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Printable Version 

Fluorescent Lamp Ballasts 

Public Meeting to Discuss the 

Preliminary Analyses in the 

Energy Conservation Standard 

Rulemaking 

The U.S. Department of Energy (DOE) is 

holding a public meeting that will first cover 

the test procedure notice of proposed 

rulemaking (NOPR) for fluorescent lamp 

ballasts and then the energy conservation 

standards rulemaking for the same products. 

This public meeting gives DOE an opportunity 

to discuss and receive comments on: (1) the 

product classes that DOE analyzed for 

purposes of amending energy conservation 

standards for certain fluorescent lamp 

ballasts; (2) the analytical framework, 

models, and tools that DOE is using to 

evaluate standards for these products; (3) the 

results of preliminary analyses performed by 

DOE for these products; and (4) the potential 

energy conservation standard levels derived 

from these analyses that DOE could consider 

for these products. DOE is publishing this 

notice of public meeting to announce the 

availability of the preliminary technical 

support document which details the 

preliminary analyses, discusses the comments 

on the framework document, and summarizes 

the preliminary results. In addition, it 

announces a public meeting to solicit feedback 

EERE Information Center

Programs and Offices 

DATE: April 26, 2010 

TIME: 9:00 a.m. ET 

LOCATION:

U.S. Department of Energy 

Forrestal Building 

Room 8E-089 

1000 Independence Avenue, SW 

Washington, DC 20585 

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EERE-2007-BT-STD-0016 COMMENT 18
from interested parties on the analytical 

framework, models, and preliminary results. 

The following documents are available as 

Adobe Acrobat PDFs. Download Adobe 

Reader. 

Meeting Materials 

z Energy Conservation Standards for 

Fluorescent Lamp Ballasts: Notice of 

Public Meeting and Availability of the 

Preliminary Technical Support 

Document, as issued by the 

Department of Energy (PDF 147 KB) 

NOTE: The official version of the 

NOPM will be published in the Federal 

Register shortly. 

z Presentation (available after meeting) 

z Agenda (available after meeting) 

z Transcript (available after meeting) 

A transcript will also be available for public 

inspection in the Building Technologies 

Program Reading Room, between 9:00 a.m. 

and 4:00 p.m., Monday through Friday, 

except Federal holidays. To schedule an 

appointment or to purchase this transcript, 

contact: 

Brenda Edwards 

U.S. Department of Energy 

Building Technologies Program 

950 L'Enfant Plaza, 6th Floor 

Washington, DC 20024 

202-586-2945 

How to Submit Comments 

All comments submitted to DOE must 

identify the rulemaking to which it 

corresponds. All comments submitted must 

identify the docket number and regulatory 

identifier number (RIN). 

z Docket Number EERE-2007-BT-STD0016 and RIN 1904–AB50. 

Comments may be submitted using any of 

the following methods: 

z Federal eRulemaking Portal: 

http://www.regulations.gov/

Follow the instructions for submitting 

comments. 

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EERE-2007-BT-STD-0016 COMMENT 18
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Webmaster | Web Site Policies | Security & Privacy | USA.gov 

Content Last Updated: 03/19/2010 

z Email: 

ballasts.rulemaking@ee.doe.gov

Include docket number EERE-2007-

BT-STD-0016 and/or RIN 1904-AB50 

in the subject line of the message. 

z Postal Mail: 

Brenda Edwards 

U.S. Department of Energy 

Building Technologies Program 

Mailstop EE-2J 

1000 Independence Avenue, SW 

Washington, DC 20585 

Please include one signed paper 

original. 

z Hand Delivery/Courier: 

Brenda Edwards 

U.S. Department of Energy 

Building Technologies Program, Sixth 

Floor 

950 L'Enfant Plaza, SW 

Washington, DC 20024 

202-586-2945 

Please include one signed paper 

original. 

Contact Information 

Linda Graves

Project Manager 

202-586-1851 

Printable Version 

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EERE-2007-BT-STD-0016 COMMENT 18
[6450-01-P] 

DEPARTMENT OF ENERGY 

10 CFR Part 430 

(Docket No. EERE-2007-BT-STD-0016) 

RIN: 1904-AB50 

Energy Conservation Standards for Fluorescent Lamp Ballasts: Public Meeting and 

Availability of the Preliminary Technical Support Document 

AGENCY: Office of Energy Efficiency and Renewable Energy, Department of Energy. 

