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Printable Version Fluorescent Lamp Ballasts Preliminary Technical Support Document

The U.S. Department of Energy prepared this preliminary technical support document for the analyses conducted for its energy conservation standards rulemaking on fluorescent lamp ballasts.

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Title Page ( PDF 63 KB ) Executive Summary ( PDF 488 KB )

Chapters Chapter 1. Introduction ( PDF 163 KB ) Chapter 2. Analytical Framework ( PDF 517 KB ) Chapter 3. Market and Technology Assessment ( PDF 586 KB ) Chapter 4. Screening Analysis ( PDF 132 KB ) Chapter 5. Engineering Analysis ( PDF 1.1 MB ) Chapter 6. Energy Use Characterization ( PDF 211 KB ) Chapter 7. Markups Analysis ( PDF 224 KB ) Chapter 8. Life-Cycle Cost and Payback Period Analyses ( PDF 470 KB ) Chapter 9. Shipments Analysis ( PDF 495 KB ) Chapter 10. National Impacts Analysis ( PDF 576 KB ) Chapter 11. Life-Cycle Cost Sub-Group Analysis ( PDF 69 KB ) Chapter 12. Manufacturer Impact Analysis ( PDF 201 KB ) Chapter 13. Utility Impact Analysis ( PDF 99 KB ) Chapter 14. Employment Impact Analysis ( PDF 106 KB )

Reports
Environmental Assessment ( PDF 129 KB ) Regulatory Impact Analysis ( PDF 110 KB )

Appendices Appendix AA. Acronyms and Abbreviations ( PDF 79 KB ) Appendix 3A. U.S. Code and Code of Federal Regulations ( PDF 253 KB ) Appendix 5A. Material Prices ( PDF 109 KB ) Appendix 5B. T5 Baseline Ballasts ( PDF 135 KB ) Appendix 5C. Test Data ( PDF 198 KB ) Appendix 5D. Max-Tech ( PDF 146 KB ) Appendix 8A. User Instructions for Life-Cycle Cost Spreadsheet (coming soon) Appendix 10A. User Instructions for National Impact Analysis Spreadsheet (coming soon) Appendix 12A. Interview Guide ( PDF 234 KB ) Appendix EA-SCC. Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866 ( PDF 1.0 MB )

Contact Information

Linda Graves Project Manager

202-586-1851

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# PRELIMINARY TECHNICAL SUPPORT

DOCUMENT: ENERGY EFFICIENCY PROGRAM

FOR CONSUMER PRODUCTS AND CERTAIN COMMERCIAL AND INDUSTRIAL EQUIPMENT:

FLUORESCENT LAMP BALLASTS

March 2010

U.S. Department of Energy Assistant Secretary Office of Energy Efficiency and Renewable Energy Building Technologies Program Appliances and Commercia l Equipment Standards Washington, DC 20585

### This Document was prepared for the Department of Energy by staff members of Navigant Consulting, Inc., Pacific Northwest National Laboratory, and the Lighting Research Center

### EXECUTIVE SUMMARY

TABLE OF CONTENTS

ES.1 OVERVIEW OF PRELIMINARY ANALYSIS ACTIVITIES

......................................... 1

ES.2 KEY RESULTS OF THE ANALYSIS

.............................................................................. 3

ES.2.1 Determination of Scope

.......................................................................................... 3

ES.2.2 Market and Technology Assessment

...................................................................... 3

ES.2.3 Screening Analysis

.................................................................................................. 5

ES.2.4 Engineering Analysis

.............................................................................................. 5

ES.2.5 Energy Use Characterization

.................................................................................. 6

ES.2.6 Markups Analysis

................................................................................................... 7

ES.2.7 Life-Cycle Cost and Payback Period Analyses

...................................................... 8

ES.2.8 Shipments Analysis

............................................................................................... 10

ES.2.9 National Impact Analysis

...................................................................................... 14

ES.2.9.1 National Energy Savings Analysis

................................................ 15

ES.2.9.2 Net Present Value Analysis

.......................................................... 17

ES.2.10 Preliminary Manufacturer Impact Analysis

.............................................. 19

ES.2.11 Other Anal yses

.......................................................................................... 20

ES.3 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT

............................................. 20

ES.3.1 Test Procedures

..................................................................................................... 20

ES.3.2 Scope of Coverage

................................................................................................ 20

ES.3.3 Product Classes

..................................................................................................... 21

ES.3.4 Technology Options

.............................................................................................. 21

ES.3.5 Screening Analysis

................................................................................................ 21

ES.3.6 Candidate Standard Levels for Representative Product Classes

........................... 21

ES.3.7 Maximum Technologically Feasible Ballast

........................................................ 22

ES.3.8 Manufacturer Production Costs

............................................................................ 22

ES.3.9 Candidate Standard Levels for N on-Representative Pr oduct Classes

.................. 22

ES.3.10 Cumulative and Future Regulation

........................................................... 22

ES.3.11 Operating Profiles for Energy Use Characterization

................................ 23

ES.3.12 Lighting Controls and Balla st Operating Profiles

..................................... 23

ES.3.13 Price Markups

........................................................................................... 23

ES.3.14 Electricity Prices for LCC and PBP Analyses

.......................................... 24

ES.3.15 Effects of Energy Efficient Design on Ballast Life

.................................. 24

ES.3.16 Average Ballast Lifetimes and Failure Distributions

................................ 24

ES.3.17 Historical Shipments Data

........................................................................ 24

ES.3.18 Shipment Trends

....................................................................................... 25

ES.3.19 NIA and External Benefits

........................................................................ 25

ES.3.20 Trial Standard Levels

................................................................................ 25

ES.3.21 Impact on Manufacturers

.......................................................................... 25

ES.3.22 Valuing Air-Borne Emission Reductions

................................................. 25

ES-i

### LIST OF TABLES

Table ES.2.1 Scope of Coverage for Fl uorescent Lamp Ballast Rulemaking

................................. 3

Table ES.2.2 Product Classes for Fluorescent Lamp Ballasts

......................................................... 4 Table ES.2.3 Summary of Baselines and Candi date Standard Levels for Fluorescent Lamp Ballast Represen tative Product Classes

......................................................... 5 Table ES.2.4 Summary of Incremental Manufactur er Selling Prices Over the Baseline for Fluorescent Lamp Ballast Re presentative Product Classes

..................................... 6 Table ES.2.5 Average Annual Lamp-and-Ballast System Operating Hours by Sector

.................. 6 Table ES.2.6 Annual Energy Consum ption by Ballast Product Class

............................................ 7 Table ES.2.7 Markups for Ballasts

............................................................................................. .... 8 Table ES.2.8 Life-Cycle Cost and Pa yback Period Results for Ballasts

........................................ 9 Table ES.2.9 Cumulative National Energy Sa vings for Ballasts Under the Existing Technologies, Shift Scenario (2014–2044)

............................................................ 16 Table ES.2.10 Cumulative National Energy Sa vings for Ballasts Under the Emerging Technologies, Roll-Up Scenario (2014–2044)

...................................................... 17

Table ES.2.11 Cumulative NPV Results for Ba llasts Under the Existing Technologies, Shift Scenario (2014–2044)

................................................................................... 18

Table ES.2.12 Cumulative NPV Results for Ba llasts Under the Emerging Technologies, Roll-Up Scenario (2014–2044)

.............................................................................. 19

LIST OF FIGURES

Figure ES.1.1 Flow Diagram of Analyses for the Fluorescent Lamp Ballast Rulemaking

Process

..................................................................................................................... 2 Figure ES.2.1 Ballast Distribution Channels

................................................................................... 8 Figure ES.2.2 Base-Case Forecasted Shipme nts for Ballasts Operating Four-Foot MBP Lamps (Commercial Sector, Exis ting and Emerging Technologies Scenarios)

............................................................................................................... 11 Figure ES.2.3 Base-Case Forecasted Shipme nts for Ballasts Operating Eight-Foot RDC HO Lamps (Excluding Sign Ballasts)

.................................................................... 12 Figure ES.2.4 Base-Case Forecasted Shipme nts for Ballasts Operating Eight-Foot SP Slimline Lamps

...................................................................................................... 12 Figure ES.2.5 Base-Case Forecasted Shipme nts for Ballasts Operating Four-Foot T5 MiniBP SO and HO Lamps (Existing and Emerging Technologies Scenarios)

............................................................................................................... 13 Figure ES.2.6 Base-Case Forecasted Shipme nts for Ballasts Operating Four-Foot MBP Lamps in the Residential Sector

............................................................................ 14 Figure ES.2.7 Base-Case Forecasted Shipment s for Sign Ballasts Operating Eight-Foot RDC HO Lamps

..................................................................................................... 14

ES-ii

### EXECUTIVE SUMMARY

ES.1 OVERVIEW OF PRELIMINARY ANALYSIS ACTIVITIES

Section 6295(o)(3)(B) of 42 U.S.C. requires the U.S. Department of Energy (DOE) to establish energy conservation standards that are technologically feasible and economically justified, and that would achieve the maximum improvement in energy efficiency. This executive summary highlights the activities associated with this preliminary analysis that DOE conducted when considering amended energy conservation standards for fluorescent lamp ballasts. The executive summary also describes key results from DOE’s preliminary analysis and delineates issues on which DOE seeks comment. These issues are highlighted in the public meeting presentation and are further discussed in chapte r 2 of the preliminary technical support document (TSD).

Figure ES.1.1 presents a summary of the an alytical components of the standards-setting process and illustrates how key results are generated. The focal point of the figure is the center column, labeled “Analyses.” The columns labeled “Key Inputs” and “Key Outputs” show how the analyses fit into the process and how they relate to each other. Key inputs are the types of data and other information that the analyses require. Some key information is obtained from public databases; DOE collects other inputs from interested partie s or persons having special knowledge and expertise. Key outputs are analytical results that feed directly into the standardssetting process. The issues on which DOE seeks comment from interested parties derive from the key results that are generated by the pre-NOPR analyses. Arrows connecting analyses show the types of information that feed from one analysis to another.

ES-1

### Figure ES.1.1 Flow Diagram of Analyses for the Fluorescent Lamp Ballast Rulemaking

Process

ES-2

### ES.2 KEY RESULTS OF THE ANALYSIS

The following sections describe in detail the key analyses DOE performed.

ES.2.1 Determination of Scope

Amendments to the Energy Policy and Cons ervation Act of 1975 (EPCA) direct DOE to determine whether to amend energy conservati on standards for fluoresce nt lamp ballasts and

whether such standards should be made applicable to additional fluorescent lamp ballasts. (42

U.S.C. 6295(g)(7)(B)) After identifying additi onal ballasts for consid eration, DOE assessed whether each ballast type met the criteria for prescribing new or amended standards

⎯ i.e.

, potential for significant energy savings, technological feasibility, and economic justification. (42

U.S.C. 6295(o)(2)(A)) The following table summarize s the fluorescent lamp ballast market and indicates ballasts included in coverage by this rulemaking and ballasts not included in coverage (indicated by shading).

Table ES.2.1 Scope of Coverage for Fluorescent Lamp Ballast Rulemaking
Ballast-Specific Characteristic Lamp-Specific Characteristic

Dimmable Input Voltage

V Lamp Base Nominal Lamp Length

Feet Lamp Diameter Rated Lamp Wattage

W

Not

Dimmable Can operate within the range

of 120 to 277V Medium Bipin Four T8 and T12 ≥ 25

Miniature Bipin Four T5 ≥ 26 for std output

≥ 49 for high output
Single Pin Eight T8 and T12 ≥ 52

Recessed Double

Contact Eight T8 and T12 All



### ES.2.2 Market and Technology Assessment

A market and technology assessment charact erizes the relevant product markets and technology options, including prototype designs. See chapter 3 of the preliminary TSD for

details.

DOE generally divides covered products into product classes by the type of energy used or by capacity or other performance-related features that affect efficiency. Different energy conservation standards may apply to different product classes. (42 U.S.C. 6295(q)) Table ES.2.2 describes all of the product classes DOE is considering in this rulemaking.

ES-3

### Table ES.2.2 Product Classes for Fluorescent Lamp Ballasts

Number of Lamps Ballast and Lamp Type Starting

Method* Ballast

Factor** One Two Three Four Five Six

High 1 2 3 4 5 6

Normal 7 8 9 10 11 12 IS and RS

Low 13 14 15 16 17 18

High 19 20 21 22 23 24

Normal 25 26 27 28 29 30 4-Foot MBP and 2­

Foot U-Shaped

PS

Low 31 32 33 34 35 36

High 37 38 N/A N/A N/A N/A

Normal 39 40 N/A N/A N/A N/A 4-Foot T5 MiniBP

SO All

Low 41 42 N/A N/A N/A N/A

4-Foot T5 MiniBP All All 43 44 45 46 N/A N/A

High 47 48 N/A N/A N/A N/A

Normal 49 50 N/A N/A N/A N/A 8-Foot SP Slimline All

Low 51 52 N/A N/A N/A N/A

IS and RS All 53 54 N/A N/A N/A N/A 8-Foot RDC HO PS All 55 56 N/A N/A N/A N/A

IS and RS All 57 58 59 60 N/A N/A Residential Ballast,

4-Foot MBP and 2­

Foot U-Sha p ed PS All 61 62 63 64 N/A N/A

Sign Ballasts All All 65 66 67 68 69 70

*Starting methods include instant start (IS), rapid start (RS), and programmed start (PS) ** DOE classifies a low ballast factor as less than or equal to 0.78, a normal ballast factor as greater than 0.78 but less than 1.1, and a high ballast factor as greater than or equal to 1.1.



### DOE addresses (1) manufacturer market share and characteristics, (2) existing regulatory and non-regulatory initiatives for improving pr oduct efficiency, and (3) trends in product characteristics and retail markets. This information provides data and resource material throughout the analysis.

DOE reviews literature and in terviews manufacturers to de velop an overall understanding of the fluorescent lamp ballast industry. Industry publications, including trade journals, literature from manufacturers, government agencies, and trade organizations provide the bulk of the information, including: (1) manufacturers and their market share; (2) shipments by product type; (3) product information; and (4) industry trends.

DOE typically uses information about existing and past technology options and prototype designs to determine which tec hnologies and combinations of t echnologies manufacturers use to attain higher performanc e levels. In consultation with interest ed parties, DOE develops a list of technologies to be considered. The identifie d technologies initially include all those DOE believes are technologically feasible.

ES-4

### ES.2.3 Screening Analysis

DOE develops an initial list of options fo r enhancing efficiency from the technologies that the technology assessment identified as feasib le. In consultation with interested parties, DOE reviews the list to assess whether the technologie s are practicable to ma nufacture, install, and service; would adversely affect product utility or availability; or would have adverse impacts on health and safety. In the subsequent engineerin g analysis, DOE further examines the technology options that it did not remove from consideration in the screening analysis. See chapter 4 of the preliminary TSD for details.

ES.2.4 Engineering Analysis

The engineering analysis develops cost -efficiency relationships that show a manufacturer’s cost of achieving increased ef ficiency. DOE uses manufacturer markups to convert manufacturer production cost (MPC) to manufacturer selling price (MSP) (chapter 5).

The engineering analysis analyzed ten key product classes that cover the range of product classes within the fluorescent lamp ballast market. For each product class, DOE chose appropriate baseline ballasts and identified more efficient replacements. For each candidate lamp-and-ballast design, DOE calculated the manufacturer selling price, measured the ballast efficacy factor (BEF), and used the values to generate cost-efficiency curves for each representative product class. To calculate MSP, DOE generated a bill of materials by disassembling multiple manufacturers’ ballasts that spanned a range of efficiency levels. DOE then developed a cost model that converted the b ill of materials pricing in to MPCs. By applying derived manufacturer markups to the MPCs, DOE calculated the MSPs. DOE was not able to generate a bill of materials for all ballasts in this engineering analysis. In these cases, DOE developed a scaling method using retail prices to estimate an MSP for each one. See chapter 5 of the preliminary TSD for details.

Table ES.2.3 presents the BEF identified for each baseline and candida te standard level (CSL) in the engineering analysis. Table ES.2.4 pr esents the incremental MSP for each of these more efficient options.

Table ES.2.3 Summary of Baselines and Candidat e Standard Levels for Fluorescent Lamp Ballast Representative Product Classes

Representative Product Class Baseline CSL1 CSL2 CSL3

BEF BEF BEF BEF Two-Lamp Normal BF 4-Foot MBP IS & RS 1.359 1.450 1.535 1.561 Two-Lamp Normal BF 4-Foot MBP PS 1.418 1.518 N/A N/A Four-Lamp Normal BF 4-Foot MBP IS & RS 0.768 0.781 N/A N/A Four-Lamp Normal BF 4-Foot MBP PS 0.708 0.755 N/A N/A Two-Lamp Normal BF 4-Foot T5 MiniBP SO 1.309 1.441 1.482 N/A Two-Lamp 4-Foot T5 MiniBP HO 0.688 0.791 0.837 N/A Two-Lamp Normal BF 8-Foot SP Slimline 0.797 0.807 N/A N/A Two-Lamp 8-Foot RDC HO IS & RS 0.440 0.500 0.549 N/A Two-Lamp 4-Foot MBP IS & RS Residential 1.277 1.457 1.492 N/A Four-Lamp Sign Ballasts 0.196 0.238 N/A N/A

ES-5

### Table ES.2.4 Summary of Incremental Manufac turer Selling Prices Ov er the Baseline for Fluorescent Lamp Ballast Representative Product Classes

Representative Product Class CSL1 CSL2 CSL3
$ $ $ Two-Lamp Normal BF 4-Foot MBP IS & RS (2.83)* (0.26) (1.33) Two-Lamp Normal BF 4-Foot MBP PS 3.51 N/A N/A Four-Lamp Normal BF 4-Foot MBP IS & RS 1.37 N/A N/A Four-Lamp Normal BF 4-Foot MBP PS 3.48 N/A N/A Two-Lamp Normal BF 4-Foot T5 MiniBP SO 0.24 0.37 N/A Two-Lamp 4-Foot T5 MiniBP HO 0.22 3.18 N/A Two-Lamp Normal BF 8-Foot SP Slimline 6.92 N/A N/A Two-Lamp 8-Foot RDC HO IS & RS 0.34 1.58 N/A Two-Lamp 4-Foot MBP IS & RS Residential 3.40 6.45 N/A Four-Lamp Sign Ballasts (4.64) N/A N/A *Parentheses indicate a negative value.



### ES.2.5 Energy Use Char acterization

The energy use characterization, which a ssesses the potential energy savings resulting from amended efficiency standards, provides the ba sis for developing the energy savings used in the life-cycle cost (LCC) and subsequent analyses. Ballasts are designed to operate fluorescent lamps, which are not subject to the energy efficiency standards being developed in the fluorescent ballast standards rulemaking. However, because fluorescent ballasts are not intended to operate without lamps, the i nput power of the complete lamp-and-ballast system was required for the energy use analysis. DOE determined the annual energy consumption of the lamp-andballast systems using information on input power ( i.e. , the rate of energy they consume) and the way consumers use them ( i.e. , operating hours per year). Table ES.2.5 summarizes the average annual operating hours used for the energy use characterization, organized by market sector.

Table ES.2.5 Average Annual Lamp-and-Ballas t System Operating Hours by Sector

Sector Average Annual Operating Hours hrs/year

Residential 789

Commercial 3,435 Commercial (PS)* 2,405

Industrial 4,795

* Programmed start (PS) ballasts operating 4-foot MBP lamps on

occupancy sensors.



### The engineering analysis references measur ed system input power and normalized system input power, with the latter used to normalize input power between baseline and standards-case systems to maintain the same approximate light output. Table ES.2.6 shows the average annual electricity use in kilowatt-hours (kWh) for each efficiency level in each product class that DOE is considering in this rulemaking.

