Positive LCC savings were typically unchanged by 

uncertainty/variation in inputs such as:

– operating hours– electricity prices– discount rates– sales tax rates– disposal costs

LCC-PBP Analysis Results
59 | Building Technologies Program 

Public Meeting Agenda

234

Background and Legal Authority

5

2 Market & Tech; Screening; Engineering3 Energy Use; Markup Analysis

41 Overview5

Life-Cycle Cost and Payback Period Analysis

National Impact Analysis

6 MIA; NOPR Analyses
60 | Building Technologies Program 

Framework

Document

Preliminary

Analysis

NOPR Final Rule

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use & End Use LoadCharacterization

ShipmentsAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Manufacturer Impact Analysis

NOPRRulemaking Stage
61 | Building Technologies Program 

• Historical NEMA shipments: estimated using U.S. Cens

Current Industrial Reports (CIR) (1990-2005).

– CIR remains the primary historical shipments data source– Adjusted for non-NEMA shipments in prelim and NOPR an

• Projected shipments: lifetime and growth assumptions 

produced an oscillating pattern in future shipments.

– Retained average ballast lifetimes for NOPR and used a W

distribution for lifetimes.

– For NOPR, considered historical decline in magnetic balla

shipments in projections for electronic ballasts (4-foot MBP 

– Retained existing and emerging technology scenarios for 

Shipments Analysis-1
62 | Building Technologies Program 

Shipments Analysis-2

‐

50

100150200250

Shipments in millions

PC 1 Replacement PC 1 New construction

Shipments for PC1—IS and RS Ballasts That Operate 4-Foot MBP and 8-Foot Slimline Lamps (Existing Technologies Scenario)

• Shipments by “life event”: replacement shipments assu

greater than new construction/retrofit shipments.

– For NOPR, literature (e.g., AEO) from recent years sugge

modest floor space growth and retrofit rates, supporting Dassumption that replacements dominate shipments.

‐

12345678

Shipments in millions

PC 5 Replacement PC 5 New construction

Shipments for PC 5—IS and RS SigThat Operate 8-Foot RDC HO LampTechnologies Scenario)
63 | Building Technologies Program 

• Sign ballasts: Prelim analysis used indoor ballast metho

i.e., shipments proportional to floor space growth and rerates, resulting in unrealistically high ballast shipment fo

– For NOPR, included electronic designs in base case subs– Did not assume new shipments were proportional to floors

growth and assumed lower retrofit rates, thus reducing groand shipments for NOPR.

– Added emerging technology scenario for NOPR to accoun

limited LED penetration in backlighting applications.

Shipments Analysis-3
64 | Building Technologies Program 

Shipments Base Case Existing Tech

‐

20,000,00040,000,00060,000,00080,000,000

100,000,000120,000,000

Shipments

2 x T5 SO

2x4-ft MBP IS-RS (com)

4x4-ft MBP IS-RS

2x4-ft MBP IS

2 x T5 
65 | Building Technologies Program 

Shipments Base Case Emerging Tech

‐

20,000,00040,000,00060,000,00080,000,000

100,000,000120,000,000

Shipments

2x4-ft MBP IS

2x4-ft MBP IS-RS (com)

2 x T5 

4x4-ft MBP IS-RS

2 x T5 SO
66 | Building Technologies Program 

• National energy savings (NES) and net present value (N

calculated for period from 2014-2043.

National Impacts Analysis (NIA)

Shipments Model

National Energy Savings

NationalEconomicImpacts

LCC Analysis Results and Other Inputs

National 

Energy Savings 

(Quads)

National 

Net Present Value 

($ billions)

at 3% and 7% DR
67 | Building Technologies Program 

TSL3• National energy savings increase with efficiency of insta

– Cumulative NES = 6.25 quads

• Net present value rises and then falls (discounting).

– Varies by product class, EL, scenario.– Cumulative NPV = $11.4 billion (7% DR), $24.7 billion (3

NIA Results: Existing Tech, Shift

(100)

‐

100200300400500600700

2009$ in millions

Net Present Value at 7% 

NPV Discounted operating costs change Di

‐

0.050.100.150.200.250.300.350.40

Energy savings, quads

National Energy Savings
68 | Building Technologies Program 

NIA Results: Emerging Tech, Roll Up

(100)

‐

100200300400500600700

2009$ in millions

Net Present Value at 7% 

NPV Discounted operating costs change 

TSL3• National energy savings increase with efficiency of insta

– Cumulative NES = 3.70 quads

• Net present value rises and then falls (discounting).