ACTION: Notice of public meeting and availability of preliminary technical support document. 

SUMMARY: The U.S. Department of Energy (DOE) will hold a public meeting to discuss and 

receive comments on: the product classes that DOE plans to analyze for purposes of establishing 

energy conservation standards for fluorescent lamp ballasts; the analytical framework, models, 

and tools that DOE is using to evaluate standards for these products; the results of preliminary 

analyses DOE performed for these products; and potential energy conservation standard levels 

derived from these analyses that DOE could consider for these products. DOE encourages 

written comments on these subjects. To inform interested parties and facilitate this process, DOE 

has prepared an agenda, a preliminary technical support document (TSD), and briefing materials, 

which are available at 

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EERE-2007-BT-STD-0016 COMMENT 18
http://www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_ballast

s.html. 

DATES: DOE will hold a public meeting on Monday, April 26, 2010, beginning at 9:00 a.m. in 

Washington, DC. The agenda for the public meeting will first cover the concurrent test procedure 

rulemaking for fluorescent lamp ballasts (see proposal in today’s Federal Register), and then this 

energy conservation standards rulemaking for the same products. Any person requesting to speak 

at the public meeting should submit such a request, along with an electronic copy of the 

statement to be given at the public meeting, before 4:00 p.m., Monday, April 12, 2010. Written 

comments are welcome, especially following the public meeting, and should be submitted by 

[INSERT DATE, 45 DAYS AFTER PUBLICATION OF THIS NOTICE]. 

ADDRESSES: The public meeting will be held at the U.S. Department of Energy, Forrestal 

Building, Room 8E-089, 1000 Independence Avenue, SW., Washington, DC 20585-0121. 

Please note that foreign nationals participating in the public meeting are subject to advance 

security screening procedures. If a foreign national wishes to participate in the public meeting, 

please inform DOE of this fact as soon as possible by contacting Ms. Brenda Edwards at (202) 

586-2945 so that the necessary procedures can be completed. Interested persons may submit 

comments, identified by docket number EERE-2007-BT-STD-0016, by any of the following 

methods: 

• Federal eRulemaking Portal: http://www.regulations.gov Follow the instructions for 

submitting comments. 

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EERE-2007-BT-STD-0016 COMMENT 18
• E-mail: ballasts.rulemaking@ee.doe.gov. Include EERE-2007-BT-STD-0016 and/or RIN 

1904-AB50 in the subject line of the message. 

• Postal Mail: Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies 

Program, Mailstop EE-2J, Public Meeting for Fluorescent Lamp Ballasts, EERE-2007-

BT-STD-0016, 1000 Independence Avenue, SW., Washington, DC 20585-0121. 

Telephone (202) 586-2945. Please submit one signed paper original. 

• Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of Energy, Building 

Technologies Program, Sixth Floor, 950 L’Enfant Plaza, SW., Washington, DC 20024. 

Telephone (202) 586-2945. Please submit one signed paper original. 

Instructions: All submissions received must include the agency name and docket number.

Docket: For access to the docket to read background documents or a copy of the 

transcript of the public meeting or comments received, go to the U.S. Department of Energy, 

Sixth Floor, 950 L’Enfant Plaza, SW., Washington, DC 20024, (202) 586-2945, between 9:00 

a.m. and 4:00 p.m., Monday through Friday, except Federal holidays. Please call Ms. Brenda 

Edwards at (202) 586-2945 for additional information regarding visiting the Resource Room. 

FOR FURTHER INFORMATION CONTACT: Direct requests for additional information to 

Ms. Linda Graves, U.S. Department of Energy, Office of Energy Efficiency and Renewable 

Energy, Building Technologies, EE-2J, 1000 Independence Avenue, SW., Washington, DC 

20585-0121, (202) 586-8654. E-mail: Linda.Graves@ee.doe.gov. In the Office of General 

Counsel, contact Ms. Francine Pinto or Ms. Elizabeth Kohl, U.S. Department of Energy, Office 

of General Counsel, GC-71, 1000 Independence Avenue, SW., Washington, DC 20585, (202) 

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EERE-2007-BT-STD-0016 COMMENT 18
586-7432. E-mail: Francine.Pinto@hq.doe.gov; Elizabeth.Kohl@hq.doe.gov. 