ES-6

### Table ES.2.6 Annual Energy Consumpt ion by Ballast Product Class

Representative Product Cl ass Market Sector CSL Annual Energy Consumption

kWh

Measured Normalized Two-Lamp Normal BF 4-Foot MBP IS & Commercial Baseline/1 207.5 207.5

RS 2 192.4 195.8 (T8 Baseline) 3 193.7 194.1 Two-Lamp Normal BF 4-Foot MBP PS Commercial Baseline 152.7 152.7

1 136.8 142.1 Two-Lamp Normal BF 4-Foot MBP IS & Commercial Baseline 218.1 218.1 RS (T12 Baseline) 1 207.5 202.7

2 192.4 191.3

3 193.7 189.6 Four-Lamp Normal BF 4-Foot MBP IS & Commercial Baseline 383.0 383.0

RS 1 393.0 379.9 Four-Lamp Normal BF 4-Foot MBP PS Commercial Baseline 289.3 289.3

1 279.2 274.7 Two-Lamp 8-Foot RDC HO IS & RS (T12 Industrial Baseline 999.3 999.3 Baseline) 1 815.2 879.4

1 767.2 902.9

2 684.7 1,049.1 Two-Lamp 8-Foot RDC HO IS & RS (T8 Industrial Baseline/1 767.2 767.2 Baseline) 2 684.7 891.4 Two-Lamp Normal BF 8-Foot SP Slimline Commercial Baseline 381.6 381.6 (T12 Baseline) 1 376.1 376.5 Two-Lamp Normal BF 8-Foot SP Slimline Commercial Baseline 376.8 376.8 (T8 Baseline) 1 371.0 367.2 Two-Lamp Normal BF 4-Foot T5 MiniBP Commercial Baseline 267.2 267.2

SO 1 222.9 222.9

2 224.6 215.4 Two-Lamp 4-Foot T5 MiniBP HO Industrial Baseline 688.1 688.1

1 598.4 598.4

2 586.9 571.1 Two-Lamp 4-Foot MBP IS & RS Residential Baseline 36.2 36.2 (T12 Baseline) 1 41.9 31.2

2 43.6 30.5 Two-Lamp 4-Foot MBP IS & RS Residential Baseline/1 41.9 41.9 (T8 Baseline) 2 43.6 40.9 Four-Lamp Sign Ballasts Commercial Baseline 1,352.0 1,352.0

1 906.8 1,113.3 Four-Lamp Sign Ballasts Industrial Baseline 1,887.3 1,887.3

1 1,265.9 1,554.1



### See chapter 2 and chapter 6 of the preliminary TSD for details.

ES.2.6 Markups Analysis

A markups analysis converts the manufac turer costs derived from the engineering analysis to end-user prices. In developing markups, DOE determined the distribution channels for ballasts and the markup associated with each pa rty in the distribution channel, as well as the appropriate sales tax.

ES-7

### Two types of distribution channels de scribe how most ballasts pass from the manufacturer to the end-user (Figure ES.2.1). The first distribution channe l applies to ballasts installed in fixtures. In this distribution channel, the manufacturer sells the ballast to the fixture manufacturer, who sells it to a distributor. The balla st then passes to a contractor, and finally to

the end-user. The second distribution channel a pplies to ballasts not in stalled in fixtures ( e.g. , replacement ballasts). In this distribution channel, the manufacturer sells the ballast to a distributor, who sells it to a contra ctor, who sells it to the end-user.

Figure ES.2.1 Ballast Distribution Channels

DOE developed separate ma rkups for baseline products and for the cost increase associated with improvements required to produce more-efficient products. Table ES.2.7 summarizes the markups de veloped for ballasts.

Table ES.2.7 Markups for Ballasts

Markup Baseline Incremental

OEM 1.51 1.16

Wholesaler 1.39 1.10

Sales Tax * 1.07 1.07

* Weighted national average.



### See chapter 2 and chapter 7 of the preliminary TSD for details.

ES.2.7 Life-Cycle Cost and Payback Period Analyses

An energy conservation standard usually resu lts in an increase in purchase price and a decrease in operating expenses. DOE analyzed th e net effect of amende d standards on consumers by evaluating the net LCC using the cost-effici ency relationship derived in the engineering analysis, as well as the energy costs derived from the energy use characterization analysis. All

ES-8

### replacement options are designed around two possible ballast purchasing events—ballast failure/replacement and new construction/renovation—when consumers can be affected by an amended energy conservation standard. The LCC spreadsheet calculates the LCC impacts for

each scenario.

Because the installed cost of a product typi cally increases while operating cost typically decreases in response to new standards, there is a time in the life of products having higher-thanbaseline efficiency when the net operating-cost benefit (in dollars) since the time of purchase is equal to the incremental first cost of purchasing the higher efficiency product. The length of time required for products to reach this cost-equivalence point is known as the payback period (PBP).

Inputs to the LCC calculation include the in stalled cost to the consumer, operating expenses, lifetime of the equipment, and a discount rate. Chapter 2 of this preliminary TSD summarizes the LCC and payback period (PBP) analyses; chapter 8 provides a detailed description of these analyses and the resu lts. Table ES.2.8 presents the key findings.

Table ES.2.8 Life-Cycle Cost and P ayback Period Results for Ballasts

Ballast Product Class Purchasing Event CSL LCC
$ LCC Savings
$ PBP*

yrs

Two-Lamp Normal BF 4-Foot MBP IS &

RS (T8 Baseline) Replacement Baseline/1

2

3 273.24

264.06

263.48 n/a

9.18

9.76 n/a

2.6

0.1

New Construction/

Renovation Baseline/1

2

3 275.52

269.38

266.18 n/a

6.14

9.34 n/a

3.4

0.1 Two-Lamp Normal BF 4-Foot MBP PS Replacement Baseline

1 248.26

236.07 n/a

12.20 n/a

2.4

New Construction/

Renovation Baseline

1 250.68

243.81 n/a

6.86 n/a

3.7 Two-Lamp Normal BF 4-Foot MBP IS & RS (T12 Baseline) Replacement Baseline

1

2

3 308.59

276.79

262.63

245.03 n/a

31.80

45.96

63.56 n/a

-3.6

-2.7

-0.3

New Construction/

Renovation Baseline

1

2

3 310.89

275.02

264.13

243.94 n/a

35.88

46.77

66.95 n/a

-3.0

-2.6

-0.3 Four-Lamp Normal BF 4-Foot MBP IS &

RS Replacement Baseline

1 486.04

497.97 n/a

-11.93 n/a (Never)

New Construction/

Renovation Baseline

1 488.29

489.25 n/a

-0.96 n/a

12.6 Four-Lamp Normal BF 4-Foot MBP PS Replacement Baseline

1 447.78

441.31 n/a

6.47 n/a

3.8

New Construction/

Renovation Baseline

1 450.22

439.16 n/a

11.05 n/a

2.6 Two-Lamp 8-Foot RDC HO IS & RS (T12 Baseline) Replacement Baseline

1

1

2 729.92

652.57

652.57

489.82 n/a

77.34

77.34

240.10 n/a

0.3

0.3

0.0

New Construction/ Baseline 732.38 n/a n/a

ES-9Renovation 1 683.15 49.24 0.5

1 683.15 49.24 0.5

2 551.79 180.59 0.1 Two-Lamp 8-Foot RDC HO IS & RS (T8 Replacement Baseline/1 488.29 n/a n/a Baseline) 2 455.61 32.69 0.7

New Construction/ Baseline/1 490.69 n/a n/a

Renovation 2 548.83 -58.14 (Never) Two-Lamp Normal BF 8-Foot SP Replacement Baseline 502.49 n/a n/a

Slimline 1 501.41 1.09 7.0 (T12 Baseline) New Construction/ Baseline 504.79 n/a n/a

Renovation 1 503.99 0.80 7.5 Two-Lamp Normal BF 8-Foot SP Replacement Baseline 455.72 n/a n/a

Slimline 1 454.34 1.37 6.6 (T8 Baseline) New Construction/ Baseline 457.97 n/a n/a

Renovation 1 453.48 4.49 4.0 Two-Lamp Normal BF 4-Foot T5 Replacement Baseline 310.47 n/a n/a

MiniBP SO 1 276.71 33.76 0.9

2 276.72 33.75 0.5

New Construction/ Baseline 312.98 n/a n/a

Renovation 1 279.01 33.98 0.9

2 271.42 41.56 0.4 Two-Lamp 4-Foot T5 MiniBP HO Replacement Baseline 383.90 n/a n/a

1 348.05 35.85 0.6

2 341.56 42.34 0.3

New Construction/ Baseline 386.37 n/a n/a

Renovation 1 350.48 35.89 0.6

2 337.04 49.33 0.3 Two-Lamp 4-Foot MBP IS & RS Replacement Baseline 123.98 n/a n/a Residential (T12 Baseline) 1 118.11 5.87 (Never)

2 118.68 5.30 (Never)

New Construction/ Baseline 126.35 n/a n/a

Renovation 1 108.17 18.18 -10.0

2 105.89 20.46 -10.6 Two-Lamp 4-Foot MBP IS & RS Replacement Baseline/1 114.57 n/a n/a Residential (T8 Baseline) 2 120.11 -5.54 (Never)

New Construction/ Baseline/1 116.96 n/a n/a

Renovation 2 119.37 -2.41 32.2 Four-Lamp Sign Ballasts Commercial Replacement Baseline 1,479.28 n/a n/a

1 1,108.02 371.26 0.1

New Construction/ Baseline 1,481.58 n/a n/a

Renovation 1 1,284.09 197.49 0.2 Four-Lamp Sign Ballasts Industrial Replacement Baseline 1,169.55 n/a n/a

1 900.11 269.45 0.1

New Construction/ Baseline 1,171.88 n/a n/a

Renovation 1 1,029.00 142.89 0.2

* Negative values indicate standards that reduce operating costs and installed costs. Entries of “Never” indicate standards that do not reduce operating costs.



### ES.2.8 Shipments Analysis

Shipment forecasts are needed to calculate the national impacts of amended standards on energy use, the net present value (NPV) of cons umer costs and savings, and future manufacturer cash flows for each ballast product class under co nsideration. DOE followed a three-step process

ES-10

### to forecast ballast shipments. First, DOE used historical shipment data from the U.S. Census Bureau to estimate the total historical shipment s of each ballast type. Second, DOE calculated an installed stock for each ballast type based on individual average service lifetime. Third, by modeling ballast purchasing for replacement a nd new construction/renov ation and applying growth rate, replacement rate, and emerging technologies ( i.e. , solid-state lighting) penetration rate assumptions, DOE developed annual shipment projections.

Chapter 2 and chapter 9 of the preliminary TSD provide additional detail on the shipments analysis.

Figure ES.2.2 through Figure ES.2.7 present the base case shipments forecasts from 2014–2044 for the ballast product classes under consideration, modeled fr om the 2006 installed stock based on 1990–2005 historical shipments. Estima ted historic shipmentnumbers for ballasts exhibited some variation on a year-to-year basis. Preliminary assumptions regarding ballast

lifetime and failure distri butions propagate this variability to produce periodic surges in some shipment projections; DOE seeks comment on these assumptions to further refine its shipment model (see section ES.3.16).Shipments 100,000,000

90,000,000

80,000,000

70,000,000

60,000,000

50,000,000

40,000,000

30,000,000

20,000,000

10,000,000

0

2014 2019 2024 2029 2034 2039 2044

Year

4-foot T8 MBP Base-Case Existing Tech Forecast

4-foot T12 MBP Base-Case Existing Tech Forecast

4-foot T8 MBP Base-Case Emerging Tech Forecast

4-foot T12 MBP Base-Case Emerging Tech Forecast



### Figure ES.2.2 Base-Case Forecasted Shipmen ts for Ballasts Operating Four-Foot MBP Lamps (Commercial Sector, Existing a nd Emerging Technologies Scenarios)

ES-11

### 0 50,000 100,000 150,000 200,000 250,000 300,000 350,000Shipments



### 2014 2019 2024 2029 2034 2039 2044
Year

8-foot T8 RDC HO Base-Case Forecast 8-foot T12 RDC HO Base-Case Forecast



### Figure ES.2.3 Base-Case Forecasted Shipmen ts for Ballasts Operating Eight-Foot RDC HO Lamps (Excluding Sign Ballasts)

2,500,000

2,000,000Shipments



### 1,500,000

1,000,000

500,000

Year 0

2014 2019 2024 2029 2034 2039 2044

8-foot T8 Slimline Base-Case Forecast 8-foot T12 Slimline Base-Case Forecast



### Figure ES.2.4 Base-Case Forecasted Shipmen ts for Ballasts Operating Eight-Foot SP Slimline Lamps

ES-120 5,000,000 10,000,000 15,000,000 20,000,000 25,000,000 30,000,000 35,000,000 40,000,000 45,000,000Shipments

2014 2019 2024 2029 2034 2039 2044

Year

4-foot T5 MiniBP SO Base-Case Emerging Tech Forecast

4-foot T5 MiniBP HO Base-Case Emerging Tech Forecast

4-foot T5 MiniBP SO Base-Case Existing Tech Forecast



### Figure ES.2.5 Base-Case Forecasted Shipmen ts for Ballasts Operating Four-Foot T5 MiniBP SO and HO Lamps (Existing and Emerging Technologies Scenarios)

ES-13

### 0 5,000,000 10,000,000 15,000,000 20,000,000 25,000,000 30,000,000 35,000,000Shipments



### 2014 2019 2024 2029 2034 2039 2044

Year

4-foot T8 MBP Base-Case Forecast 4-foot T12 MBP Base-Case Forecast



### Figure ES.2.6 Base-Case Forecasted Shipmen ts for Ballasts Operating Four-Foot MBP Lamps in the Residential Sector

0 500,000 1,000,000 1,500,000 2,000,000 2,500,000 3,000,000 3,500,000 4,000,000 4,500,000Shipments



### 2014 2019 2024 2029 2034 2039 2044
Year

8-foot T12 HO Base-Case Forecast



### Figure ES.2.7 Base-Case Forecasted Shipments for Sign Ballasts Operating Eight-Foot RDC HO Lamps

ES.2.9 National Impact Analysis

The national impact analysis (NIA) estimates the following national impacts from possible candidate standard levels : (1) national energy savings (NES), (2) monetary value of the

ES-14

### energy savings due to standards, (3) increased to tal installed costs of the considered products due to standards, and (4) the net present value (NPV) of energy savings (difference between value of energy savings and increased total installed costs). DOE prepared a spreadsheet model to forecast energy savings and national consumer economic costs and savings resulting from new standards. Chapter 2 of the preliminary TSD summarizes the methodology for the NIA; TSD chapter 10 provides additional detail on the analysis.

ES.2.9.1 National Energy Savings Analysis

DOE calculated annual NES as the differenc e between national energy consumption in the base case (without amended en ergy conservation standards) a nd in each higher efficiency standard case. DOE estimated energy consumption and savings based on site energy and converted the electricity consum ption and savings to source energy. Cumulative energy savings

are the sum of the annual NES over the time period of the analysis (2014–2044).

Table ES.2.9 and Table ES.2.10 show the cu mulative NES results under the existing technologies shift scenario, which reflects the upp er bound of energy savings, and the emerging technologies roll-up scenario, which reflects the lower bound. Energy savings for individual ballast product classes are provided to illustrate th e approximate relative energy savings of each ballast type under a CSL.

Due to a larger reduction in the installed stock of ballasts, the emerging technologies base-case forecast results in lower energy sa vings than the existing technologies base-case forecast. Because more consumers move to higher-efficacy ballasts in the shift scenario than in the roll-up scenario, the shift scenario results in greater energy savings. NES results are presented as undiscounted and based on a 7- and 3-percent real discount rate.

ES-15

### Table ES.2.9 Cumulative Nati onal Energy Savings for Ball asts Under the Existing Technologies, Shift Scenario (2014–2044)

CSL Ballast Product Class NES Discount* quads

None 7% 3%

1 Two-Lamp Normal BF 4-Foot MBP IS & RS (T8 Baseline) Two-Lamp Normal BF 4-Foot MBP PS Two-Lamp Normal BF 4-Foot MBP IS & RS (T12 Baseline) Four-Lamp Normal BF 4-Foot MBP IS & RS Four-Lamp Normal BF 4-Foot MBP PS Two-Lamp 8-Foot RDC HO IS & RS (T12 Baseline) Two-Lamp 8-Foot RDC HO IS & RS (T8 Baseline) Two-Lamp Normal BF 8-Foot SP Slimline (T12 Baseline) Two-Lamp Normal BF 8-Foot SP Slimline (T8 Baseline) Two-Lamp Normal BF 4-Foot T5 MiniBP SO Two-Lamp 4-Foot T5 MiniBP HO Two-Lamp 4-Foot MBP IS & RS Residential (T12 Baseline) Two-Lamp 4-Foot MBP IS & RS Residential (T8 Baseline) Four-Lamp Sign Ballasts 0.00

0.25

1.43

-0.36

0.12

0.00

0.00

0.00

0.02

1.96

0.33

-0.11

0.00

3.25 0.00

0.05

0.33

-0.08

0.02

0.00

0.00

0.00

0.00

0.38

0.08

-0.02

0.00

0.73 0.00

0.12

0.73

-0.18

0.06

0.00

0.00

0.00

0.01

0.93

0.17

-0.06

0.00

1.63

TOTAL 6.89 1.49 3.41

2 Two-Lamp Normal BF 4-Foot MBP IS & RS (T8 Baseline) Two-Lamp Normal BF 4-Foot MBP IS & RS (T12 Baseline) Two-Lamp 8-Foot RDC HO IS & RS (T12 Baseline) Two-Lamp 8-Foot RDC HO IS & RS (T8 Baseline) Two-Lamp Normal BF 4-Foot T5 MiniBP SO Two-Lamp 4-Foot T5 MiniBP HO Two-Lamp 4-Foot MBP IS & RS Residential (T12 Baseline) Two-Lamp 4-Foot MBP IS & RS Residential (T8 Baseline) 0.00

1.37

0.00

0.00

1.92

0.34

-0.11

0.00 0.00

0.32

0.00

0.00

0.37

0.08

-0.02

0.00 0.00

0.70

0.00

0.00

0.91

0.18

-0.06

0.00

TOTAL 3.52 0.75 1.73

3 Two-Lamp Normal BF 4-Foot MBP IS & RS (T8 Baseline) Two-Lamp Normal BF 4-Foot MBP IS & RS (T12 Baseline) 0.00

1.37 0.00

0.32 0.00

0.70

TOTAL 1.37 0.32 0.70

* Note that energy savings for individual ballast product classes (due to separate regulation) do not sum to equal total energy savings achieved at the CSLs due to standards-induced substitution effects among ballast types.

ES-16

### Table ES.2.10 Cumulative Nati onal Energy Savings for Ba llasts Under the Emerging Technologies, Roll-Up Scenario (2014–2044)

CSL Ballast Product Class NES Discount* quads

None 7% 3%

1 Two-Lamp Normal BF 4-Foot MBP IS & RS (T8 Baseline) Two-Lamp Normal BF 4-Foot MBP PS Two-Lamp Normal BF 4-Foot MBP IS & RS (T12 Baseline) Four-Lamp Normal BF 4-Foot MBP IS & RS Four-Lamp Normal BF 4-Foot MBP PS Two-Lamp 8-Foot RDC HO IS & RS (T12 Baseline) Two-Lamp 8-Foot RDC HO IS & RS (T8 Baseline) Two-Lamp Normal BF 8-Foot SP Slimline (T12 Baseline) Two-Lamp Normal BF 8-Foot SP Slimline (T8 Baseline) Two-Lamp Normal BF 4-Foot T5 MiniBP SO Two-Lamp 4-Foot T5 MiniBP HO Two-Lamp 4-Foot MBP IS & RS Residential (T12 Baseline) Two-Lamp 4-Foot MBP IS & RS Residential (T8 Baseline) Four-Lamp Sign Ballasts 0.00

0.14

0.00

-0.23

0.06

0.00

0.00

0.00

0.02

1.07

0.29

-0.01

0.00

3.25 0.00

0.03

0.00

-0.06

0.01

0.00

0.00

0.00

0.00

0.24

0.07

0.00

0.00

0.73 0.00

0.07

0.00

-0.12

0.03

0.00

0.00

0.00

0.01

0.54

0.15

0.00

0.00

1.63

TOTAL 4.60 1.03 2.31

2 Two-Lamp Normal BF 4-Foot MBP IS & RS (T8 Baseline) Two-Lamp Normal BF 4-Foot MBP IS & RS (T12 Baseline) Two-Lamp 8-Foot RDC HO IS & RS (T12 Baseline) Two-Lamp 8-Foot RDC HO IS & RS (T8 Baseline) Two-Lamp Normal BF 4-Foot T5 MiniBP SO Two-Lamp 4-Foot T5 MiniBP HO Two-Lamp 4-Foot MBP IS & RS Residential (T12 Baseline) Two-Lamp 4-Foot MBP IS & RS Residential (T8 Baseline) 0.00

0.93

0.04

0.00

1.05

0.43

-0.11

0.00 0.00

0.24

0.01

0.00

0.23

0.10

-0.02

0.00 0.00

0.50

0.02

0.00

0.53

0.22

-0.06

0.00

TOTAL 2.33 0.56 1.21

3 Two-Lamp Normal BF 4-Foot MBP IS & RS (T8 Baseline) Two-Lamp Normal BF 4-Foot MBP IS & RS (T12 Baseline) 0.00

0.85 0.00

0.22 0.00

0.46

TOTAL 0.85 0.22 0.46

* Note that energy savings for individual ballast product classes (due to separate regulation) do not sum to equal total energy savings achieved at the CSLs due to standards-induced substitution effects among ballast types.