– Varies by product class, EL, scenario.– Cumulative NPV = $8.13 billion (7% DR), $16.5 billion (3

‐

0.050.100.150.200.250.300.350.40

Energy savings, quads

National Energy Savings
69 | Building Technologies Program 

Public Meeting Agenda

234

Background and Legal Authority

5

2 Market & Tech; Screening; Engineering3 Energy Use; Markup Analysis

41 Overview5

Life-Cycle Cost and Payback Period Analysis

National Impact Analysis

6 MIA; NOPR Analyses
70 | Building Technologies Program 

Framework

Document

Preliminary

Analysis

NOPR Final Rule

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

Energy Use & End Use LoadCharacterization

ShipmentsAnalysis

Markups forEquipmentPriceDetermination

Life-CycleCost andPayback Period Analysis

Manufacturer Impact Analysis

NOPRRulemaking Stage
71 | Building Technologies Program 

• Purpose

– To assess the impacts of standards on manufacturers;– To identify and estimate impacts on manufacturer sub-group

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

– To examine the direct employment impacts, manufacturing 

and the cumulative regulatory impact on the industry.

• Methodology 

– Analyze industry cash flow and industry net present value (I

through use of the Government Regulatory Impact Model (G

– Interview manufacturers to refine inputs to the GRIM, develo

group analyses, and address qualitative issues.

Manufacturer Impact Analysis (MIA)
72 | Building Technologies Program 

Industry profile

Develop straw-man GRIM*

Develop interview guide

Interviews & 

industry-wide/ 

subgroup 

analyses

Assess direct employment, manufacturing capacity, and cumulative burde

Phase 2

* Government Regulatory Impact Model (GRIM)

Phase 1 Phase 3

Manufacturer Impact Analysis:Overview
73 | Building Technologies Program 

• Impacts on Profits

– Higher standards may eliminate manufacturers’ ability to offe

products at two compliant efficiency levels (e.g. baseline and efficiency), which could lower profit margins.

• Market Impact and Opportunity Cost of Investments

– With mature technologies such as fluorescent ballasts, new 

may force investment in a low-growth or even shrinking marhasten consumers’ switch to emerging technologies

– Manufacturers’ resources for the development of new produ

decrease when they are deployed to redesign mature produof new standards.

• Regulatory Impact

– Manufacturers are concerned with the number of ongoing Fe

lighting standards

• Component Shortage

– Electronic component suppliers scaled back production duri

recent recession, but have not increased production since drecovered

Manufacturer Impact Analysis:Manufacturer Key Issues
74 | Building Technologies Program 

• DOE modeled eight different scenarios representing all combi

– Two markup scenarios (preservation of operating profit markup and two-tie– Two technology scenarios (existing technologies and emerging technologie– Two shipment scenarios (roll-up and shift)

• Upper Bound Scenario (Lowest Impacts) - Preservation of Ope

Markup, Existing Technologies, and Shift Shipments

– Manufacturers maintain same level of operating profits (earnings before int

absolute terms) in the standards case as the base case

– Shipments are unaffected by emerging technologies– Efficiency-conscious consumers at or above the new standard level may se

higher efficiency level 

• Lower Bound Scenario (Highest Impacts) - Two-Tier Markup, E

Technologies, and Roll-Up Shipments

– Higher energy conservation standards result in lower manufacturer markup

earn a premium in the base case

– Ballasts lose market share to emerging technologies such as LEDs over the – Only consumer purchases below the new standard level are affected by the 

Manufacturer Impact Analysis:Scenarios Analyzed
75 | Building Technologies Program 

• Preservation of Operating Profit Markup, Existing 

Technologies, and Shift Shipment Scenario (Upper Bo

• Two-Tier Markup, Emerging Technologies, and Roll-U

Shipment Scenario (Lower Bound)

Manufacturer Impact Analysis:INPV Results

Units Base Case

Trial Standard Lev

12 

INPV (2009$ millions) 1,241 1,221 1,189 Change in INPV (2009$ millions) - (19.4) (51.6) 

(%) - -1.6% -4.2% 

Units Base Case

Trial Standard Lev

12 

INPV (2009$ millions) 853 740 635 Change in INPV (2009$ millions) - (112.7) (217.9) (

(%) - -13.2% -25.5% -
76 | Building Technologies Program 

• DOE identified several domestic small business manuf

of fluorescent lamp ballasts

– Small manufacturers are able to compete due to the fragmen

the fixture industry

– Ballast production is almost exclusively abroad, even for sma

manufacturers

– Small ballast manufacturers typically offer a wide variety of lig

products and do not focus exclusively on fluorescent lamp ba

– Small businesses lack the scale to meet the extensive produc

development, testing, and certification requirements needed fstandard levels

• With a new standard, those small businesses with in-h

design and production may consolidate and reduce the 

of product lines they offer.