SUPPLEMENTARY INFORMATION: 

I. Statutory Authority

II. History of Standards Rulemaking for Fluorescent Lamp Ballasts

A. Background

B. Current Rulemaking Process

III. Summary of the Analyses

A. Engineering Analysis

B. Energy Use Characterization

C. Markups to Determine Installed Price

D. Life-Cycle Cost and Payback Period Analyses

E. National Impact Analysis

I. Statutory Authority 

 The Energy Policy and Conservation Act (EPCA) of 1975, Pub. L. 94–163 (42 

U.S.C. 6291–6309), established an energy conservation program for major household appliances. 

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. These 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 to 

apply 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 rulemaking 

cycle to amend energy conservation standards for fluorescent lamp ballasts. 65 FR 56740, 

56740-56749 (September 19, 2000). This rulemaking encompasses DOE’s second cycle of 

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EERE-2007-BT-STD-0016 COMMENT 18
review to determine whether the standards in effect for fluorescent lamp ballasts should be 

amended and whether the standards should be applicable to additional fluorescent lamp ballasts. 

 DOE must design each standard for these products to (1) achieve the maximum 

improvement in energy efficiency that is technologically feasible and economically justified, and 

(2) result in significant conservation of energy. (42 U.S.C. 6295(o)(2)(A) and (o)(3)) To 

determine whether a proposed standard is economically justified, DOE must determine whether 

the benefits of the standard exceed its burdens to the greatest extent practicable, weighing the 

following seven factors: 

1. the economic impact of the standard on manufacturers and consumers of products subject 

to the standard; 

2. the savings in operating costs throughout the estimated average life of the covered 

products in the type (or class) compared to any increase in the price, initial charges, or 

maintenance expenses for the covered products which are likely to result from the 

imposition of the standard; 

3. the total projected amount of energy savings likely to result directly from the imposition 

of the standard; 

4. any lessening of the utility or the performance of the covered products likely to result 

from the imposition of the standard; 

5. the impact of any lessening of competition, as determined in writing by the Attorney 

General, that is likely to result from the imposition of the standard; 

6. the need for national energy conservation; and 

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EERE-2007-BT-STD-0016 COMMENT 18
7. other factors the Secretary [of Energy] considers relevant. 

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

Before proposing a standard, DOE typically seeks public input on the analytical 

framework, models, and tools that will be used to evaluate standards; the results of preliminary 

analyses; and potential energy conservation standard levels derived from these analyses. DOE is 

publishing this document to announce the availability of the preliminary technical support 

document (TSD), which details the preliminary analyses, discusses the comments on the 

framework document, and summarizes the preliminary results. In addition, DOE is announcing a 

public meeting to solicit feedback from interested parties on its analytical framework, models, 

and preliminary results.

II. History of Standards Rulemaking for Fluorescent Lamp Ballasts 

A. Background

 As mentioned above, NAECA 1988 amended EPCA to establish energy conservation 

standards for fluorescent lamp ballasts and require 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 (September 19, 

2000). This rulemaking established a consensus standard representing an agreement between the 

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EERE-2007-BT-STD-0016 COMMENT 18
fluorescent lamp ballast industry and energy efficiency advocacy organizations. A table of the 

standards DOE codified can be found in appendix 3A of the preliminary TSD and in 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 ballast 

efficacy requirements for “energy saver” versions of full-wattage ballasts, such as the F34T12 

ballast. 

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

of 2007 (EISA 2007; Pub. L. 110-140). EISA 2007 did not amend standards for fluorescent lamp 

ballasts, but instead 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)) DOE published a notice of proposed rulemaking (NOPR) for the standby and off 

mode test procedure on January 21, 2009. 74 FR 3450. In addition, DOE is directed to 

incorporate standby mode and off mode energy use in any amended (or new) standard adopted 

after July 1, 2010. (42 USC 6295(gg)(3)) 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. 

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EERE-2007-BT-STD-0016 COMMENT 18
 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 the standards 

should be made applicable to additional fluorescent lamp ballasts. This rulemaking also 

addresses 42 U.S.C. 6295(gg)(3), 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. 