### ES.2.9.2 Net Present Value Analysis

DOE calculated NPV as the difference betw een total savings in operating costs and

increases in total installed costs in the base cas e and standards case. DOE calculated savings over the life of the product using discount rates of 7- and 3-percent to discount future costs and savings to the present.

Table ES.2.11 and Table ES.2.12 show the NPV results under the existing technologies and emerging technologies scenarios. An NPV greater than zero shows that the CSL would reduce customer expenditures relative to the base case in present value terms. An NPV less than zero indicates that the CSL would result in a net increase in customer expenditures in present

value terms.

ES-17

### Table ES.2.11 Cumulative NPV Results for Balla sts Under the Existing Technologies, Shift Scenario (2014–2044)

CSL Ballast Product Class NPV Discount*
billion 2008$

7% 3%

1 Two-Lamp Normal BF 4-Foot MBP IS & RS (T8 Baseline) Two-Lamp Normal BF 4-Foot MBP PS Two-Lamp Normal BF 4-Foot MBP IS & RS (T12 Baseline) Four-Lamp Normal BF 4-Foot MBP IS & RS Four-Lamp Normal BF 4-Foot MBP PS Two-Lamp 8-Foot RDC HO IS & RS (T12 Baseline) Two-Lamp 8-Foot RDC HO IS & RS (T8 Baseline) Two-Lamp Normal BF 8-Foot SP Slimline (T12 Baseline) Two-Lamp Normal BF 8-Foot SP Slimline (T8 Baseline) Two-Lamp Normal BF 4-Foot T5 MiniBP SO Two-Lamp 4-Foot T5 MiniBP HO Two-Lamp 4-Foot MBP IS & RS Residential (T12 Baseline) Two-Lamp 4-Foot MBP IS & RS Residential (T8 Baseline) Four-Lamp Sign Ballasts 0.00

-0.05

17.70

-2.09

-0.08

0.00

0.00

0.00

-0.05

3.16

0.50

0.45

0.00

6.84 0.00

0.76

22.19

-3.22

0.30

0.00

0.00

0.00

0.01

9.44

1.22

0.03

0.00

16.15

TOTAL 26.39 46.89

2 Two-Lamp Normal BF 4-Foot MBP IS & RS (T8 Baseline) Two-Lamp Normal BF 4-Foot MBP IS & RS (T12 Baseline) Two-Lamp 8-Foot RDC HO IS & RS (T12 Baseline) Two-Lamp 8-Foot RDC HO IS & RS (T8 Baseline) Two-Lamp Normal BF 4-Foot T5 MiniBP SO Two-Lamp 4-Foot T5 MiniBP HO Two-Lamp 4-Foot MBP IS & RS Residential (T12 Baseline) Two-Lamp 4-Foot MBP IS & RS Residential (T8 Baseline) 0.00

24.89

0.00

0.00

3.31

0.57

0.45

0.00 0.00

29.20

0.00

0.00

9.46

1.31

0.03

0.00

TOTAL 29.22 40.01

3 Two-Lamp Normal BF 4-Foot MBP IS & RS (T8 Baseline) Two-Lamp Normal BF 4-Foot MBP IS & RS (T12 Baseline) 0.00

24.89 0.00

29.20

TOTAL 24.89 29.20

* Note that NPV for individual ballast product classes (due to separate regulation) do not sum to equal total NPV achieved at the CSLs due to standards-induced substitution effects among ballast types.

ES-18

### Table ES.2.12 Cumulative NPV Results for Ballasts Under the Emerging Technologies, Roll-Up Scenario (2014–2044)

CSL Ballast Product Class NPV Discount
billion 2008$

7% 3%

1 Two-Lamp Normal BF 4-Foot MBP IS & RS (T8 Baseline) Two-Lamp Normal BF 4-Foot MBP PS Two-Lamp Normal BF 4-Foot MBP IS & RS (T12 Baseline) Four-Lamp Normal BF 4-Foot MBP IS & RS Four-Lamp Normal BF 4-Foot MBP PS Two-Lamp 8-Foot RDC HO IS & RS (T12 Baseline) Two-Lamp 8-Foot RDC HO IS & RS (T8 Baseline) Two-Lamp Normal BF 8-Foot SP Slimline (T12 Baseline) Two-Lamp Normal BF 8-Foot SP Slimline (T8 Baseline) Two-Lamp Normal BF 4-Foot T5 MiniBP SO Two-Lamp 4-Foot T5 MiniBP HO Two-Lamp 4-Foot MBP IS & RS Residential (T12 Baseline) Two-Lamp 4-Foot MBP IS & RS Residential (T8 Baseline) Four-Lamp Sign Ballasts 0.00

0.08

0.00

-1.31

0.00

0.00

0.00

0.00

-0.05

1.92

0.35

-0.04

0.00

6.84 0.00

0.52

0.00

-2.01

0.20

0.00

0.00

0.00

0.01

5.32

0.98

-0.06

0.00

16.15

TOTAL 7.79 21.12

2 Two-Lamp Normal BF 4-Foot MBP IS & RS (T8 Baseline) Two-Lamp Normal BF 4-Foot MBP IS & RS (T12 Baseline) Two-Lamp 8-Foot RDC HO IS & RS (T12 Baseline) Two-Lamp 8-Foot RDC HO IS & RS (T8 Baseline) Two-Lamp Normal BF 4-Foot T5 MiniBP SO Two-Lamp 4-Foot T5 MiniBP HO Two-Lamp 4-Foot MBP IS & RS Residential (T12 Baseline) Two-Lamp 4-Foot MBP IS & RS Residential (T8 Baseline) 0.00

3.17

0.20

0.00

2.15

0.83

0.45

0.00 0.00

6.04

0.28

0.00

5.48

1.79

0.03

0.00

TOTAL 6.80 13.62

3 Two-Lamp Normal BF 4-Foot MBP IS & RS (T8 Baseline) Two-Lamp Normal BF 4-Foot MBP IS & RS (T12 Baseline) 0.00

14.64 0.00

17.28

TOTAL 14.64 17.28

* Note that NPV for individual ballast product classes (due to separate regulation) do not sum to equal total NPV achieved at the CSLs due to standards-induced substitution effects among ballast types.



### ES.2.10 Preliminary Manufacturer Impact Analysis

A preliminary manufacturer impact analysis (MIA) assesses the potential impacts of energy conservation standards on manufacturers, such as effects on expenditures for capital conversion, marketing costs, ship ments, and research and devel opment costs. Potential impacts might lead to changes in manufacturing practices for fluorescent lamp ballasts. DOE identified potential impacts through interviews with manufacturers and other interested parties.

DOE identified three key issues for fluorescent lamp ballasts: impacts on profitability; product conversion costs/diminishing returns to consumers; and product innovation. See chapter 12 of the preliminary TSD for details.

ES-19

### ES.2.11 Other Analyses

The remaining chapters of the preliminary TSD address the analyses to be performed for the notice of proposed rulemaking (NOPR):

• The life-cycle cost analysis for subgroups ev aluates the effects of energy conservation

standards on various nationa l subgroups (chapter 11).

• The utility impact analysis examines impacts of energy conservation standards on the generation capacity of electric utilities (chapter 13).

• The employment impact analysis examines the effects of energy conservation standards on national employme nt (chapter 14).

• The environmental assessment examines the effects of energy conservation standards on

various airborne emissions.

• The regulatory impact analysis examines the national impacts of non-regulatory alternatives to mandatory en ergy conservation standards.

ES.3 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT

DOE is interested in receiving comments on all aspects of this preliminary analysis. DOE especially invites comments or data to improve DOE’s analysis, including information that will respond to the following questions and concerns th at were raised in response to the framework document and in preparation of the preliminary TSD.

ES.3.1 Test Procedures

Manufacturers have observed non- compliant ballasts that were labeled as compliant in the marketplace. DOE requests comments on ways to enhance the certification and enforcement procedures for fluorescent lamp ballasts.

ES.3.2 Scope of Coverage

In chapter 2, DOE considers including the fo llowing ballasts in its scope of coverage:

(1) ballasts that operate one, two, three, four, fi ve, or six 4-foot medium bipin lamps with a rated wattage a 

### of 25W or more and an input voltage at or between 120V and 277V; (2) ballasts that operate one, two, three, four, five, or six 2-foot U-shaped lamps with a rated wattage of 25W or more and an input voltage at or between 120V and 277V; (3) ballasts that operate one or two 8-foot recessed double contact high output lamps with an input voltage at or between 120V and 277V;

a The 2009 Lamps Rule adopted a new definition for rated wattage that can be found in 10 CFR 430.2.

ES-20

### (4) ballasts that operate one or two 8-foot single pin slimline lamps with a rated wattage of 52W or more and an input vo ltage at or between 120V and 277V; (5) ballasts that operate one or two 4-foot miniature bipin st andard output lamps with a rated wattage of 26W or more and an input voltage at or between 120V and 277V; (6) ballasts that operate one, two, three, or four 4-foot minia ture bipin high output lamps with a rated wattage of 49W or more and an input voltage at or between 120V and 277V; (7) ballasts that operate one, two, three, or four 4-foot medi um bipin lamps with a rated wattage of 25W or more, an input volta ge at or between 120V and 277V, a power factor of less than 0.90, and that are desi gned and labeled for use in residential applications; and (8) ballasts that operate one, two, three, four , five, or six 8-foot recessed double contact high output lamps with an input voltage at or between 120V and 277V, and that operate at ambient temperatures of 20 °F or less and are used in outdoor signs.

DOE invites comment on its rationale for exte nding coverage and also its proposed scope of coverage. DOE specifically requests comment on its exclusion of dimming ballasts from the scope of coverage.

ES.3.3 Product Classes

DOE considered 10 potential class-setting factors: (1) lamp length, (2) the maximum number of lamps operated, (3) ba llast factor, (4) lumen package (or lamp output), (5) lamp diameter, (6) starting method, (7 ) market sector, (8) cold temperature operation, (9) input voltage, and (10) universal voltage. Using the st atutory criteria described above (i.e., type of energy consumed or capacity or other performa nce-related feature affecting efficiency), DOE eliminated many of these. DOE defined product classes based on lamp le ngth, lumen package, maximum number of lamps operated, starting method, ballast fact or, and market sector. These class-setting factors created 70 product clas ses, summarized in Table ES.2.2. DOE seeks comments on these product classes – including comments on the appropr iate starting method definitions to use in the regulatory language and the ranges attributed to high, low, and normal

ballast factor.

ES.3.4 Technology Options

DOE identified several technology options to improve the efficiency of a fluorescent lamp ballast. DOE invites comment on these options, discussed in preliminary TSD chapter 3.

ES.3.5 Screening Analysis

DOE invites comment on the technology opti on eliminated during the screening analysis.

ES.3.6 Candidate Standard Levels for Representative Product Classes

DOE tested many manufacturers’ product offe rings for BEF and ballast efficiency to determine their efficiency. DOE identified the most prevalent BEF values in the range of

ES-21

### available products and establishe d CSLs based on those products. W ithin a given product class, no currently available products or working prototypes appear to exist that have a distinguishably higher BEF than commercially available ballasts. Therefore, the highest CSL presented, which represents the most efficient tier of commercially available ballasts, is the “max-tech” level that DOE determined for this preliminary rulemaking. DOE requests comment on its selection of representative product classes, baseline ballasts, and the lamp-and-ballast systems chosen to represent baseline and increasing efficiency.

ES.3.7 Maximum Technologically Feasible Ballast

Within a given product class, no working products or prototypes appear to exist that have a distinguishably higher BEF than commercially available ballasts. Therefore, the highest CSL presented, which represents the most efficient tier of commercially available ballasts, is the “max-tech” level that DOE determined for this preliminary rulemaking. However, DOE presents additional research in appendix 5D of the preliminary TSD to ex plore whether technologies used in products similar to ballasts can be used to improve the efficiency of ballasts currently on the market. DOE requests comments on the maximum t echnologically feasible ballast efficiency

and its associated MSP.

ES.3.8 Manufacturer Production Costs

To estimate MPCs for fluorescent lamp balla sts, DOE conducted a teardown analysis for many high-volume ballasts. Given the large numbe r of available ballasts and the fact that DOE was unable to tear down certain ballasts due to physical restrictions (potting), DOE used scaling techniques estimate the MPC for those ballasts that it did not tear down. DOE then calculated MSPs by applying overhead and manufactur er markups. DOE requests comments on its estimates of manufacturer producti on costs, as well as DOE’s estimates for overhead and the manufacturer markup.

ES.3.9 Candidate Standard Levels for Non-Representative Product Classes

To determine CSLs for non-representative product classes, DOE tested the BEF of certain ballasts in those product cl asses and compared these values to the representative classes to create scaling relationships. These scaling rela tionships were used to create CSLs for those product classes not directly analyzed. DOE re quests comments on its scaling methodology and the proposed CSLs for fluorescent lamp ballasts in non-representative product classes.

ES.3.10 Cumulative and Future Regulation

DOE recognizes and seeks to mitigate the overlapping effects on manufacturers of new or amended DOE standards and other regulatory actions affecting the same equipment. DOE will analyze and consider the impact on manufacturer s of multiple, product-sp ecific regulatory

actions in the NOPR. DOE invites comment on re gulations applicable to ballast manufacturers that contribute to their cumulative regulatory burden.

ES-22

### In addition to existing regulation, several po ssible upcoming regulations could affect the engineering and life-cycle cost analysis for fluorescent lamp ballasts. DOE requests comments on how safety requirements for system interconnect s, safety requirements for lamp end-of-life protection, electromagnetic field requirements, and hazardous mate rial regulation could affect the efficiency of commercially available ballasts. DOE also requests information on the cost of low and high efficiency ballasts that are expected to be compliant with these regulations so that DOE can assess how these requirements may affect payback calculations.

ES.3.11 Operating Profiles for Energy Use Characterization

To characterize the country’s average use of lamp-and-ballast systems for a typical year, DOE developed annual operating hours by sector using data published in the U.S. Lighting Market Characterization: Volume I, Residential Energy Consumption Survey, the Commercial Building Energy Consumption Survey, and the Manufacturer Energy Consumption Survey. DOE assumed a primary sector for each ballast produ ct class analyzed (Table ES.2.6) and applied average annual operating hours based on sector (Table ES.2.5). DOE welcomes comments on the basis and assignment of these end-use operating profiles for the ballast types covered under this rulemaking. See chapter 2 of the preliminary TSD for details.

ES.3.12 Lighting Controls and Ballast Operating Profiles

Except for programmed-start (PS) ballasts opera ting four-foot medium bipin lamps in the commercial sector, DOE did not modify the operating hour data from the U.S. Lighting Market Characterization to reflect use of lighting controls for other ballast product classes. Based on its

market research and feedback from interested parties, DOE assumed th at PS ballasts operating four-foot medium bipin lamps in the commercial sector are cont rolled with occupancy sensors, resulting in reduced annual operating hours. Howe ver, DOE is unsure how it would account for lighting controls, as there is uncertainty about which types of control systems are specified in practice, and DOE did not receive or identify comprehensive data on the impact of lighting controls. DOE invites comments on this issue, as well as details on the use of lighting controls in the commercial, industrial, and residential sectors. See chapte r 2 of the preliminary TSD for

details.

ES.3.13 Price Markups

In the framework document, DOE solicited comments on typical ballast pricing and distributor and contractor markups . Unable to obtain any detailed pricing or markup data for the preliminary analyses, DOE developed OEM and w holesaler markups using financial data from

U.S. Securities and Exchange Commission form 10-K reports for publicly owned companies. DOE seeks comments on typical markups, as well as ballast pricing data that DOE could use to verify the price markups it developed for the preliminary analysis. See chapter 2 of the preliminary TSD for details.

ES-23

### ES.3.14 Electricity Prices for LCC and PBP Analyses

DOE estimates electricity prices for commerc ial, industrial, and residential consumers using Energy Information Administration (EIA ) data. DOE received a number of comments on the potential effects of energy efficient ballast designs on electricity demand charges and how

DOE accounts for these effects in its LCC and PBP analyses. DOE’s approach for forecasting electricity prices does not include evaluating de mand load profiles or allow for quantifying the potential impacts on peak demand for electricity from changes in product efficiency. DOE requests comments on alternate data sources, methods for quantifying changes in demand charges, and their impacts on electricity prices. See chapter 2 of the preliminary TSD for details.

ES.3.15 Effects of Energy Efficient Design on Ballast Life

DOE received multiple comments on the potential effects of energy efficient design on

ballast life. Some commenters obs erved that energy efficient ballasts should operate cooler, which would result in longer operating life. A nother commenter remarked that ballasts are generally operating at higher temperatures due to the trend toward smalle r fixtures and ballast enclosures. DOE acknowledges the general trend to ward smaller fixtures and ballast enclosures, and assumed ballast operating temp eratures equal to or greater than those for current ballast designs, with no extended life for energy effici ent ballast designs. DOE welcomes additional comments and data on operating lifetimes for energy efficient ballasts. See chapter 2 of the preliminary TSD for details.

ES.3.16 Average Ballast Lifetimes and Failure Distributions

For the LCC/PBP analyses and shipment projections, DOE assumed average ballast lifetimes as 15 years (commercial and residential sectors) and 10 years (industrial sector). These average values suggest that a majority of ballast failures occur later in the service lifetime. DOE seeks comment on the assumed average ballast lifetimes, as well as the distribution of failures around the average values. In particular, DOE seeks comment on how many years beyond average lifetimes that ballasts potentially remain in service. See chapter 2 of the preliminary

TSD for details.

ES.3.17 Historical Shipments Data

DOE requested historical balla st and residential fixture shipments data from the National Electrical Manufacturers Association (NEMA), but these data were not available for the preliminary shipments analysis. Consequently, DOE used data from the U.S. Census Bureau to

estimate the total historical shipments of each ballast ty pe analyzed, which required disaggregating the Census data and adjustin g it to include estimate d non-NEMA shipments. DOE seeks actual, disaggregated ballast and residen tial fixture shipments data to help verify its shipments analysis. See chapter 2 of the preliminary TSD for details.

ES-24

### ES.3.18 Shipment Trends

DOE modeled ballast purchasing events ( e.g. , replacement and new construction) and applied growth rate, replacement ra te, and emerging technologies ( i.e. , solid-state lighting) penetration rate a ssumptions to develop annual shipment projections. DOE based future ballast shipment trends on manufacturer interviews and market tre nds identified in the 2009 Lamps Rule; DOE assumes that these trends integrate various regulatory and non-regulatory initiatives in the lighting marketplace. DOE requests comments on the magnitude and timing of its forecasted ballast shipment trends ( e.g. , rising and declining shipments, plateaus, etc.) as well as the impacts of current regulatory initiatives on future ballast shipments. See chapter 2 of the preliminary TSD for details.