Manufacturer Impact Analysis:Small Business Impacts
77 | Building Technologies Program 

Issues for Discussion

Issue 12: DOE requests comment on the potential impamended standards on the small fluorescent lamp ballamanufacturers.Issue 11: DOE requests comment the methodology aninputs used for the manufacturer impact analysis—specDOE’s assumptions regarding markups, capital costs, aconversion costs.
78 | Building Technologies Program 

• Subgroups were identified by interested parties as pote

more sensitive to economic impacts of new standard.

• DOE examined three consumer subgroups (input varied

– Low-income consumers (fractionally higher electricity pric– Institutions of religious worship (reduced operating hours)– Institutions that serve low-income populations (higher disc

• Results consistent with the main LCC-PBP analysis.

– Robust LCC savings resistant to variation in inputs.

LCC Subgroup Analysis
79 | Building Technologies Program 

• Increased electric efficiency Æ reduced electricity dem

Utility Impact Analysis

Trial 

Standard 

Level

Cumulative reduction in electric generating capacity

(gigawatts)

Existing Technologies,

Shift

Emerging Technologi

Roll-up

1 4.17 1.512 5.20 2.993 7.22 4.37
80 | Building Technologies Program 

Employment Analysis

• DOE modeled the indirect effects of higher efficiency pr

on national employment.

Analysis 

Period 

Year

Trial 

Standard 

Level

Net national change in jobs

(thousands)

Existing Technologies,

Shift

Emerging Technolo

Roll-up

2020

1 12.6 3.672 2.89 2.593 3.63 3.31

2043

1 124 31.82 63.2 37.13 89.5 51.1
81 | Building Technologies Program 

• Reduced energy demand Æ reduced air pollutant emis

Environmental Impact Analysis

Trial 

Standard 

Level

Cumulative reduction in emissions (2014 through 2043)

Existing Technologies,

Shift

Emerging Technologies,

Roll-up

CO2

(MMt)

NOX

(kt)

Hg

(t)

CO2

(MMt)

NOX

(kt)

Hg

(t)

1 70 26 0.96 14 11 0.202 87 32 1.20 27 22 0.403 121 44 1.67 40 32 0.59
82 | Building Technologies Program 

Proposed Energy Conservation Standards – TSL 3

Description

Representative 

BLE Equatio

IS and RS ballasts that operate

two 4-foot MBP lampsfour 4-foot MBP lampstwo 8-foot slimline lampstwo 4-foot MBP lamps in the 

residential sector

91.2%92.2%92.2%92.3%

1.32 * ln(total lamp ar

PS ballasts that operate

two 4-foot MBP lampsfour 4-foot MBP lampstwo 4-foot T5 SO lamps two 4-foot T5 HO lamps

90.4%91.7%90.7%91.6%

1.79 * ln(total lamp ar

IS and RS ballasts that operate

two 8-foot T8 HO lamps 91.6% 1.49 * ln(total lamp ar

PS ballasts that operate

8-foot HO lamps 89.8% 1.46 * ln(total lamp ar

Ballasts that operate

four 8-foot HO lamps in cold 

temperature outdoor signs

89.6% 1.49 * ln(total lamp ar
83 | Building Technologies Program 

In all correspondence, include all of the following:

– Energy Conservation Standards for Fluorescent Lamp B– Docket Number EERE-2007–BT–STD–0016– Regulatory Identification Number (RIN) 1904–AB50

Email: ballasts.rulemaking@ee.doe.gov

Comment period closes: Friday, June 10, 2011, midnight EDT

DOE Seeks Comments on its Proposal

Postal Mail: 

Ms. Brenda EdwardsU.S. Department of EnergyBuilding Technologies ProgramMailstop EE-2J1000 Independence Avenue, S.W.Washington, DC 20585-0121

Courier: 

Ms. Brenda EdwardsU.S. Department of EneBuilding Technologies P950 L’Enfant Plaza, S.W

Washington, DC 20024 Telephone: (202) 586-29

DOE Seeks Comments on its Proposal