 

 Under the consolidated Consent Decree in New York v. Bodman, No. 05 Civ. 7807 

(S.D.N.Y. filed Sept. 7, 2005) and Natural Resources Defense Council v. Bodman, No. 05 Civ. 

7808 (S.D.N.Y. filed Sept. 7, 2005) the U.S. Department of Energy is required to publish a final 

rule amending energy conservation standards for fluorescent lamp ballasts no later than June 30, 

2011. 

B. Current Rulemaking Process

 On January 22, 2008, DOE published a notice announcing the availability of the 

framework document, “Energy Conservation Standards Rulemaking Framework Document for 

Fluorescent Lamp Ballasts,” and a public meeting to discuss the proposed analytical framework 

for the rulemaking. 73 FR 3653. DOE also posted the framework document on its website 

describing the procedural and analytical approaches DOE anticipated using to evaluate the 

establishment of energy conservation standards for fluorescent lamp ballasts. This document is 

available at 

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

011408.pdf. 

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EERE-2007-BT-STD-0016 COMMENT 18
 DOE held a public meeting on February 6, 2008, to describe the various rulemaking 

analyses DOE would conduct, such as the engineering analysis, the life-cycle cost (LCC) and 

payback period (PBP) analyses, and the national impact analysis (NIA); the methods for 

conducting them; and the relationship among the various analyses. Manufacturers, trade 

associations, and environmental advocates attended the meeting. The participants discussed 

multiple issues, including the scope of covered fluorescent lamp ballasts, definitions, test 

procedures, the ballast efficiency metric, DOE’s engineering analysis, life-cycle costs, efficiency 

levels, and energy savings. 

 Comments received since publication of the framework document have helped DOE 

identify and resolve issues involved in the preliminary analyses. Chapter 2 of the preliminary 

TSD summarizes and addresses the comments DOE received. 

III. Summary of the Analyses 

DOE conducted in-depth technical analyses in the following areas for the fluorescent 

lamp ballasts currently under consideration: (1) engineering, (2) energy-use characterization, (3) 

markups to determine product price, (4) LCC and PBP, and (5) national impact. The preliminary 

TSD presents the methodology and results of each analysis. The analyses are described in more 

detail below. 

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EERE-2007-BT-STD-0016 COMMENT 18
 DOE conducted several other analyses that either support the five major analyses or are 

preliminary analyses that will be expanded in the NOPR. These include the market and 

technology assessment; the screening analysis, which contributes to the engineering analysis; and 

the shipments analysis, which contributes to the NIA. DOE has begun some preliminary work on 

the manufacturer impact analysis and identified the methods to be used for the LCC subgroup 

analysis, the environmental assessment, the employment analysis, the regulatory impact analysis, 

and the utility impact analysis. DOE will expand on these in the NOPR. 

A. Engineering Analysis

The engineering analysis establishes the relationship between the manufacturer selling 

price and the efficiency of the product. This relationship serves as the basis for cost-benefit 

calculations for individual consumers, manufacturers, and the nation. The engineering analysis 

identifies representative baseline models, which is the starting point for analyzing technologies 

that provide energy efficiency improvements. A baseline model refers to a model or models 

having features and technologies typically found in products currently offered for sale. The 

baseline model in each equipment class represents the characteristics of certain fluorescent lamp 

ballasts in that class and, for ballasts already subject to energy conservation standards, usually is 

a model that just meets the current standard. Chapter 5 of the preliminary TSD discusses the 

engineering analysis. 

B. Energy Use Characterization

The energy use characterization provides estimates of annual energy consumption for 

fluorescent lamp ballasts, which DOE uses in the LCC and PBP analyses and the NIA. DOE 

10

EERE-2007-BT-STD-0016 COMMENT 18
developed energy consumption estimates for all of the product classes analyzed in the 

engineering analysis as the basis for its energy use estimates. Chapters 2 and 6 of the preliminary 

TSD provide detail on the energy use characterization. 