ES.3.19 NIA and External Benefits

DOE acknowledges that there may be certain “external” benefits resulting from the improved efficiency of ballasts that are not captured by the equipment’s users. These include both environmental and energy security-related externalities that are also not already reflected in energy prices, such as reduced emissions of gr eenhouse gases and reduced use of fossil fuels for electricity generation. DOE invites comments on the nature and magnitude of such benefits. See chapter 2 of the preliminary TSD for details.

ES.3.20 Trial Standard Levels

For the NOPR, DOE will develop trial standard levels (TSLs) based on the candidate

standard levels for fluorescent la mp ballasts. DOE is considering several criteria in developing the TSLs, including, but not limited to, minimum LCC, maximum NPV, and maximum technologically-feasible efficiency. These TSLs may include combinations of CSLs and the interaction between product classes such as ballasts that opera te 4-foot medium bipin and 8-foot single pin slimline fluorescent lamps. From the list of TSLs developed, DOE will select one as its proposed standard for the NOPR. DOE invite s comment on the criteria it should use as the

basis for selection of TSLs.

ES.3.21 Impact on Manufacturers

DOE requests comment on its identificati on of key issues and requests data and information from interested parties that can assist in evaluating the potential impact on

manufacturers.

ES.3.22 Valuing Air-Borne Em ission Reductions

DOE will conduct an environmenta l assessment as part of the next phase of the standards rulemaking, the NOPR. The primary environmental effects of ener gy conservation standards for ballasts are to reduce power plant emissions resu lting from reduced consumption of electricity. DOE will assess these environmental effects by using NEMS-BT to provide key inputs to its analysis. The portion of the environmental as sessment that will be produced by NEMS-BT considers carbon dioxide (CO 2 

### ), sulfur dioxide (SO 2 

### ), nitrogen oxides (NO X 

### ), and mercury (Hg).

ES-25

### DOE also plans on monetizing the emission reductions due to standards consistent with methods used in recent DOE standards rulemakings pert aining to commercial cl othes washers and other consumer products and comme rcial equipment. For example, in the case of CO 2 

### , the most recent interagency estimates of the potential global benefits resulting from reduced CO 2 

### emissions in 2010 were $4.7, $21.4, $35.1, and $64.9 per metric t on in 2007 dollars. DOE invites comments on the approaches for monetizing the emission sa vings due to energy conservation standards.

ES-26

### 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 Unde r the Process Rule

............................................................................ 1-5

1-i

### CHAPTER 1. INTRODUCTION

1.1 PURPOSE OF THE DOCUMENT

This preliminary technical support document (T SD) provides the analytical approaches, inputs and results associated with the U.S. Depa rtment 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 lif e-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 a nd Conservation Act (EPCA) of 1975 (42 U.S.C. 6291–6309) established the energy conservation pr ogram 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 fluores cent 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 effi ciency 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 great est 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

1-1

### (5) the impact of any lessening of comp etition, 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 Secret ary 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 App liance 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 am endments also required that DOE: (1) conduct two rulemaking cycles to determine whet her 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 add itional 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 (hereaft er “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 advocac y 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 standa rds codified by DOE can be found in Appendix A under 10 CFR 430.32(m)(3).

Congress promulgated new energy conservati on 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 statut e 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 commerci al and industrial sectors, such as electric motors and pumps, and packaged terminal air conditioners and heat pumps.

1-2

### as the F34T12 ballast. A table of the standard s 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 bipi n 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 2 77 volts with an input current frequency of 60 hertz. 10 CFR 430.32(m). Ballasts that are ex cluded 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 temp eratures 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 buildin g applications; and (4) replacement ballasts as define d 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 num erous 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 consum ption. (42 U.S.C. 6295(gg)(2)(B)(ii)) DOE published a final rule for the standby and o ff 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 ne w) 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 cy cle of review to determine whether the standards in effect for fluorescent lamp ba llasts 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.

1-3

### should be made applicable to additional fluorescent lamp ba llasts 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 am ended (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 covera ge 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 durin g the comment period of each rulemaking stage. Beginning with the rulemaking framework document for fluorescent lamp ballasts (the framework doc ument) 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 procedur e and the energy conservation standard rulemakings, DOE involves stakeholders th rough 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 Sta ndards 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 und er 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 effi ciency that is technologically feasible and economically justified, and would result in signif icant energy savings. (42 U.S.C. 6295(o)(2)(A) and (3)) To determine whether a proposed sta ndard complies with these requirements, DOE must, after receiving comments on the proposed st andard, determine whethe r 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 frame work 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 pa rticipation before the proposed rule stage. After the preliminary analys es 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 imp acts of standards on cons umers, manufacturers, and the nation; DOE’s weighing of the impacts; a nd the proposed standards. The third notice is the final rule, which presents a discussion of comments received in response to the NOPR; the

1-4

### revised analysis of the impacts of standards; DOE’s weighing of the impacts; the standards adopted by DOE; and the effectiv e dates of the standards.

Table 1.4.1 Analyses U nder 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 an alytical approaches DOE anticipated using to evaluate the establishment of energy conservati on 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 (h ereafter “public mee ting”), to discuss procedural and analytical approaches to the rulemaking, and to inform and facilitate stakeholders’ involvement in the rulemaking proce ss. 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 conducti ng them, and the relationships among the various analyses. See Table 1.4.1 for all the anal yses discussed at the public meeting to be undertaken in each of the formal public rulemaki ng 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 framewor k document comment period, stakeholders, including manufacturers, trade associations, e nvironmental advocates, and other interested parties submitted seve ral comments about the fluorescent la mp ballast rulemaking. The major issues discussed were: (1) the rulemaking’s sc ope of coverage; (2) the development of product classes; (3) investigating the use a of a new ener gy 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) th e lifetime of the balla st 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

1-5

### 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 manufact urers 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, a nd 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 proce ss 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 spre adsheets calculate the economic impacts of replacing products with standard -compliant ones. The NIA spr eadsheets 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 spreadsheet s 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: descri bes 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 Asse ssment: characterizes the fluorescent lamp ballast market and the tec hnologies available for increasing ballast efficacy factor and outlines product classes

1-6

### Chapter 4 Screening Analysis: determin es 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: disc usses the economic effects of standards and compares the LCC and PBP of fl uorescent 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 balla sts, and annual fluorescent lamp

ballast sales in the absence or presence of new standards

Chapter 11 Life-Cycle Cost Sub-Group An alysis: discusses the methods to be used to study the effects of sta ndards on a subgroup of fluorescent lamp ballast consumers and comp ares the LCC and PBP of product with and without higher efficien cy 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 standa rds on two pollutants, sulfur dioxide (SO 2 

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

Regulatory Impact Analysis for Fluorescent La mp Ballasts: discusses the methods to be used to determine the impact of non- regulatory alternatives to energy

conservation standards

1-7

### 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 re quirements 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 de veloping T5 ma gnetic 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 technol ogy 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

1-8

### CHAPTER 2. ANALYTICAL FRAMEWORK

TABLE OF CONTENTS

2.1 INTRODUCTION

........................................................................................................... 2-1

2.2 BACKGROUND

............................................................................................................. 2-3

2.2.1 History of Standards Rulemakings for Fl uorescent Lamp Ballasts and Regulatory Authority

.............................................................................................................. 2-3

2.2.2 Test Procedure

..................................................................................................... 2-5

2.2.3 Standby and Off Mode Energy Consumption

...................................................... 2-8

2.3 SCOPE OF COVERAGE

................................................................................................ 2-9

2.3.1 Current Scope of Ballast Energy Conservation Standards

.................................. 2-9

2.3.2 Additional Fluorescent Lamp Ballasts

............................................................... 2-10

2.3.3 Rationale for Coverage

...................................................................................... 2-10

2.3.4 Analysis of Individual Ballast Types

................................................................. 2-11

2.3.5 Summary

............................................................................................................ 2-18

2.4 MARKET AND TECHNOLOGY ASSESSMENT

...................................................... 2-19

2.4.1 Market Assessment

............................................................................................ 2-20

2.4.1.1 Manufacturers of Fluorescent Lamp Ballasts

........................................ 2-20

2.4.1.2 Product Classes

...................................................................................... 2-21

2.4.1.3 Ballast Shipments

................................................................................... 2-26

2.4.1.4 Regulatory and Non-Re gulatory Programs

............................................ 2-27

2.4.2 Technology Assessment

..................................................................................... 2-28

2.5 SCREENING ANALYSIS

............................................................................................ 2-30

2.5.1 Technology Options Screened Out

.................................................................... 2-31

2.6 ENGINEERING ANALYSIS

........................................................................................ 2-32

2.6.1 Preliminary Engineering Analysis Approach

.................................................... 2-33

2.6.2 Representative Produ ct Classes

......................................................................... 2-36

2.6.3 Baseline Ballasts and Candidate St andard Levels Analyzed

............................. 2-37

2.6.4 Results

................................................................................................................ 2-40

2.6.5 Scaling Between Pr oduct Classes

...................................................................... 2-44

2.6.6 Price Analysis

.................................................................................................... 2-44

2.6.7 Other Key Issues

................................................................................................ 2-47

2.7 ENERGY USE AND END-USE LOAD CHARACTERIZATION

............................. 2-48

2.8 MARKUPS ANALYSIS

............................................................................................... 2-49

2.9 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES

.................................. 2-50

2.10 SHIPMENTS ANALYSIS

............................................................................................ 2-52

2.11 NATIONAL IMPACT ANALYSIS

.............................................................................. 2-52

2.11.1 National Energy Savings Analysis

..................................................................... 2-53

2.11.2 Net Present Value Analysis

............................................................................... 2-53

2.11.3 Efficiency Scenarios and Trends

....................................................................... 2-54

2.12 LIFE-CYCLE COST SUBGROUP ANALYSIS

.......................................................... 2-54

2.13 MANUFACTURER IMPACT ANALYSIS

.................................................................. 2-55

2.13.1 Sources of Information for the Manufacturer Impact Analysis

......................... 2-55

2.13.2 Industry Cash-Flow Analysis

............................................................................. 2-56

2.13.3 Manufacturer Subgr oup Analysis

...................................................................... 2-56

2-i

### 2.13.4 Competitive Impacts Assessment

...................................................................... 2-56

2.13.5 Cumulative Regulatory Burden

......................................................................... 2-56

2.13.6 Preliminary Results for the Manufacturer Impact Analysis

.............................. 2-57

2.13.7 Impacts on Profitability

...................................................................................... 2-57

2.13.8 Product Conversion Costs/Diminishing Returns to Consumers

........................ 2-57

2.13.9 Product Innovation

............................................................................................. 2-58

2.14 UTILITY IMPACT ANALYSIS

................................................................................... 2-58

2.15 EMPLOYMENT IMPACT ANALYSIS

....................................................................... 2-59

2.16 ENVIRONMENTAL ASSESSMENT

.......................................................................... 2-59

2.16.1 Carbon Dioxide

.................................................................................................. 2-59

2.16.2 Sulfur Dioxide

.................................................................................................... 2-60

2.16.3 Nitrogen Oxides

................................................................................................. 2-60

2.16.4 Mercury

.............................................................................................................. 2-61

2.16.5 Particulate Matter

............................................................................................... 2-61

2.16.6 Monetization of Emission s Reduction Benefits

................................................. 2-62

2.17 REGULATORY IMPACT ANALYSIS

....................................................................... 2-63

LIST OF TABLES

TABLE 2.4.1 PRODUCT CLASSES FOR FLUORESCENT LAMP BALLASTS

... 2-26

TABLE 2.4.2 BALLAST MARKET SHARE IN 2005

............................................... 2-27

TABLE 2.4.3 FLUORESCENT LAMP BALLAST TECHNOLOGY OPTIONS

...... 2-30

TABLE 2.6.1 REPRESENTATIVE AND SCALED PRODUCT CLASSES FOR

FLUORESCENT LAMP BALLASTS

.......................................................................... 2-37

TABLE 2.6.2 BASELINE BALLASTS FOR TWO-LAMP FOUR-FOOT AND TWOFOOT U-SHAPED MBP IS & RS NORMAL BF PRODUCT CLASS

....................... 2-39

TABLE 2.6.3 SUMMARY OF PROPOSED CANDIDATE STANDARD LEVELS

FOR REPRESENTATIVE FLUORESCENT LAMP BALLAST PRODUCT CLASSES

2-40

TABLE 2.6.4 TWO-LAMP FOUR-FOOT MBP RS AND IS PRODUCT CLASS WITH

F32T8 BASELINE

......................................................................................................... 2-42

TABLE 2.6.5 TWO-LAMP FOUR-FOOT MBP RS AND IS PRODUCT CLASS WITH

F34T12 BASELINE

....................................................................................................... 2-43

LIST OF FIGURES

FIGURE 2.6.1 FULL PRODUCTION COSTS

......................................................................... 2-45

FIGURE 2.8.1 BALLAST DISTRIBUTION CHANNELS

..................................................... 2-49

2-ii

### CHAPTER 2. ANALYTICAL FRAMEWORK

2.1 INTRODUCTION

This chapter describes the analytical framework that the U.S. Department of Energy (DOE) is using to develop energy conservation standards for fluorescent lamp ballasts, including a description of the methodology, the analytical tools, and relationships among the various analyses that are part of th is rulemaking. Chapter 2 also provides an overview of the preliminary activities DOE conducted and discusses the comments it received. In addition, chapter 2 provides additional de tail on key issuesidentified in the executive summary. Finally, chapter 2 provides citations and crossreferences to the other chapters of the pr eliminary technical support document (TSD) that address DOE's analytical approach, inputs, and findings.

The analyses presented in this preliminary TSD include:

• a market and technology assessment that characterizes the fluorescent lamp ballast market, and reviews technologie s and designs that improve ballast efficiency;

• a screening analysis that reviews technolog y options to improve ballast efficiency and considers them according to four prescribed screening criteria;

• an engineering analysis that determines the manufacturer selling prices (MSPs) associated with more energy efficient fluorescent lamp ballasts by estimating the manufacturing production cost (MPC) a nd applying a manufacturer markup;

• an energy use characterization that generates energy use estimates for fluorescent lamp ballasts;

• a markup analysis that converts average MSPs to consumer installed prices;

• a life-cycle cost (LCC) analysis that calculates, at the consumer level, the discounted savings in operating costs th roughout the estimated average life of the ballast, compared to any increase in the installed costs likely to result directly from imposition of the standard;

• a payback period (PBP) analysis to estimate the amount of time it takes consumers to recover the higher purcha se expense of more energy efficient ballasts through lower operating costs;

• a shipments analysis that estimates shipments of fluorescent lamp ballasts over the time period examined in the analysis;

2-1

### • a national impact analysis (NIA) that assesses the aggregate impacts at the national level of potential en ergy conservation standards as measured by the net present value (NPV) of total consumer economic impacts and national energy savings (NES); and

• a preliminary manufacturer impact analysis (MIA) that begins to evaluate the effects on manufacturers that may result from a new efficiency standard.

DOE may revise any of its analyses based on comments and new information received. The analyses DOE will perform in the subsequent notice of proposed rulemaking (NOPR) stage in clude those listed below:

• an LCC subgroup analysis that evalua tes the economic impacts on identifiable groups of customers of fluorescent lamp ba llasts, including various categories of ballast purchasers or owners who may experience disproportionate impacts from a national energy conservation standard;

• a manufacturer impact analysis that estimates the financial impact of standards on

ballast manufacturers and cal culates impacts on competition, employment at the manufacturing plant, and manufacturing capacity;

• a utility impact analysis that estimates the effects of proposed standards on the installed capacity and the generating base of electric utilities;

• an employment impact analysis that estimates the impacts of standards on net jobs eliminated or created in the general economy as a consequence of increased spending on the installed price of balla sts and reduced customer spending on

energy;

• an environmental assessment to provide estimates of the effects of amended energy conservation standards on emissions of carbon (CO 2 

### ), sulfur dioxide (SO 2 

### ), nitrogen oxides (NO X 

### ), and mercury (Hg); and

• a regulatory impact analysis (RIA) that presents major alternatives to proposed standards that may achieve comparable energy savings at a reasonable cost.

DOE developed this analytical framew ork and documented its findings in the Energy Conservation Standards Rulemaking Framework Document for Fluorescent Lamp Ballasts (January 14, 2008). a 

### DOE presented the analytical approach to interested parties during a public meeting held on February 6, 2008.

a The framework document is available at http://www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_ballasts.html

.



### 2-2

### In response to the publication of the framework document and the framework public meeting, DOE received comments from interested parties on its analytical approach. This chapter summarizes the ke y comments DOE received, describes DOE’s responses, and summarizes any significant change s in the analytical approach made since DOE published the framework document. Lastly, in the executive summary of the preliminary TSD, DOE identifies issues on wh ich it seeks public comment, each of which is explained in the sections below.

2.2 BACKGROUND

2.2.1 History of Standards Rulemakings for Fluorescent Lamp Ballasts and Regulatory Authority

Amendments to the Energy Policy and Conservation Act of 1975 (EPCA) in the National Appliance Energy Conservati on Amendments of 1988 (NAECA 1988), Pub. L.100-357, established energy conservation st andards for fluorescent lamp ballasts. b 

### (42 United States Code (U.S.C.) 6295( g)(5)) These same amendments also required that DOE (1) conduct two rulemaking cycles to dete rmine whether these standards should be amended; and (2) determine for each rulemaking cycle whether the standards for fluorescent lamp ballasts should be amended to be applicab le 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 (FR) 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”). c 

### 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 promulgated in NAECA 1988 for certain fluor escent lamp ballasts. These standards eliminated certain “magnetic” ballasts, which operate lamps at line frequency (60 Hertz)

and are less efficient than electronic ballast s, which operate lamp s at high frequency. d 

### A

table of the codified standards can be found in appendix 3A of the preliminary TSD under 10 Code of Federal Regu lations (CFR) 430.32(m)(3).

b Although fluorescent lamp ballasts are typically understood to be used in the commercial and industrial sectors, the consumer products section of EPCA grants authority to DOE to cover and regulate this product. In Title III of EPCA, “Part A – Energy Conservation Program for Consumer Products Other Than Automobiles” includes a range of consumer products, some which may be classified for use primarily in the residential sector, such as refrigerators, dishwa shers, and clothes washers. Part A also includes consumer products that might also be used primarily in the commercial sector, however, such as fluorescent lamps, fluorescent lamp ballasts, and urinals. “Par t A-1 – Certain Industrial Equipment,” includes products that are used primarily in the commercial and industrial sectors, such as electric motors and pumps, as well as packaged terminal air conditioners and heat pumps.

c The final rule is available at http://www1.eere.energy.gov/buildings/appliance_standards/residential/gs_fluorescent_lamps.html

. d The standard level eliminated magnetic ballasts that operate one and two nominally 40W medium bipin lamps (F40T12) and for ballasts that operate two nominally 75W 8-foot T12 single pin slimline lamps (F96T12).



### 2-3

### Congress then 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)(5). 70 FR 60407. These standards established minimum efficiency requirements for “energy saver” versions of full-wattage ballasts, such as the F34T12 ballast. A table of the standards promulgated by EPACT 2005 can be found in appendix 3A in the preliminary

TSD.

In summary, fluorescent lamp ballasts that are currently regulated under EPCA, as amended, include ballasts that are designed to operate

• one and two nominally 40 watt (W) and 34W 4-foot T12 medium bipin (MBP) lamps (F40T12 and F34T12);

• two nominally 75W and 60W 8-foot T12 single pin (SP) 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).

The following ballasts are excluded from current regulations:

• ballasts designed for dimming to 50 perc ent or less of its maximum output;

• ballasts designed for use with two F 96T12HO 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; e



### • ballasts with a power factor of less th an 0.90 and designed and labeled for use only in residential building applications; and

• replacement ballasts as define d in paragraph (m)(4)(ii). f


### 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 made numerous amendments to EPCA.

EISA 2007 did not amend standards for fluores cent lamp ballasts. Instead, it directed

e 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 ° F or less.

f The exclusion provided for replacement ballasts requires that they meet certain cr iteria 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.



### 2-4

### DOE to amend its test procedure for fluorescent lamp ballasts to incorporate a measure of standby mode and off mode energy c onsumption. (42 U.S.C. 6295(gg)(2)) DOE published a NOPR for the standby and off mode test procedure on January 21, 2009. 74 FR 3450. DOE is also directed to incorporate standby mode and off mode energy use in any amended (or new) standard adopted after July 1, 2010. (42 U.S.C. 6295(gg)(3)) Because this energy conservation standards rulemaking for fluorescent lamp ballasts will be completed in 2011, the re quirement is applicable.

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

whether the standards in effe ct for fluorescent lamp ba llasts should be amended and whether the standards should apply to additi onal fluorescent lamp ballasts as stated under section 325(g)(7)(B) of EPCA. (42 U.S.C. 6295(g)(7)(B))

This rulemaking also addresses 42 U.S.C. 6295(gg)(3) in which DOE is directed to incorporate standby mode and off mode ener gy use in any amended (or new) standard adopted after July 1, 2010 pursuant to 42 U.S.C. 6295(o).

2.2.2 Test Procedure

As mentioned above, DOE published a NOPR on January 21, 2009 to amend its test procedure for fluorescent la mp ballasts to incorporate a measure of standby mode and off mode energy consumption. 74 FR 3450. g 

### In that NOPR, DOE proposed that fluorescent lamp ballasts do not operate in an off mode as defined by EISA 2007. (42

U.S.C. 6291(gg)(1)(A)(ii)) DOE furthermore proposed that the only ballasts that consume power in a standby mode are thos e that are active components of lighting control systems, meaning the ballasts incorporate electronics that can receive a signal from a control system, and can respond to that signal by adjusting light output. 74 FR 3450, 3452 (January 21, 2009). Thus, DOE propose d a test procedure to measure only standby mode energy consumption. Standb y and off mode energy consumption is

discussed in more detail in section 2.2.3.

On February 6, 2008, DOE held a public meeting in Washington, DC, to discuss

the framework document for the fluorescent la mp ballast energy conservation standards rulemaking. The comments from this meeting prompted DOE to initiate a separate rulemaking to revise the existing test pro cedure for active mode energy consumption. The section contains comments regarding the active mode test procedure that are also relevant to this energy conservation sta ndards rulemaking. All other comments on the active mode test procedure can be found in the active mode test procedure NOPR.

The National Electrical Manufacturers Association (NEMA) expressed concern that BEF measurements made in accordance with the current fluorescent lamp ballast test procedure (in appendix Q to subpart B of 10 CFR 430) can have a measurement uncertainty on the order of 5 percent, which is similar to the range of T8 ballast BEFs

g EISA 2007 directed DOE to amend test procedures for fluorescent lamp ballasts to incorporate a measure of standby mode and off mode energy consumption. (42 U.S.C. 6295(gg)(2))



### 2-5

### observed on the market today. The measuremen t uncertainty would thus negatively affect DOE’s ability to set standards for ballasts. (NEMA, Public Meeting Transcript, No. 9 at pp. 11-12, 23, 35-36, 42, 56-58; NEMA, No. 11 at pp. 2, 6) NEMA stated that this level of measurement uncertainty comes from seve ral sources, such as lamp manufacturing variations (as the test pro cedure requires photomet ric measurements), lamp filament heating, and differences between high-frequ ency and low-frequency ballasts. (NEMA, Public Meeting Transcript, No. 9 at pp. 26, 38-39, 43, 73-74, 76-77, 99, 124-125; NEMA, No. 11 at p. 6) Acuity Brands Lighting also commented that much of the marketplace does not use the BEF metric and may not have knowledge of it; the primary users of BEF values in ballast purchasing decisions ar e luminaire manufacturers. (Acuity Brands Lighting, Public Meeting Tran script, No. 9 at pp. 45-46)

For these reasons, NEMA, the New York State Energy Research and Development Authority (NYSERDA), and a joint comment produced by the Appliance Standards Awareness Project (ASAP), the American Council for an Energy-Efficient Economy (ACEEE), the Alliance to Save Energy (ASE ), the Natural Resources Defense Council (NRDC), the Northeast Energy Efficiency Partnerships (NEEP), and the Northwest

Power and Conservation Council (NPCC) all recommended that DOE consider changing

the metric from BEF to an alternate me tric. (Joint Comment, No. 12 at p. 1)

NEMA expressed support for a generic metric that would establish minimum efficiency standards for ballasts that do not ha ve such standards. (NEMA, No. 11 at p. 3) The Joint Comment stated that any alternat e metric implemented by DOE should account for all power loads served by the ballast , including arc current, cathode power, and standby power consumption. (Joint Comment, No. 12 at p. 1) NEMA suggested ballast efficiency (BE), which has lower measurement uncertainty (on the order of 1 to 2 percent) and is the most appropriate metric for instant start ballasts. (NEMA, Public Meeting Transcript, No. 9 at pp. 25-27, 36-38, 76-77, 100-101; NEMA, No. 11 at p. 2) NEMA, NYSERDA, and the Joint Comment recommended the investigation of relative system efficiency (RSE) as a metric. (NYS ERDA, Public Meeting Transcript, No. 9 at pp. 27-28; NEMA, Public Meeting Transcript , No. 9 at pp. 33, 100; Joint Comment, No. 12 at pp. 6-7) Neither the BE nor the RS E metric would refl ect individual lamp characteristics; thus, these metrics could be used to compare ballasts that operate different lamp types. NYSERDA supported a me tric that could be normalized to allow for comparison among different ballast type s. (NYSERDA, Public Meeting Transcript, No. 9 at p. 75)

DOE understands the concerns expressed by interested parties about the BEF

measurement method in the current fluorescent lamp ballast test procedure. DOE agrees that a number of factors, including the ma nufacturing variability of lamps used during ballast testing, can interact to produce me asurement uncertainty. As discussed in the active mode test procedure NOPR, DOE is propo sing to use the ballast efficiency metric to reduce measurement variation, and then to use transfer equations so that BEF can be reported for consistency with 42 U.S.C. 6295(g)(5), (g)(8).

2-6

### DOE also understands the importance of the ability to fully characterize all power loads served by a fluorescent lamp ballast, as suggested by the Joint Comment. DOE believes that BEF does capture all power modes listed by the Joint Comment (arc current and cathode power). DOE does not believe, however, that it is feasible to incorporate standby power into the BEF metric. See section 2.2.3 for further discussion of this issue.

NEMA suggested that if DOE cannot change the metric from BEF in the test procedure, DOE should develop a test proce dure that requires the measurement of an alternate metric unrelated to lamp lumen out put, along with a correlation to BEF that takes lamp filament ef fects into account. (NEMA, Public Meeting Transcript, No. 9 at pp. 32, 37-38) DOE is investigating the implementation of an alte rnate metric and a set of

correlation functions so that BEF values ca n be produced reliably and accurately during ballast testing.

NEMA commented that it is studying the measurement uncertainty of BE through ballast testing and may eventually encour age the industry-wide usage of BE. Lamp

manufacturers as well as technical coordinators from the American National Standards Institute (ANSI) are involved, and NEMA has already initiated the usage of BE in its Premium Ballast Program. NEMA invited DOE a nd other interested parties to participate in the investigation. (NEMA, Public Meeting Transcript, No. 9 at pp. 23-25, 32, 37-39, 41-42, 45, 48-50, 53-55; NEMA, No. 11 at p. 3) ASAP encouraged DOE to partake in NEMA’s evaluation of a new metric. (ASAP, Public Meeting Transcript, No. 9 at pp. 47, 49) DOE participated in NEMA’s technical committee on ballast efficiency to obtain additional data that DOE is now using to develop the active mode test procedure.

Participants at the public meeting also discussed the lack of compliance and enforcement of efficiency standards. Two manufacturers, Acuity Brands Lighting and Osram Sylvania, stated that they have observed non-compliant ballast s that were labeled as compliant in the marketplace. (Acuity Brands Lighting, Public Meeting Transcript, No. 9 at pp. 88-89; Osram Sylvania, Public M eeting Transcript, No. 9 at p. 90) Acuity Brands Lighting suggested that DOE should share the legal responsibility for enforcing compliance with standards. (Acuity Brands Li ghting, Public Meeting Transcript, No. 9 at pp. 88-89)

Compliance with the fluorescent ballast standard has been required and enforceable since its effective year. Manufacturers, however, are not yet required to submit compliance certification reports under 10 CFR 430.62. Therefore, DOE is modifying reporting requirements for ballasts in the active mode test procedure NOPR. DOE believes that modifying these reporting requirements will aid in the certification and enforcement of energy conservation standa rds for ballasts. DOE requests comments on other ways that it can enhance the certification and enforcement procedures.

More information about the active mode TP NOPR can be found on DOE’s

website at http://www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp _ballasts.html

.

2-7

### 2.2.3 Standby and Off Mode Energy Consumption

EISA 2007, enacted December 19, 2007, requires DOE to amend test procedures to include standby mode and off mode en ergy consumption in the overall energy efficiency, energy consumption, or other energy descriptor for each covered product for which DOE’s current test procedures do not fully account for standby mode and off mode energy consumption. If that is technically infeasible, DOE must prescribe a separate standby mode and off mode energy use test procedure, if technically feasible. (42 U.S.C. 6295(gg)(2)(A)) In January 2009, DOE prescrib ed a separate standby mode test procedure and determined that fluorescent la mp ballasts do not exhibit off mode energy use. In addition, DOE stated that the onl y ballasts subject to standby mode power measurements would be those that incorporate some electronic circuit enabling the ballast to communicate with and be part of a lighting control system ( e.g. , a digitally addressable lighting interface (DALI)). 74 FR 3450.

The amendments to EPCA contained in s ection 310(3) of EISA 2007 direct that any final rule establishing or revising a sta ndard for a covered product adopted after July 1, 2010 incorporate standby mode and off mode energy use into a single amended or new standard if feasible or sepa rate standard if not feasible. (EPCA section 325(gg)(3); 42

U.S.C. 6295(gg)(3)) In addition, the single amended new or separate standard must achieve the maximum improvement in energy ef ficiency that is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A))

The Joint Comment argued that DOE should use an alternate metric to BEF that would account for all power loads served by the ballast, including standby power consumption. (Joint Comment, No. 12 at p. 1) The current active mode test procedure determines ballast efficiency, whereas sta ndby mode test procedure reports energy consumption. Ballast efficiency is reported in terms of BEF for consistency with 42

U.S.C. 6295(g)(5) and (g)(8), however, while en ergy consumption is expressed in watts. Because BEF is a measure of efficiency and standby mode power is a measure of energy consumption, DOE does not believe it is feasible to incorporate a measure of standby mode energy use into the BEF metric. Therefore, DOE intends to establish a separate metric for standby mode energy consum ption as allowed by EPCA. (42 U.S.C. 6295(gg)(3)(B))

As stated earlier, the only ballasts that exhibit standby mode energy use are those that incorporate an electronic circuit that enables the ballast to communicate with and be part of a lighting control interface ( e.g. , DALI-enabled ballasts). DOE believes that the only commercially available ballasts that incorporate an electronic circuit to communicate with a lighting control interface are dimming ballasts. With the exception of dimming ballasts, NEMA agreed that fluorescent lamp ballasts typically do not consume power in standby mode. (NEMA, P ublic Meeting Transcript, No. 9 at p. 69; NEMA, No. 11 at p. 2) In considering the preliminary scope of coverage discussed in section 2.3, DOE maintains the exclusion of dimming ballasts from energy conservation standards. Therefore, none of the ballasts under consideration for coverage exhibit any standby mode energy use. Because it is not technologically feasible to reduce standby mode or off mode energy use for any balla st currently being considered for amended

2-8

### energy conservation standards, DOE tenta tively concludes that it cannot establish a separate standard that incorporates standby or off mode energy use. If DOE chooses to revise the scope of coverage to include dimming ballasts and ballasts that exhibit a lighting control interface, DOE will re-evaluate whether standby mode standards are justified.

2.3 SCOPE OF COVERAGE

EPCA directs DOE to amend energy conservation standards for fluorescent lamp

ballasts and to determine wh ether current standards shoul d be made applicable to additional fluorescent lamp ballasts. (42 U.S.C. 6295(g)(7)(B)) After identifying additional ballasts for consideration, DOE conducted a preliminary assessment of

whether a standard for these ballasts would have the potential to meet the criteria for prescribing new or amended standards

⎯ i.e. , demonstrating the potential for energy savings and being technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) As discussed, DOE’s preliminary analysis has determined that certain

ballasts meet the criteria for new or am ended energy conservation standards.

2.3.1 Current Scope of Ballast Energy Conservation Standards

The current energy conservation standards for ballasts originate from two

sources

⎯ an energy conservation standard prom ulgated in the 2000 Ballast Rule and

EPACT 2005. The 2000 Ballast Rule set standards for 4-foot and 8-foot T12 lamps that

took effect in 2005. These standards covere d ballasts that operate F40T12, F96T12, and F96T12HO lamps, but included several exemptions h 

### . Additional energy conservation standards from the 2000 Ballast Rule apply to replacement F40T12 ballasts and F34T12 ballasts and take effect in 2010. EPACT 2005 pr escribed energy conservation standards specific to ballasts designed for lower wattage applications that have an initial effective date of July 1, 2009. These prescribed sta ndards cover ballasts de signed to operate F34T12 lamps, F96T12/ES lamps, a nd F96T12HO/ES lamps. (See 10 CFR 430.32(m)(4)(ii) and 430.32(m)(5)-(6)) In summary, current ballast standards cover the following ballasts with the exclusions previously noted:

• F34T12

• F40T12

• F96T12

• F96T12/ES

• F96T12HO

• F96T12HO/ES

h Ballasts designed for dimming to 50 percent or less of its maximum output, ballasts for use with two F96T12HO lamps at ambient temperatures of

− 20 °F or less and for use in an outdoor sign, ballasts with a power factor of less than 0.90 and designed and labeled for use only in residential building applications, and replacement ballasts are excluded from the standards promulgated in the September 2000 fluorescent lamp ballast energy conservation standard final rule.



### 2-9

### 2.3.2 Additional Fluorescent Lamp Ballasts

According to the definition set forth in 42 U.S.C. 6291(29)(A), “[t]he term ‘fluorescent lamp ballast’ means a device whic h is used to start and operate fluorescent lamps by providing a starting voltage and current and limiting the current during normal operation.” In determining which fluorescen t lamp ballasts would be suitable for consideration under 42 U.S.C. 6295(g)(7)(B), DOE intends to focus its inquiry on those ballasts that operate fluorescent lamps with generic physical and operational features closely matching the Illuminating Engineering Society of North America’s (IESNA) widely accepted definition of “fl uorescent lamp,” as contained in The IESNA Lighting Handbook: Reference and Application ” Ninth Edition, 2000, p. G-14:

The definition of a fluorescent lamp is “a low-pressure mercury electricdischarge lamp in which a fluorescing coating (phosphor) transforms some of the UV energy generated by the discharge into light.”

This IESNA definition is consistent with the general description of a “fluorescent lamp” in the introductory language of 42 U.S.C. 6291(30)(A). i 

### Because the only lamps with these features are commonly understood to be fluorescent lamps, DOE would only consider standards for ballasts that operate such fluorescent lamps. Therefore, in considering whether to amend the standards in effect for fluorescent lamp ballasts so that they apply to “additional” fluor escent lamp ballasts as specified in section 325(g)(7)(B) of EPCA, DOE will consider all fluorescent lamp ballasts (for which EPCA does not prescribe standards) that operate fluor escent lamps, as defined by IESNA.

ASAP commented that EPCA does not preclude DOE from considering previously exempt ballast types in this energy conservation standards rulemaking. (ASAP, Public Meeting Transcript, No. 9 at pp. 106-107) DOE has the authority to determine “whether to amend the standards in effect for fluorescent lamp ballasts, including whether such standards should be amen ded so that they would be applicable to additional fluorescent lamp ballasts.” (42 U.S.C. 6295(g)(7)(B)) Thus, Congress authorized DOE to consider setting standards for fluorescent lamp ballasts that had been excluded from the prescriptive standards set by EPCA, as amended. Accordingly, DOE has considered these ballast types in its preliminary assessment.

2.3.3 Rationale for Coverage

As mentioned in section 2.3, DOE c onsiders potential energy savings, technological feasibility and economic justif ication when determining the scope of coverage. DOE assessed the potential energy savings from market share estimates, potential ballast designs that improve ballast efficiency, a nd other factors. For market share estimates, DOE obtained quantitative shipment information for many ballast types. In the absence of specific shipment data, DOE estimated shipments and market share using information obtained during manufactu rer interviews. For example, based on

i The introductory language of 42 U.S.C. 6291(30)(A) is as follows: “the term ‘fluorescent lamp’ means a low pressure mercury electric-discharge source in which a fluorescing coating transforms some of the ultraviolet energy generated by the mercury discharge into light.”



### 2-10

### information from manufacturers, DOE was able to estimate the annual shipments for cold temperature outdoor sign ballasts as a percentage of a larger category reported in the U.S. Census. DOE invites comments on the shipment or market share data presented in this

section.

DOE also assessed the potential to achieve energy savings in certain ballasts by considering whether those ballasts serve as potential substitutes for other regulated ballasts. At the framework public meeting, ASAP suggested that DOE should anticipate market changes as a result of the ballast en ergy conservation standards. (ASAP, Public Meeting Transcript, No. 9 at pp. 63-64) DOE agrees that leaving potential substitutes unregulated runs the risk that regulation of one ballast type may lead to rapid increased sales of other, unregulated substitutes. This shift toward unregulated ballasts may result in decreased energy savings or even increased energy use. To avoid these consequences, DOE plans to consider coverage of ballasts that are potential substitutes for any ballast that has high energy savings potential and is likely to be regulated. Though the shipments of these substitute ballasts may not currently be high volume, energy savings could still be significant because these ballasts may capture increased market share if they are left unregulated. As long as efficiency improveme nts are technologically feasible, coverage of these additional substitute ballasts could not only yield energy savings, but also prevent potentially significant losses in energy savings through the substitution effect.

In addition to independent ly conducting its preliminary determination analysis,

DOE considered comments on the additional ballasts it should cover. The following subsections provide a discussion of the balla sts considered for coverage and related

comments. DOE invites comments on the rati onale for coverage presented in this preliminary determination. DOE also invites comments on the scope of coverage proposed in this pre liminary determination.

2.3.4 Analysis of Individual Ballast Types

As stated in section 2.2.1, current ballast standards cover ba llasts that operate F34T12, F40T12, F96T12, F96T12/ES, F96T12HO, and F96T12HO/ES lamps. Pursuant to its obligation to cover additional ballast types (42 U.S.C. 6295(g)(7)(B)), DOE considered various unregulated ballasts. At the framework public meeting, DOE stated it would consider expansion to unregulated ba llasts that operate the fluorescent lamps covered under EPCA, which include:

• 4-foot medium bipin, rated ≥ 28 watts;

• 2-foot medium bipin U-shaped lamps, rated ≥ 28 watts;

• 8-foot recessed double contact rapid start high output (HO) lamps, 0.800 nominal
amperes, as defined in ANSI C78.1–1991; and

• 8-foot single pin instant start slimline lamps, rated ≥ 52 watts, as defined in ANSI

C78.3–1991.

DOE noted that it was considering covering additional ballast type s that operate the lamps covered in the recently published rulemaking for general service fluorescent lamps.

2-11

### The scope of coverage outlined in the energy conservation standards rulemaking for general service fluorescent and incandescen t reflector lamps (hereafter “the 2009 Lamps Rule”) j 

### included the following additional lamp types:

• 2-foot medium bipin U-shaped lamps with a rated wattage ≥ 25 and < 28;

• 4-foot medium bipin lamp s with a rated wattage ≥ 25 and < 28;

• 4-foot T5 miniature bipin straight-shape d standard output (SO) lamps with rated

wattage ≥ 26;

• 4-foot T5 miniature bipin straight -shaped HO lamps with rated wattage ≥ 49;

• 8-foot recessed double contact (RDC) rapid start HO lamps other than those

defined in ANSI Standard C78.1–1991;

• 8-foot RDC rapid start HO lamps other than 0.800 nominal amperes defined in

ANSI Standard C78.1–1991; and

• 8-foot single pin instant start slimline lamps with a rated wattage ≥ 52, not

defined in ANSI Standard C78.3–1991.