C. Markups to Determine Installed Price

DOE derives the installed prices for products based on manufacturer markups, retailer 

markups, distributor markups, contractor markups, builder markups, and sales taxes. In deriving 

these markups, DOE has determined the distribution channels for product sales, the markup 

associated with each party in the distribution channels, and the existence and magnitude of 

differences between markups for baseline products (baseline markups) and for more-efficient 

products (incremental markups). DOE calculates both overall baseline and overall incremental 

markups based on the product markups at each step in the distribution channel. The overall 

incremental markup relates the change in the manufacturer sales price of higher-efficiency 

models (the incremental cost increase) to the change in the retailer or distributor sales price. 

Chapters 2 and 7 of the preliminary TSD provide detail on the estimation of markups. 

D. Life-Cycle Cost and Payback Period Analyses

 The LCC and PBP analyses determine the economic impact of potential standards on 

individual consumers. The LCC is the total consumer expense for a product over the life of the 

product. The LCC analysis compares the LCCs of products designed to meet possible energy 

conservation standards with the LCCs of the products likely to be installed in the absence of 

standards. DOE determines LCCs by considering (1) total installed cost to the purchaser (which 

11

EERE-2007-BT-STD-0016 COMMENT 18
consists of manufacturer selling price, sales taxes, distribution chain markups, and installation 

cost); (2) the operating expenses of the products (energy use and maintenance); (3) product 

lifetime; and (4) a discount rate that reflects the real consumer cost of capital and puts the LCC 

in present-value terms. The PBP represents the number of years needed to recover the increase in 

purchase price (including installation cost) of more efficient products through savings in the 

operating cost of the product. PBP is equal to the change in total installed cost due to increased 

efficiency divided by the change in annual operating cost from increased efficiency. Chapters 2 

and 8 of the preliminary TSD provide detail on the LCC and PBP analyses. 

E. National Impact Analysis

The NIA estimates the NES and the NPV of total consumer costs and savings expected to 

result from new standards at specific efficiency levels (referred to as candidate standard levels). 

DOE calculated NES and NPV for each level for each candidate standard for fluorescent lamp 

ballasts as the difference between a base-case forecast (without new standards) and the 

standards-case forecast (with standards). DOE determined national annual energy consumption 

by multiplying the number of units in use (by vintage) by the average unit energy consumption 

(also by vintage). Cumulative energy savings are the sum of the annual NES determined over a 

specified time period. The national NPV is the sum over time of the discounted net savings each 

year, which consists of the difference between total operating cost savings and increases in total 

installed costs. Critical inputs to this analysis include shipments projections, retirement rates 

(based on estimated product lifetimes), and estimates of changes in shipments and retirement 

rates in response to changes in product costs due to standards. Chapters 2 and 10 of the 

preliminary TSD provide detail on the NIA. 

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EERE-2007-BT-STD-0016 COMMENT 18
DOE consulted with interested parties on all of the analyses and invites further input on 

these topics. The preliminary analytical results are subject to revision following review and input 

from the public. A revised TSD will be made available upon issuance of a NOPR. The final rule 

will contain the final analysis results and be accompanied by a final rule TSD. 

DOE encourages those who wish to participate in the public meeting to obtain the 

preliminary TSD and be prepared to discuss its contents. However, public meeting participants 

need not limit their comments to the topics identified in the preliminary TSD. DOE is also 

interested in receiving information on other relevant issues that participants believe would affect 

energy conservation standards for these products or that DOE should address in the NOPR. 

DOE welcomes all interested parties, regardless of whether they participate in the public 

meeting, to submit comments and information in writing by [INSERT DATE 45 DAYS 

AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER]. 

The public meeting will be conducted in an informal, conference style. A court reporter 

will be present to record the minutes of the meeting. There shall be no discussion of proprietary 

information, costs or prices, market shares, or other commercial matters regulated by United 

States antitrust laws. 

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EERE-2007-BT-STD-0016 COMMENT 18
14

After considering all comments and additional information it receives from interested 

parties or through further analyses, DOE will prepare and publish in the Federal Register a 

NOPR. The NOPR will include proposed energy conservation standards for the products covered 

by the rulemaking. Members of the public will have an opportunity to submit written and oral 

comments on the proposed standards. 

 Issued in Washington, DC, on February 22, 2010. 

 _________________________________ 

 Cathy Zoi 

Assistant Secretary 

Energy Efficiency and Renewable Energy

EERE-2007-BT-STD-0016 COMMENT 18