DOE selected lamps for coverage in th e 2009 Lamps Rule using the same criteria as in this rulemaking for fluorescent lamp ballasts. Therefore, if a lamp was deemed to have the potential for significant energy sa vings (based on shipment volume and other factors), the ballasts that operate those lamps will likely also have significant potential energy savings. The Joint Comment supports DOE’s decision to consider a broader scope of coverage through the ballasts noted in the framework document and framework public meeting. (Joint Comment, No. 12 at pp. 2-3, 8) In addition, ASAP urged DOE to consider a broader scope of coverage than in prev ious rulemakings. (ASAP, Public Meeting Transcript, No. 9 at p. 61)

The Joint Comment supports a scope of coverage limited to ballasts with input voltage to 120 to 277 volts. (Joint Comment, No. 12 at p. 5) DOE examined the ballast market and found input voltages of 120V to 277V to be common to the U.S. market. Ballasts outside this range are primarily de signed for foreign markets, such as 347V ballasts for the Canadian market. DOE’s preliminary determination of scope includes ballasts designed only for operation w ithin the range of 120 to 277 volts.

At the framework public meeting, NEMA commented that the maturity of ANSI

standards should be considered in the dete rmination of technological feasibility for a ballast product. (NEMA, Pub lic Meeting Transcript, No. 9 at p. 116) DOE understands that a product contained in a mature ANSIstandard would likely belong to a welldeveloped product line, but belie ves that investigating product offerings currently sold by

manufacturers is a better method to determine technological feasibility. DOE establishes technological feasibility by understanding the ra nge of energy efficient products available in a particular product class. When products are available at multiple levels of efficiency,

j The final rule for energy conservation standards for general service fluorescent and incandescent reflector lamps was published in the Federal Register on July 14, 2009. It is available at http://edocket.access.gpo.gov/2009/pdf/E9-15710.pdf

.



### 2-12

### energy conservation standards are technologic ally feasible. DOE does consider maturity of a product in the rulemaking process, but does not plan to use the maturity of ANSI standards as criterion for technological feasib ility. The following sections discuss each additional ballast type and de termine whether each type should be extended coverage.

Dimming ballasts . DOE received comments from ASAP at the framework public meeting and in the Joint Comment recommendi ng expanding the scope of coverage to include dimming ballasts. (ASA P, Public Meeting Transcript, No. 9 at pp. 62, 69, 108; Joint Comment, No. 12 at pp. 2-3) The cu rrent energy conservation standards promulgated by the 2000 Ballast Rule exclude ballasts designed for dimming to 50 percent or less of their maximum output. NEMA believes that dimming ballasts are beyond the scope of this rulemaking, alt hough ASAP disagrees with this conclusion. (NEMA, Public Meeting Transcript, No. 9 at p. 69; ASAP, Public Meeting Transcript, No. 9 at p. 69; NEMA, No. 11 at p. 2) NEMA commented that it is premature to set requirements for dimming ballasts because dimming ballast compatibility with lamps is still being defined. NEMA argued that BEF values from today's commercially available products are inappropriate for use in this ru lemaking analyses because BEF values will change once a lamp-ballast compatibility standard is developed. (NEMA, Public Meeting Transcript, No. 9 at pp. 108-109) NEMA also commented that the energy savings possible with dimming systems, using evidence from DOE's Commercial Lighting Initiative, can be on the order of 30 to 50 percent, and far outweigh any incremental gains of a few percent that can be realized by setting component standa rds on dimming ballasts. (NEMA, Public Meeting Transcript, No. 9 at p. 109) However, the Joint Comment stated that dimming ballasts exhibit a range of efficiencies. The Joint Comment urged DOE to consider setting an efficiency standard that removes the least efficient products from the market but allows flexibility for including features that affect total system efficiency, such as control systems. (Joint Comment, No. 12 at p. 4)

As discussed in section 2.3.2, DOE ha s determined it is not precluded from considering previously exempt ballasts as “additional fluorescent ballasts.” Data from the 2005 U.S. Census reveal that dimming ballast s have less than 1 percent market share. k


### Although some manufacturers do not report thei r shipments, after interviewing ballast manufacturers, DOE concluded the current market share is likely close to the market share indicated by the U.S. Census. Therefor e, DOE has tentatively determined not to

include these ballasts in the sc ope of coverage for this rule making because of their small market share and their use in existing energy-saving systems.

After examining the potential for substitution from other ballast types, DOE also believes there is little risk of dimming ballasts becoming a substitute for other covered ballast types. Dimming ballasts are more expensive than comparable fixed-light output ballasts. Moreover, dimming ballasts require specialized control systems, resulting in additional upfront cost. For these reasons, DOE believes dimming ballasts are not a potential loophole for existing ballast standard s and currently represent a small ballast market segment. Therefore, DOE does not pl an to extend coverage to dimming ballasts.

k Except when otherwise specified, DOE used data from the 2005 U.S. Census, available at www.census.gov/cir/www/335/mq335c.html

.



### 2-13

### Mini-ballasts. The Joint Comment requested that DOE consider mini-ballasts used in under-cabinet fixtures. (Joint Comm ent, No. 12 at p. 5) DOE found that while mini-ballasts could be made more efficient, they represent a tiny fraction of the ballast market and will likely lose additional market share to LED fixtures. There is little potential for substitution for this ballast type because the light output is too small for typical fluorescent lamp-and-ballast systems. Based on these findings, DOE does not plan to include this ballast type in the scope of coverage.

Ballasts that operate straight and U-shaped lamps ranging in size from 2 to 8 feet and diameters from T5 to T12. The Joint Comment recommended that DOE cover ballasts that operate less common lamp types in addition to high volume ballasts. The comment suggested covering ballasts for straight and U-shaped lamps ranging from 2 feet to 8 feet and diameters from T5 to T12, as well as reduced-wattage lamps. (Joint Comment, No. 12 at p. 4) DOE’s research f ound that many of these lamps and ballasts have very small market shares . Though a ballast can operate lamps other than the one it is designed to operate, DOE believes there is low risk of substitution. There has been no substitution effect under current and previous energy conservation standards, when the impacts could have been even greater. Th e 2009 Lamps Rule did not cover lamps of alternate lengths, diameters, or bases for similar reasons

⎯ low market share with limited potential for growth. For these reasons, and becau se these ballasts are unlikely to be used as substitutes, DOE does not plan to include them in this rulemaking.

Cold temperature ballasts for outdoor signs. The most recent standards exclude ballasts designed to operate two F96T12HO la mps at ambient temperatures of 20 °F or less and for use in an outdoor sign. ( 10 CFR 430.32(m)) As discussed earlier, DOE believes it has the statutory authority under 42 U.S.C. 6295(g)(7)(B) to consider these ballasts for the current energy conservati on standards rulemaking. Cold temperature ballasts for outdoor signs were originally ex cluded because electronic sign ballasts were

not available at the time of the 2000 Ballast Rule. Now, electronic sign ballasts are gaining acceptance in the market. DOE received multiple comments requesting that cold temperature ballasts be included in this ru lemaking. (Joint Comment, No. 12 at pp. 2-3; ASAP, Public Meeting Transcript, No. 9 at p. 62) The Joint Comment suggested that low temperature ballasts, such as those used in outdoor signage and in refrigeration applications, should be covered. Otherwise, low temperature ballasts could become a substitute for regulated ballasts in standard applications. (Joint Comment, No. 12 at p. 5)

DOE found that the market share of cold temperature ballasts was about 1 percent in 2005. Sales of LEDs in outdoor signage c ould rise in the future. However, DOE believes LEDs will have a more immediate impact in the neon sign market than in the market for large fluorescent outdoor signs. Though high output ballasts have a relatively small market share, the energy savings potential per ballast is substantial. Moving from a magnetic to an electronic sign ballast could reduce energy consumption by as much as 25 to 35 percent. Given that sign ballasts exist at multiple efficiency levels, DOE has determined it is technologically feasible to cover sign ballasts. Preliminary results from

2-14

### the LCC and NIA analyses indicate that setting standards would be economically justified.

Cold temperature ballasts for outdoor sign s are typically designed to operate a range of lamp lengths and numbers of lamps. Based on product catalogs and

conversations with manufactur ers, DOE found that sign ballasts can be designed to operate HO lamps between 1.5 and 10 feet and between 1 a nd 6 lamps per ballast. DOE plans to include these ballasts in the scope of coverage.

T5 ballasts. DOE received comments both for and against covering T5 ballasts. Both ASAP and the Joint Comment encourag ed DOE to carefully consider additional ballast types such as T5 ballasts. (Joint Comment, No. 12 at p. 3; ASAP, Public Meeting Transcript, No. 9 at p. 108) Conversely, NE MA did not support including T5 ballasts

because it believes T5 ballasts to be an immature technology that is not yet established in the marketplace. (NEMA, Public Meeting Tr anscript, No. 9 at p. 106; NEMA, No. 11 at

p. 3)

The U.S. Census reports that T5 ballasts comprised about 4 percent of the ballast market in 2005. Shipment data are available only for T5 high output ballasts, so the actual market share is likely larger than this. T5 ballast shipments have been steadily increasing since the shipments were first reported in 2002. Furthermore, DOE research indicates that T5 high output ballasts are ra pidly taking market share from metal halide systems used in high bay industrial applica tions. DOE concluded that T5 ballasts are a growing market segment of significant size and represent significant potential energy savings. In its interviews, DOE learned th at some ballast manuf acturers are concerned that a low-cost, inefficient product could enter the market if T5 ballasts were not subject

to standards. This inefficient T5 ballast could take market share from more efficient T5 or T8 ballasts, decreasing potential energy saving s. If T5 lamps were subject to standards, the possibility of substitution would be eliminated. Because higher-efficiency versions of some of these ballasts are already present in the market, DOE tentatively concludes that standards for these ballasts are technologic ally feasible. Based on DOE’s preliminary analysis of these ballasts in the LCC and NIA, coverage of T5 ballasts would be economically justified. DOE believes T5 ballasts have a significant and growing market share, and also have the potential to beco me a loophole in ballast standards if not included. In addition, DOE believes the T5 ballast market is sufficiently established that it will not be adversely affected by energy conservation standards.

DOE found that T5 ballasts and lamps exist in a variety of lengths and wattages. Although standard T5 lamps include watta ges ranging from 14W to 80W, and lengths ranging from nominally 2 feet to 6 feet, the primary driver of T5 ballast and lamp market share growth is substitution for currently regulated 4-foot T8 MBP ballasts and lamps. Therefore, DOE proposes to cover only the balla sts designed to operate nominally 4-foot lengths of T5 miniature bipin (miniBP) lamps. These include one and two-lamp 4-foot T5

miniBP SO ballasts and one through four-lamp 4-foot T5 miniBP HO ballasts.

2-15

### Low power factor ballasts. Low power factor ballasts have a power factor less than 0.9 and are typically used in residentia l applications. These ballasts are exempt from current energy conservation standards. DOE has the authority to consider previously exempted ballasts in this rulemaking and has received multiple comments on low power factor ballast coverage.

The Joint Comment encouraged DOE to ev aluate coverage of low power factor ballasts. (Joint Comment, No. 12 at pp. 2-3) It stated that the exemption for low power

factor ballasts should be rem oved due to improvements in electronic ballast technology and reduced production costs. Additionally, th e Joint Comment noted that the size of the

residential ballast market should be large enough to warrant inclusion in the scope of coverage. At the framework public meeting, ASAP also noted that residential ballasts have significant market share and suggested that DOE consider low power-factor ballasts for coverage. (ASAP, Public Meeting Transcript, No. 9 at pp. 61, 108)

Only magnetic residential ballast shipments are reported in the U.S. Census. The market for residential magne tic ballasts held steady at a bout 7 percent between 1995 and 2002, and then decreased to about 1.5 percen t in 2005. DOE believes the 2005 market share and total shipments to be much high er. Electronic ballasts are a common option for residential fluorescent lighting fixtures, but they are not reported in the Census data. Also, many residential ballast s are manufactured overseas by foreign companies that do not share shipment data with the U.S. Cens us. Because of these omissions, DOE believes residential ballasts represent a sizeable portion of the overall ballast market.

Residential ballasts do exhibit variation in energy e fficiency. Residential ballasts can be magnetic or electronic and also exis t in both T8 and T12 diameters. Therefore, DOE believes standards for low power factor ballasts are technologically feasible. Preliminary analysis in the LCC and NIA indicates that standards for residential ballasts are economically justified. For these reasons, DOE plans to include residential ballasts that operate 4-foot medium bipin or 2-foot U-shaped lamps in the scope of coverage.

Four-foot T8 MBP and 2-foot T8 U-shaped ballasts. At the framework public meeting, DOE stated its intention to expand th e scope of coverage to include ballasts that operate 4-foot medium bipin and 2-foot U-shaped lamps with rated wattages greater than or equal to 25 watts. These lamps were s ubject to standards in the 2009 Lamps Rule. DOE received several comments in support of c overing the T8 ballasts that operate these lamps, both from manufacturers and energy efficiency advocates (NEMA, No. 11 at p. 3; Joint Comment, No. 12 at p. 4; NEMA, Pub lic Meeting Transcript, No. 9 at p. 106)

According to the U.S. Census, the market share of 4-foot T8 MBP and 2-foot T8 U-shaped ballasts represented 55 percent of shipments in 2005. In addition, ballasts that operate 4-foot T8 MBP and 2-foot T8 U-shap ed lamps exhibit a range of efficiencies, thereby satisfying the technological feasibilit y requirement. Partly because of energy conservation standards promulgated for T12 balla sts, shipments of T8 ballasts have been increasing. T8 ballasts are being purchased and installed in applications previously popular for T12 systems. There is potential fo r significant energy savings by regulating

2-16

### the 4-foot T8 ballast market. Furthermore, preliminary analysis in the LCC and NIA demonstrated the potential for significant economic savings. For these reasons, DOE proposes to include ballasts that operate 4-foot T8 MBP and 2-foot T8 U-shaped lamps in the scope of coverage.

DOE received comments that ballasts designed to operate lower wattage lamps should be covered in addition to those designed to operate standard-w attage lamps. (Joint Comment, No. 12 at p. 3) Afte r investigating the ballast market, DOE agrees. DOE does not want to create a potential loophole wher e the standard-watta ge lamp-and-ballast systems that dominate the market can shift to reduced-wattage systems. Therefore, if DOE includes a ballast in its scope of coverage, it will also cover ballasts that can operate the same type of lamp (length, contacts, etc.) at reduced wattages. For example, DOE will not only cover the two-lamp ballast that opera tes the 32W T8 lamp, but also all ballasts that operate two straight-shaped lamps (commonly referred to as 4-foot medium bipin lamps) with medium bipin base s of nominal overall length of 48 inches and rated wattage

of 25 or more.

Eight-foot SP slimline T8 ballasts. At the framework public meeting, DOE announced its intention to expand the scope of coverage to include ballasts that operate 8­ foot single pin instant start slimline lamps with a rated wattage greater than or equal to 52 watts, as defined in ANSI C78.3–1991, as well as 8-foot single pin instant start slimline lamps with a rated wattage greater than or equal to 52, not defined in ANSI Standard C78.3–1991. These lamps were included in coverage in the 2009 Lamps Rule. DOE received comments in support of covering the T8 ballasts from many interested parties, including manufacturers and energy efficiency advocates. (NEMA, No. 11 at p. 3; Joint Comment, No. 12 at p. 4; NEMA, Public Meeting Transcript, No. 9 at p. 106)

According to the U.S. Census, 8-foot SP slimline T8 ballasts had about 2 percent market share in 2005; 8-foot SP slimline T 12 ballasts had about 3 percent. While the

market share for 8-foot SP slimline T8 balla sts is relatively small, the 2009 Lamps Rule will eliminate all currently commercially available T12 lamps, further increasing demand for T8 lamp-and-ballast systems. In add ition, while some 8-foot SP slimline T12 lamps are being replaced by two 4-foot T8 lamps, others are being replaced by 8-foot SP slimline T8 lamps. DOE believes there is potential for significant energy savings by regulating ballasts that operate 8-foot SP slimline T8 lamps and that these regulations are technologically feasible. Also, based on DOE’s preliminary analysis of these ballasts in the LCC and NIA, coverage of ballasts that operate 8-foot SP slimline T8 lamps would be economically justified. For these reasons, DOE plans to include balla sts that operate 8­ foot SP slimline T8 lamps in the scope of coverage.

Eight-foot HO T8 ballasts . At the framework public meeting DOE announced it planned to cover ballasts that operate 8-foot recessed double contact rapid start high output lamps, 0.800 and other than 0.800 nominal amperes, as defined in ANSI C78.1– 1991. These lamps were included in coverage in the 2009 Lamps Rule. Both T8 and T12 HO ballasts can drive 8-foot RDC lamps, but the current ballast energy conservation standard only regulates F96T12HO and F96T12HO/ES ballasts. In addition, DOE has

2-17

### received comments in support of covering the T8 ballasts from many interested parties, including manufacturers and energy efficiency advocates. (NEMA, No. 11 at p. 3; Joint Comment, No. 12 at p. 4; NEMA, Public Meeting Transcript, No. 9 at p. 106)

According to the U.S. Census, the market share of 8-foot HO (T8 and T12) ballasts (excluding cold temperature si gn ballasts) was about 0.5 percent in 2005. Because shipments of 8-foot RDC HO lamps are mostly T12 lamps, DOE believes most of the 8-foot HO ballasts currently shipped are T12. The 2009 Lamps Rule will reduce the number of T12 RDC HO lamps shipped by promulgating more stringent T12 lamp standards. In addition, DOE received comme nts on the 2009 Lamps Rule that T8 RDC HO lamps are replacing T12 RDC HO lamps. DOE believes the associated fluorescent lamp ballasts will follow a similar trend toward increased T8 RDC HO ballast shipments. Because T8 HO ballasts are currently unregulated, DOE believes cove ring these ballasts will prevent potential negative substitution effects. There is a range of efficiency levels for 8-foot T8 HO ballasts currently in th e market; therefore, energy conservation standards are technologically feasible. In addition, preliminary analysis in the LCC and NIA demonstrated the potential for sign ificant economic savings. Based on these findings, DOE proposes to include 8-foot HO T8 ballasts in the scope of coverage.

2.3.5 Summary

In summary, DOE is considering extending coverage to the following list of fluorescent lamp ballasts:

(1) ballasts that operate one, two, three, four, five, or six straight-shaped lamps (commonly referred to as 4-foot medium bipin lamps) with medium bipin bases, a nominal overall leng th of 48 inches, a rated wattage l 

### of 25W or more, and an input voltage at or between 120V and 277V; (2) ballasts that operate one, two, three, four, five, or six U-shaped lamps (commonly referred to as 2-foot U- shaped lamps) with medium bipin bases, a nominal overall length between 22 and 25 inches, a rated wattage of 25W or more, and an input vo ltage at or between 120V and 277V; (3) ballasts that operate one or two rapid start lamps (commonly referred to as 8-foot high output lamps) with re cessed double contact bases, a nominal overall length of 96 inches, and an i nput voltage at or between 120V and 277V; (4) ballasts that operate one or two instant start lamps (commonly referred to as 8-foot slimline lamps) with single pin bases, a nominal overall length of 96 inches, a rated wattage of 52W or more, and an input voltage at or between 120V and 277V; (5) ballasts that operate one or two straight-shaped lamps (commonly referred to as 4-foot miniature bipin standard output lamps) with miniature bipin bases, a nominal length between 45 a nd 48 inches, a rated wattage of 26W or more, and an input voltage at or between 120V and 277V;

l The 2009 Lamps Rule adopted a new definition for rated wattage that can be found in 10 CFR 430.2.



### 2-18

### (6) ballasts that operate one, two, thr ee, or four straight-shaped lamps (commonly referred to as 4-foot minia ture bipin high output lamps) with miniature bipin bases, a nominal leng th between 45 and 48 inches, a rated wattage of 49W or more, and an input voltage at or between 120V and 277V; (7) ballasts that operate one, two, thre e, or four straight-shaped lamps (commonly referred to as 4-foot medi um bipin lamps) with medium bipin bases, a nominal overall length of 48 inches, a rated wattage of 25W or more, an input voltage at or between 120V and 277V, a power factor of less than 0.90, and are designed and labeled for use in residential applications; and (8) ballasts that operate one, two, three, four, five, or six rapid start lamps (commonly referred to as 8-foot hi gh output lamps) with recessed double contact bases, a nominal overall length of 96 inches, an input voltage at or between 120V and 277V, and operate at ambient temperatures of 20 °F or less and are used in outdoor signs.

DOE is considering exempting the following ballasts: (1) ballasts designed for dimming to 50 percent or less of the maximum output of the ballasts; (2) mini-ballasts designed for use in under-cabinet fixtures; (3) ballasts that operate lamps with lengths and wattages other than those described above; and (4) ballasts with input voltages out side of the covered range.

2.4 MARKET AND TECHNOLOGY ASSESSMENT When DOE begins an energy conser vation standards rule making, it gathers information that provides an overall picture of the market for the products concerned, including the nature and market characteristic s of the products and the industry structure. This activity consists of both quantitative and qualitative analysis based primarily on publicly available information. The subjects addressed in the market and technology assessment for the preliminary TSD analysis include the major manufacturers, product classes, retail market trends, shipment s of covered products , regulatory and nonregulatory programs, and technologies that c ould be used to improve the efficiency of fluorescent lamp ballasts. This informa tion serves as a resource throughout the rulemaking.

DOE reviewed existing literature and spoke with manufacturers to gain an understanding of the fluorescent lamp balla st industry in the United States. Industry publications ( e.g. , manufacturer catalogs, trade journals ), government agencies, and trade organizations provided the bulk of the inform ation. Using this information, DOE assessed the overall state of the industry, ballast manufacturing and market shares, shipments by ballast type, general technical inform ation on ballasts, a nd industry trends.

2-19

### The discussion below summarizes the analytical approach and the comments DOE received in response to the framework document. m 

### A more detailed discussion on DOE’s approach can be found in the market and technology assessmen t (chapter 3 of the preliminary TSD).

2.4.1 Market Assessment

The market assessment focuses on developing a qualitative and quantitative characterization of the fluorescent lamp ballast industry. It characterizes the market structure based on publicly available informa tion and data supplied by manufacturers and other interested parties. The market as sessment also includes information about

manufacturers of fluorescent la mp ballasts, product classe s, ballast shipments, and existing regulatory and non-regulatory efficiency improvement initiatives.

2.4.1.1 Manufacturers of Fluorescent Lamp Ballasts

The majority of the domestic market share of fluorescent lamp ballasts is held by

four manufacturers: GE Consumer and Industr ial of General Electric, Inc. (hereafter, “GE”); OSRAM Sylvania of Siemens AG (hereafter “Osram Sylvania”); Advance Transformer of Philips Lighting (hereafter “Advance”); and Universal Lighting Technologies (hereafter “Universal”). In add ition to ballasts listed under this rulemaking, the lighting divisions of several of these co mpanies manufacture other products, such as fluorescent lamps, high intensity discharge lamps, and LED lighting.

All four companies are members of NEMA, a trade association that represents fluorescent lamp ballast manufacturers. NEMA provides an organizational framework for manufacturers of lighting products to work together on projects that affect their industry

and business.

Although the fluorescent lamp ballast mark et is predominantly supplied by large manufacturers, DOE intends to conduct a st udy of small businesses that manufacture fluorescent lamp ballasts for the NOPR stage of this rulemaking analysis. The Regulatory Flexibility Act (5 U.S.C. 601 et seq .) requires preparation of an initial regulatory flexibility analysis for every rule that by law must be proposed for public comment, unless the agency certifies that the rule, if promulgated, will not have a significant economic impact on a substantial number of small entities. A regulatory flexibility analysis examines the impact of the rule on small entities and considers alternative ways of reducing negative impacts. The Small Business Administration defines small business manufacturing enterprises for fluorescent la mp ballasts under the North American Industry Classification System product c ode 33511, Power, Distribution, & Specialty Transformer Manufacturing, which has a size standard of 750 employees or fewer. This includes the total number of employees in the parent company, not only those in the division that produces fluorescent lamp ballasts. DOE invites interested parties to provide

m

For more information on the framework document, visit http://www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_ballasts.html

.



### 2-20

### names and contact information for any sma ll businesses that manufacture fluorescent lamp ballasts and shoul d be consulted before DOE publishes a NOPR.

2.4.1.2 Product Classes

In general, when evaluating and estab lishing energy conservation standards, DOE divides covered product into cla sses by (1) the type of energy used; (2) the capacity of the product; or (3) any other performance-related feature that affects en ergy efficiency and justifies different standard levels, considering factors such as consumer utility. (42 U.S.C. 6295(q)) Different energy conservation standard s may apply to different product classes.

In the framework document, DOE considered amending the existing product classes for fluorescent lamp ballasts. DOE be lieved that the existing class divisions did not properly account for expected market ch anges due to existing standards or for a potentially expanded scope of coverage. DOE sought comments on prospective classsetting factors, specifically number of lamps, lamp length, lamp base, lamp wattage, lamp diameter, and input voltage. DOE received seve ral comments on its appr oach to defining product classes.

The Joint Comment argued that DOE shoul d use relative system efficiency as a performance metric instead of BEF (section 2.2.2). Because BEF depends on total lamp wattage operated by the ballast, the Joint Comment remarked that a large number of product classes would be require d to satisfy the proposed sc ope of coverage. The Joint Comment stated that by RSE as a performance metric instead of BEF, DOE could establish 30 product classes to cover a wide range of ballasts. Because RSE is BEF multiplied by total rated lamp power (a normalizing quantity), more comparisons are possible among ballasts that operate different lamp types. The Joint Comment proposed defining product classes for an RSE standard based on a combination of starting method, lamp length, lamp output, and lamp diam eter. (Joint Comment, No. 12 at pp. 6-9)

As discussed in section 2.2.2 and the active mode test procedure NOPR, for consistency with 42 U.S.C. 6295(g)(5), (g)(8), DOE has preliminarily determined that it cannot change the reported metric from BEF. For this reason, DOE is currently considering calculating BEF by measuring BE (using a resistor-based method) and then using transfer equations to correlate that m easurement to a reported BEF value. Though DOE did not consider product classes for fluores cent lamp ballasts in the context of an RSE standard, DOE did consider the four pr oduct class criteria recommended by the Joint Comment. For this preliminary analysis, with BEF as the efficiency metric, DOE considered 10 potential class-setting factors: (1) lamp length, (2) the maximum number of lamps operated, (3) ballast factor, (4) lumen package (or lamp output), (5) lamp diameter, (6) starting method, (7 ) market sector, (8) cold temperature operation, (9) input voltage, and (10) universal voltage. In general, when considering the above characteristics, DOE identified three main factors as affecting consumer utility: (1) thelumen package of the lamp-and-ballast system; (2) the physical constraints of the lampand-ballast system; and (3) the use of the ballast in an app lication for which other ballasts are not suitable. The potential class-setting factors DOE considered for the preliminary analysis are addressed below.

2-21

### The fluorescent ballasts considered for cove rage are designed to operate lamps with lengths of 4 or 8 feet. Because BEF is a f unction of ballast input power, and input power is highly dependent on the length of the lamp operated by the ballast, all else being equal, a ballast operating a shorter length lamp generally has a higher BEF than the same ballast operating a longer lamp. Furthermore, be cause consumers are often physically constrained by their building ceiling layout, systems operating 8-foot lamps and 4-foot lamps are not always substitutable for each ot her. Therefore, DOE believes that lamp length affects consumer utility. Given the impact that lamp length has on both BEF and utility, DOE is establishing separate product classes for ballasts that operate different lamp lengths.

DOE is considering covering ballasts th at operate different maximum numbers of lamps (from one to six lamps). Increasing the number of lamps a ballast operates increases the input power, thus resulting in a corresponding decrease in BEF. DOE believes that operating multiple lamps offers the consumer a distinct utility because this capacity affects the space required by fixtures (a four-lamp fixture requires more physical space than one-lamp fixture). Given this impact on both BEF and consumer utility, DOE has decided to establish sepa rate product classes based on th e maximum number of lamps a ballast operates.

The ballasts considered for coverage in this rulemaking are also available with a range of ballast factors. In applying DOE’s proposed amended active mode test procedure (as presented in the active m ode test procedure NOPR), DOE found that ballasts with high or low ba llast factors have lower BEFs than ballasts with a normal

ballast factor. n 

### Furthermore, ballast factor is typicall y used to adjust the lumen package ofa lamp-and-ballast system. Lumen package refers to the quantity of light that a lamp-andballast system provides to a consumer. DOE has observed that consumers tend to use systems with different lumen packages for different applications. For example, low BF ballasts (with smaller lumen packages) are commonly used in applications where less light is desired. In consideration of the ef fect that ballast factor has on both BEF and consumer utility, DOE has decided in this preliminary TSD to establish separate product classes for low, normal, and high ballast factor ballasts.

The tendency of consumers to use system s with different lumen packages for different applications was also observed for ballasts that opera te certain types of lamps. For example, high output systems may be in stalled in certain hi gh-ceiling or outdoor applications where large quantities of light are needed. Alternatively, standard output systems might be installed in lower-ceiling applications such as offices or hospitals, where, for example, the distance between the light source and the illuminated surface is not as large. Notable differences in the application of ballasts designed to operate SO lamps versus HO lamps indicate a difference in utility. This difference in utility is accompanied by a difference in BEF, often due to the differences in ballast input power.. Therefore, given the observed utility distinctions and notable efficiency differences, DOE

n DOE classifies a low BF as less than or equal to 0.78, a normal BF as greater than 0.78 but less than 1.1, and a high BF as greater than or equal to 1.1.



### 2-22

### has tentatively decided to esta blish separate product classes for ballasts that operate SO lamps and ballasts that operate HO lamps.

With regard to ballasts that operate lamps of differing diameters, NEMA

commented that DOE should not combine balla sts for T8 and T12 lamps in the same product class because T8 systems are inhere ntly more efficient than T12 systems. (NEMA, No. 11 at p. 3) While DOE agrees with NEMA that T8 systems are generally more efficient than T12 systems and that T8 ballasts generally have higher BEFs than T12 ballasts, DOE does not belie ve that this alone justif ies creating separate product classes for ballasts that operate T8 and T12 lamps. Consistentwith its approach in past rulemakings (74 FR 16920, 16937 (April 13, 2009 )), DOE maintains that T8 lamp-andballast systems are commonly used as substitutes for T12 lamp-and-ballast systems, suggesting that there is no unique utility associated with T12 systems. Manufacturer marketing literature and general guidance on lighting design and installation often promote T8 lamp-and-ballast systems as energy saving substitutes for T12 systems. Such substitute systems have the same lengths and bases, offer comparable lumen output, and can fit within the same fixtures. DOE recognizes that the diameter of the lamp may affect ballast BEF, but the utility provided to the end-user is comparable and/or equivalent. o 

### Therefore, DOE has tentatively decided to in clude ballasts that opera te T8 and T12 lamps in the same product class.

However, DOE has decided to establish a separate product cla ss for ballasts that operate T5 lamps. All else being equal, 4-foot T5 ballast s generally have lower input power (due to the lower wattage of the test lamp), and therefore higher BEF than T8 or T12 ballasts. These systems, though often us ed to replace T8 and T12 systems, are not viable substitutes in all applications. Because T5 lamps have similar total lumen output as T8 and T12 lamps over a significantly smaller surface area, T5 lamp-and-ballast systems are often marketed as too bright for use in direct lighting fixtures. To prevent eliminating lamps appropriate for direct lighting app lications, DOE has tentatively decided to establish separate produc t classes for ballasts th at operate T5 lamps.

DOE received several comments encouraging the consideration of more than just ballast efficiency when creating product cl asses. NEMA commented that DOE should consider the efficiency of the whole system instead of just the ballast efficiency. (NEMA, Public Meeting Transcript, No. 9 at pp. 57, 103-104, 124, 211-212; NEMA, No. 11 at p. 5) NEMA advised DOE to create product classe s and set standards so as not to prevent new technologies from entering the market that may be less efficient than existing

ballasts but more efficient when considered as part of a system (with a lamp and fixture). (NEMA, Public Meeting Transcript, No. 9 at pp. 104, 124) Furthermore, NEMA commented that DOE should consider the application in which ballasts are used because this can affect total energy savings. (NEMA, Public Meeting Transcript, No. 9 at p. 104;

o However, recognizing that different ballasts operate T12 and T8 lamps and in order to consider separately the impact of standards on consumers of both types of ballasts, DOE structured the analytical tools (including the LCC and NIA spreadsheets) so that eac h consumer subgroup could be analyzed separately. Thus, for example, the LCC results are reported separately for baseline ballasts that operate T8 and T12 lamps.



### 2-23

### NEMA, No. 11 at p. 5) For example, progra mmed start ballasts are commonly used with occupancy sensors and dimming ballasts are often used with control systems. Both of these combinations typically provide significant energy savings when compared to an installation of just a lamp and ballast. Programmed start and dimming ballasts, however, are generally less efficient than instant start ballasts. NEMA encouraged DOE to create a separate product class for progr ammed start ballasts. (NEMA, Public Meeting Transcript, No. 9 at pp. 41, 106) If extending coverage to dimming ballasts, the Joint Comment encouraged DOE to account for daylight ha rvesting when setting product classes because its benefits are not captured in the BEF metric. (Joint Comment, No. 12 at p. 4)

In response, DOE agrees with NEMA that programmed start ballasts warrant separate product classes from instant start and rapid start ballasts. As discussed in chapter 3 of the preliminary TSD, programmed start ballasts have inherently lower BEFs than instant start ballasts. However, programmed start ballasts are commonly used in conjunction with occupancy sensors because of their ability to maintain the lifetime of the fluorescent lamp. DOE’s research indicates that use of instant start ballasts with occupancy sensors can result in an 80 percent reduction in lamp lifetime. Because of the application in which they are used, programme d start ballasts offer the user a distinct utility. In consideration of its affect on both BEF and utility, DOE has tentatively decided to establish separate product classes for programmed start ballasts.

As DOE did not extend coverage to dimming ballasts in this preliminary analysis (section 2.3.4), DOE did not study how to incorp orate daylight harvesting into a ballast efficiency metric. Should d imming ballasts be included in future coverage, however, DOE notes the Joint Comment’s suggestion that energy savings due to daylight harvesting be included in any efficiency metric.

Regarding different market segments, Ac uity Brands Lighting commented that if

DOE were to cover residential ballasts, they should be addr essed separately because the

residential market and its consumers are very different from their commercial counterparts. (Acuity Brands Lighting, Pub lic Meeting Transcript, No. 9 at pp. 110-111) As discussed in section 2.3, DOE has initiall y included them in its expanded scope of coverage. As discussed in chapter 3, separa te minimum power factor and electromagnetic interference requirements exist for residential ballasts as compared to commercial ballasts. Residential ballasts have more stringent (or lower maximum allowable) electromagnetic interference requirements than commercial ballasts, they also have less stringent (or lower minimum allowable) pow er factor requirements. These differing requirements between commercia l and residential products re sult in differing BEFs. In addition to their effect on BEF, these tw o requirements offer the consumer a unique utility in that they serve distinct market sectors and applications. Therefore, DOE has tentatively decided to establish a separate pr oduct classes for ballasts that operate in the

residential sector and commercial sector.

Ballasts that are designed for use in co ld temperature outdoor signs have slightly different characteristics than those ballasts that operate in the commercial or residential sectors. First, sign ballasts are designed to operate in cold temperature environments – as

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### low as -20 °F. Second, sign ballasts are classifi ed by the total length (in feet) of lamps they can operate as well as the total number of lamps. To operate in cold temperature

environments and to be able to handle numer ous lamp combinations, sign ballasts contain more robust components compared to ballasts in the commercial sector that operate 8­ foot HO lamps and therefore sign ballasts are in herently less efficient. Regular 8-foot HO ballasts cannot be used as substitutes due to their inability to operate in cold temperature environments. For this reason, DOE believes cold temperature sign ballasts offer the consumer a distinct utility. Therefore, DO E has initially establis hed separate product classes for cold temperature sign ballasts.

In addition to the criteria discussed above, DOE also considered establishing product classes by input voltage of the ballast. Fluorescent lamp ballasts are available at a variety of input voltages, but the two most common input voltages are 120V and 277V. In examining test data between ballasts that operate only at 120V and ballasts that operate only at 277V, DOE found that there was not a significant difference in BEF. In addition, in its research, DOE found that the ballasts with the highest BEF allowed operation at both 120V and 277V. For this reason, DOE does not consider input voltage to be a factor in determining product classes.

Universal voltage ballasts can opera te at multiple input voltages ( e.g., 120V and 277V). To accommodate multiple voltages, th ese ballasts contain more components than dedicated voltage ballasts (balla sts that operate only one input voltage). Universal ballasts are growing in popularity because they can be used in multiple applications and serve as replacements for multiple ballasts. This allows distributors to stock fewer types of

ballasts and allows contractor s to keep fewer on hand for maintenance. Consolidation of products creates economies of scale for manu facturers, which can lead to reduced production costs. DOE compared test data between ballasts that operate only at one voltage and universal voltage ballasts operating at that volta ge and found that there was not a significant difference in BEF between the two. Therefore, DOE does not consider operating at multiple voltage s to be a factor in de termining product classes.

In summary, after considering all potential class-setting factors, DOE decided to define product classes based on lamp length, lumen package, maximum number of lamps operated, starting method, ballast factor, and market sector. These class-setting factors created 70 product classes, summarized in Table 2.4.1. DOE requests comments on these proposed product classes. A mo re detailed discussion of each class-setting factor that DOE considered can be found in chapter 3 of this preliminary TSD.

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### Table 2.4.1 Product Classes for Fluorescent Lamp Ballasts

Number of Lamps Ballast and Lamp Type Starting

Method Ballast

Factor One Two Three Four Five Six

High 1 2 3 4 5 6

Normal 7 8 9 10 11 12 IS and RS

Low 13 14 15 16 17 18

High 19 20 21 22 23 24

Normal 25 26 27 28 29 30 4-Foot MBP and 2-Foot U-Shaped

PS

Low 31 32 33 34 35 36

High 37 38 N/A N/A N/A N/A

Normal 39 40 N/A N/A N/A N/A 4-Foot T5 MiniBP SO All

Low 41 42 N/A N/A N/A N/A

4-Foot T5 MiniBP HO All All 43 44 45 46 N/A N/A

High 47 48 N/A N/A N/A N/A

Normal 49 50 N/A N/A N/A N/A 8-Foot SP Slimline All

Low 51 52 N/A N/A N/A N/A

IS and RS All 53 54 N/A N/A N/A N/A 8-Foot RDC HO PS All 55 56 N/A N/A N/A N/A

IS and RS All 57 58 59 60 N/A N/A Residential Ballast, 4­ Foot MBP, and 2-Foot U-Shaped PS All 61 62 63 64 N/A N/A

Sign Ballast All All 65 66 67 68 69 70



### 2.4.1.3 Ballast Shipments

To calculate the national energy savings fr om an energy conservation standard for fluorescent lamp ballasts, DOE presents shipment estimates disaggregated by product class. In chapter 3 of the preliminary TSD, DOE prepared historical shipments data based on public shipment records from the U.S. Census.

DOE used this data for three main purposes . First, the shipment data and market trend information contributed to the shipments analysis and base-case forecast for ballasts (chapter 9 of the preliminary TSD). Second, DOE used the data to select the representative product classes and representa tive units for analysis (chapter 5 of the preliminary TSD). Third, DOE used the data to develop the installed stock of ballasts for the national impact analysis (chapter 10 of the preliminary TSD).

The Census data indicates that 83,440 ballast s were shipped in the United States in

2005. p 

### The U.S. Census data is organized in to many subcategories, beginning with

p The total number of shipments is likely higher than indicated because every manufacturer does not report ballast shipments to the U.S. Census.



### 2-26

### magnetic versus electronic type ballasts. Under each technology type, the shipments are categorized by a variety of characteristics in cluding commercial versus residential sector, starting method, maximum number of lamps driven (1, 2, 3, or 4), lamp wattage, lamp diameter, and a few additional specific charac teristics. The shipment data does not include specific information for every permut ation of design characteristics, but it does indicate major trends in the market. Table 2.4.2 shows the market share of major ballast types in 2005.

Table 2.4.2 Ballast Market Share in 2005

Ballast Type 2005 Market Share (%)

T8 56

T12 18

CFL 8

T5 4

Residential 2 Linear Dimming 1 Cold Temperature Outdoor Sign 1

Other 10 A total of 83,440 ballasts were shipped in 2005.



### The most significant trend in fluorescent lamp ballast shipments to date has been a shift away from magnetic T12 ballasts to electronic T8 ballasts. Magnetic ballasts commanded a majority of shipments in 1990 but were overtaken by electronic ballasts in

2005. Part of this trend has been driven by energy conservation standards for T12

ballasts.

In addition, consumer demand is changing for some ballast subcategories. For example, 8-foot SP slimline T12 lamp-and-balla st systems are moving toward both 8-foot slimline SP T8 lamp-and-ballast systems and two 4-foot T8 MBP lamp-and-ballast systems. T5 ballasts have also seen an in crease in shipments, partly because F54T5HO ballasts are being used as substitutes for hi gh bay metal halide systems in industrial applications.

2.4.1.4 Regulatory and Non-Regulatory Programs

Several Federal and international regulatory programs affect the market for fluorescent lamp ballasts. U.S., Canadian, and European regulatory initiatives relevant to the ballasts covered by this rulemaking are currently in place. While the following summary is not exhaustive in describing all regulatory action related to fluorescent lamp ballasts, it indicates notable initiatives that characterize recent developments in the lighting market. Chapter 3 of the preliminary TSD discusses these programs and

initiatives in additional detail.

In the United States, EPCA established an energy conservation program for major household appliances. Subsequently, NAE CA 1988 expanded DOE’s authority to regulate the energy efficiency of several products, including fluorescent lamp ballasts. NAECA 1988 prescribed standards and requi red DOE to conduct two rulemakings on

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### fluorescent lamp ballasts. The first of thes e two rulemakings was completed in 2000 (the 2000 Ballast Rule); the second is this rule making. In addition, EPACT 2005 prescribed energy conservation standards for a dditional fluorescent lamp ballasts.

In Canada, the Natural Resources Canada (NRCan) Office of Energy Efficiency regulates the energy efficiency of fluores cent lamp ballasts. In 1992, Parliament passed the Energy Efficiency Act (S.C. 1992, c. 36), which concerns minimum performance levels for energy using products, effective in February 1995. Fluorescent lamp ballasts were included in the first set of energy efficiency regulations in 1994 and were amended in April 2003 to adopt the standards prom ulgated by DOE in the 2000 Ballast Rule. Finally, Amendment 9, published in the Canadian Gazette Part II on November 15, 2006 further amended Canadian energy efficiency standards.

In Europe, Directive 2005/32/EC of the Eu ropean Parliament and the Council of the European Union amended Council Directive 92/42/EEC and Dir ectives 96/57/EC and

2000/55/EC to establish a framework for se tting energy efficiency requirements for energy using products.

2.4.2 Technology Assessment

In the technology assessment, DOE identifie s technology options that appear to be a feasible means of improving product effici ency. This assessment provides the technical background and structure on which DOE bases its screening and engineering analyses. The following discussion provides an overvie w of the salient aspects of the technology assessment, including issues on which DOE seeks public comment. Chapter 3 of the preliminary TSD provides detailed descriptions of the basic construction and operation of fluorescent lamp ballasts, followed by a discu ssion of technology options to improve the ballast efficacy factor of a fluorescent lamp ballast.

In the framework document, DOE requested comments on a list of preliminary technology options that DOE intended to study further. These technology options included cathode cutout or hybrid ballasts, electronic ballasts, integrated circuits, higher grade components, and improved circuit de signs. NEMA provided comments on each of these technology options.

NEMA recommended that cathode cutout technology be evaluated as a technology option. (NEMA, No. 11 at p. 4; NE MA, Public Meeting Transcript, No. 9 at

p. 113) DOE agrees that cathode cut out technolog y can be used to increase the efficiency of a ballast by removing fila ment heating after the lamp has started. Therefore, DOE is considering this a method to improve a ballast’s BEF in th e technology assessment. After reviewing this technology option further, DOE has determined that this technology is a type of improved circuit design.

NEMA also recommended that DOE consider electronic ballasts as a technology option. NEMA stated that DOE should establish an electronic ballast efficiency level for all future rulemakings. (NEMA, No. 11 at p. 4; NEMA, Public Meeting Transcript, No. 9 at p. 113) DOE considers electronic ballasts to be a technology option and will consider

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### NEMA’s comment about establishing an electr onic ballast efficiency level for all ballasts when DOE proposes a standard in the fluorescent lamp ballast NOPR.

NEMA commented that the use of integr ated circuits by themselves do not directly influence ballast effica cy factor and thus should not be a factor in establishing energy conservation standards. (NEMA, No. 11 at p. 4; NEMA, Public Meeting Transcript, No. 9 at p. 113) DOE agrees that not all integrated circuits directly influence ballast efficacy factor. However, DOE believes that some do. For example, there is an integrated circuit that can increase ballast efficacy factor by replacing transistors in the direct current (DC) to alternating current (AC) inverter. q 

### Therefore, DOE is maintaining integrated circuits as a technology option in the technology assessment.

NEMA stated that higher grade compon ents should be considered a technology option because these components can reduce en ergy loss. NEMA also noted that DOE should evaluate the cost impact of su ch improvements in determining energy conservation standards for fluorescent lamp ballasts. (NEMA, No. 11 at p. 4; NEMA, Public Meeting Transcript, No. 9 at p. 113) DOE agrees that higher grade components like improved transformers, diodes, capacitors, and resistors should be considered a technology option as these components can redu ce energy loss. Once DOE determines if this technology option meets the screening criteria discussed in section 2.5, DOE will analyze the cost impact of the design option in the engineering analysis. More information on higher grade components can be found in chapter 3 of the preliminary

TSD.

In discussing improved circuit designs, DOE stated in the framework document that improving a ballast’s power factor could improve a ballast’s BEF. NEMA stated that raising the power factor is not an option for the majority of commercial ballasts and that increasing the power factor for residential ba llasts would increase ballast losses. (NEMA, No. 11 at p. 4; NEMA, Public Meeting Transc ript, No. 9 at pp. 113-114) DOE agrees that increasing a commercial or residential ballast’s power factor may not necessarily increase

the ballast’s BEF. r 

### Therefore DOE is not considering this a technology option. DOE continues to believe that changing the circuit design of a ballast ca n increase a ballast’s BEF and therefore maintains improved ci rcuit designs as a technology option.

In discussing improved circuit designs, NEMA stated that it was unaware of any emerging technology that promises to lowe r ballast losses while maintaining the same level of performance as today’s state-of-the-a rt ballast designs. (NEMA, Public Meeting Transcript, No. 9 at pp. 114, 118; NEMA, N o. 11 at p. 4) DOE appreciates NEMA’s comment on the existence of emerging tec hnologies. DOE will only consider technology options in the engineering analysis that satisfy the screening criteria ( i.e. , technological feasibility; practicability to manufacture, install, and service; adverse impacts on

qInternational Rectifier. International Rectifier Introduces Robus t Self-Oscillating Electronic Ballast Lighting Control IC . November 22, 2005. (Last accessed March 19, 2009.) <http://www.irf.com/whatsnew/nr051122.html>

r ANSI 82.77-2002 already requires commercial ballasts to have a power factor greater than or equal to

0.90 and residential ballasts to have a power factor greater than or equal to 0.50.



### 2-29

### equipment utility or equipment availability; and adverse impacts on health or safety).

DOE invites comments on all of the technol ogy options it considered for fluorescent lamp ballasts (listed in Table 2.4.3), including any omissions or revisions necessary to have a more comprehensive technology asse ssment. In the context of commenting on technology options, DOE also requests in formation on the feasibility, performance improvement, and cost of the technology options , as well as any recent developments in their technical maturity. More information concerning these technology options can be found in chapter 3 of the preliminary TSD.

Table 2.4.3 Fluorescent Lamp Ballast Technology Options

Technology Option Description

Magnetic Ballast Magnetic Ballast Design

Electronic Ballast Electronic Ballast Design

Lamp Diameter Vary the lamp diameter to improve system performance.

Improved Components Transformers Use grain-oriented silicon steel or amorphous steel to reduce core

losses.

Laminated sheets of amorphous steel to reduce core losses.

Litz Wire reduces winding losses.

Diodes Diodes with lower losses.

Capacitors Capacitors with a lower effective series resistance.

Transistors Transistors with low drain-to-source resistance.

Improved Circuit Design Cathode Cutout Remove filament heating after lamp has started.

Integrated Circuits Substitute discrete components with an integrated circuit.

Starting Method Use instant start instead of rapid start as a starting method for lamp operation.



### In the engineering analysis, DOE only cons iders technology options that meet the criteria in the screening analysis, discussed below. DOE was not able to identify working products or prototypes that have a dis tinguishably higher BEF than commercially available ballasts. Therefore, the most efficient ballasts in the engineering analysis are the most efficient tier of commercially available ballasts, and represent the “max-tech” level that DOE determined for this preliminary rulemaking. However, DOE presents additional research in appendix 5D of the preliminary TSD to explore whether technologies used in products similar to ballasts can be used to improve the efficiency of ballasts currently on the market. DOE requests comments on the feasibility, performance improvement, and cost of these technology options.

2.5 SCREENING ANALYSIS

After DOE identified the technologies that might improve the energy efficiency of fluorescent lamp ballasts, DOE conducted the screening analysis. The purpose of the screening analysis is to determine which opti ons to consider further and which options to screen out. DOE consults with industry, techni cal experts, and other interested parties in

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### developing a list of design options. DOE then applies the following set of screening criteria to determine which design options ar e unsuitable for further consideration in the rulemaking (10 CFR Part 430, subpart C, appendix A at 4(a)(4) and 5(b)):

• Technological Feasibility: DOE will consider technologies incorporated in commercial equipment or in working protot ypes to be technologically feasible.

• Practicability to Manufactu re, Install, and Service: If mass production of a technology in commercial equipment and re liable installation a nd servicing of the technology could be achieved on the scale necessary to serve the relevant market at the time of the effective date of the standard, then DOE will consider that technology practicable to manufacture, install, and service.

• Adverse Impacts on Equipment Utility or Equipment Availability: If DOE determines a technology to have significant adverse impact on the utility of the equipment to significant subgroups of consumers, or to result in the unavailability of any covered equipment type with pe rformance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as equipment generally available in the United States at the time, it will not further consider this technology.

• Adverse Impacts on Health or Safety: If DOE determines that a technology will have significant adverse impacts on health or safety, it will not further consider this technology.

NEMA commented that DOE should not consid er technology options with significant adverse impacts on health and safety. (NEM A, No. 11 at p. 5; NEMA, Public Meeting Transcript, No. 9 at p. 117) DOE agrees and maintains this as a screening criterion. For a complete discussion of the screening analysis, refer to chapter 4 of the preliminary TSD. The following section focuses on one t echnology option that was screened out due to its failure to comply with one or more of the screening criteria.

2.5.1 Technology Options Screened Out

In considering technologies in the screen ing analysis, NEMA stated that the only technologies that have been shown to be pr actical to manufacture, to have no adverse impacts on reliability, and to have no impact on the marketplace are used in commercially available products (which may not include all products that appear in manufacturer catalogs). Therefore, NEMA argued that only technologies used in currently commercially available products should be considered when setting standards for ballasts. NEMA noted that examining the ballasts listed in the NEMA Premium program could be one method of determining which products are actually used in the marketplace and therefore commercially available. (NEMA, Public Meeting Transcript, No. 9 at pp. 115-116; NEMA, No. 11 at p. 5) Acuity Brands Lighting agreed with NEMA, stating that data on reliability is ava ilable only for those products that have been commercially available. (Acuity Brands Lightin g, Public Meeting Transcript, No. 9 at pp. 118-119) ASAP disagreed, arguing that DOE sh ould not screen out a technology based on whether that technology has gained mark et acceptance. (ASAP, Public Meeting

2-31

### Transcript, No. 9 at p. 119) NYSERDA also not ed that there may be some emerging technologies that should not be screened out as the lighting industry moves very fast and these standards are 7 years from applicati on. (NYSERDA, Public Meeting Transcript, No. 9 at pp. 117-118)

DOE agrees that technologies should not be screened out based on whether they are used in a commercially available product. The screening criteria define technological feasibility to include technology incorporated into working prototypes as well as commercially available products. It is possible that a technology that is not commercially available or simply has not gained noticeable market share could increase the efficiency of a ballast and meet all of the screening criteria. Therefore, DOE will not screen out a technology based on its presence in commercially available products.

After considering all of the technology options identified in the technology assessment, DOE determined that improving ba llast efficiency by employing an inductor composed of laminated sheets of amorphous st eel did not meet the screening criteria. DOE screened out this technology option be cause this method increases the size and weight of the ballast. Therefore, DOE be lieves this option is not practicable to manufacture, install, and service. Employin g this technology option may cause problems with installing and servicing ballasts because the ballasts could be too large to fit in a fixture. DOE also believes this technology op tion fails the screening criterion of adverse impacts on consumer utility. Specifically, increasing the size and weight of the ballast may limit the places a consumer could use the ballast in a building. DOE is unaware of available data on whether this technology op tion is technologically feasible or has adverse impacts on health or safety be cause it is not commercially available.

In summary, after examining all of th e options presented in the technology assessment, DOE screened out only one option (laminated sheets of amorphous steel) because it did not meet all of the screening criteria. All remaining technology options met the screening criteria, and therefore will be considered in the engineering analysis.

2.6 ENGINEERING ANALYSIS

DOE performed an engineering analysis to establish the relationship between the manufacturer production cost (MPC) and th e energy efficiency of ballasts. Therelationship between the MPC and energy efficiency serves as the basis of the costbenefit calculations for individual consumers, manufacturers, and the Nation. This section provides an overview of the engineer ing analysis, discusses the representative product classes, establishes baseline unit specifications for those product classes, discusses incremental efficiency levels, discusses the analysis and results for the representative product classes, and estab lishes a scaling methodology for those product classes DOE did not analyze.

The primary inputs to the engineering analysis are the design options from the screening analysis (see chapter 4 of the pr eliminary TSD). Additional inputs include cost and efficiency data derived from the physical teardowns and test data from independent

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### labs. The primary output of the engineering anal ysis is a set of cost-efficiency curves. In a subsequent life-cycle cost analysis (chapter 8 of the preliminary TSD), DOE used the cost-efficiency curves to de termine customer prices for each product by applying the appropriate distributi on channel markups.

2.6.1 Preliminary Engineering Analysis Approach

DOE typically structures its engineering analysis around one of three methodologies: (1) the design-option approac h, which calculates the incremental cost of adding specific design options to the baselin e model; (2) the efficiency-level approach, which calculates the relative costs of achieving increases in energy efficiency levels, without regard to the particular design options used to achieve such increases; or (3) the reverse engineering cost-assessment a pproach, which involves a “bottom-up” manufacturing cost assessment based on a detailed bill of materials derived from teardowns of products being analyzed.

At the framework document public meetin g, DOE proposed using an efficiency level approach that included basing its determination of th e end-user retail prices for

ballasts off of marked-down manufact urer product price schedule lists. s 

### DOE received several comments on this methodology. At the pu blic meeting, manufacturers stated that the proposed approach would yield inaccurate and misleading end-user prices for ballasts

as each manufacturer has a different method of deciding how to price products. (Osram Sylvania, Public Meeting Transcript, No. 9 at p. 138; GE Lighting, Public Meeting Transcript, No. 9 at pp. 140, 144; Acuity Bra nds Lighting, Public Meeting Transcript, No. 9 at pp. 140-141) One manufacturer stated that this method may work for lamps but not ballasts because lamps are primarily maintenance compone nts and purchased in large volumes, whereas ballasts are mostly new construction components. (Acuity Brands Lighting, Public Meeting Transcript, No. 9 at pp. 140-141) The Joint Comment argued that DOE should instead give greater weight to reverse engineering cost estimates as this methodology has a better track record of estima ting actual costs. (Joint Comment, No. 12 at p. 13)

In evaluating the most appropriate methodology for the engineering analysis, DOE determined that an efficiency level approach paired with reverse engineering cost estimates would yield the most realistic data. In this way, DOE would not rely on product lists or minimum cost data supplied by manufacturers. Because DOE was unable to reverse engineer some ballasts analyzed in the rulemaking due to potting (a tar-like fill

material which inhibits the visual obs ervation of the components), DOE conducted teardowns for only unpotted balla sts and ballasts removed fro m a manufacturing facility before the potting procedure.

s U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy. Energy Conservation Program for Consumer Products: Framework Document: Energy Conservation Standards for Consumer Products: Fluorescent Lamp Ballasts. January 2008. Washington, DC.

< http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/ballast_framework_011408.p

df

>



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### DOE devised a scaling technique to estimate manufacturer product costs for additional ballasts types. Using online ballast supplier pricing, DOE developed ratios relating online prices to teardown-sourced MPCs. These ratios allowed DOE to estimate MPCs for additional ballasts by scaling from their online price. For more information on DOE’s pricing analysis, see section 2.6.6 or chapter 5 of the preliminary TSD.

The following discussion summarizes the general steps of the engineering analysis:

Representative product classes : DOE first reviews covered ballasts and the associated product classes. When a produc t has multiple product cl asses, DOE selects certain classes as “representative” and concentrates its analytical effort on these. DOE selects representative product classes primarily because of their high market volumes. For those product classes that are not analyzed, DOE extrapolates the candidate standard levels from representative product cl asses to other product classes.

Baseline ballasts : For each representative product cl ass, DOE establishes baseline

ballasts. The baseline serves as a referenc e point for each product class, against which DOE measures changes resulting from potential amended energy conservation standards. To determine energy savings and changes in price, DOE compares each energy efficiency level with the baseline unit. Generally, a baseline ballast is a commercially available ballast that just meets existing Federal ener gy conservation standa rds and provides basic consumer utility. If no standard exists for that specific ballast type, the baseline ballast represents the typical ballast sold within a product class with the lo west tested ballast efficacy factor. NEMA recommended that only documented non-commercial information from accredited testing laboratories be used for the engineering analysis because commercially available data overstates balla st efficiency. (NEMA, No. 11 at p. 6; Advance, Public Meeting Transcript, No. 9 at pp. 125-126) DOE agrees with NEMA and

therefore has not relied on information in product catalogs when determining the BEF for

ballasts.

To develop the engineering analysis, DOE purchased a range of commercially available ballasts and tested them at two accredited testing laboratories for ballast efficacy factor and ballast efficiency. All test results are presented in appendix 5C of the preliminary TSD. For the baseline ballast, DOE selected specific characteristics such as starting method, ballast factor, and input vo ltage to characterize the most common

ballast. DOE also selected mu ltiple baseline ballasts in some product classes to ensure

consideration of different ba llast types and their associ ated consumer economics.

Candidate lamp-and-ballast designs: DOE selects commercially available ballasts with a higher BEF as replacements for each baseline ballast in th e representative product classes by considering the design options identified in the tec hnology assessment and screening analysis (preliminary TSD chapter 4). DOE is able to explicitly identify many of the distinguishing design options associated with each ballast. However, at some levels, these design options are considered to be implicitly used in the ballast to achieve a

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### higher BEF. t 

### In identifying more efficient substitutes, DOE identifies ballasts using a database of commercially available ballasts. DOE then tests these ballasts to establish BEF and ballast efficiency. All test re sults are presented in appendix 5C.

Because fluorescent lamp ballasts are desi gned to operate fluorescent lamps, DOE pairs each ballast with the most common fluor escent lamp in its re spective product class. DOE develops the engineering analysis based on two substitution cases. In the first case, the consumer is not allowed to change the sp acing of their fixtures and therefore replaces

one baseline ballast with a more efficacious ballast. In this case, light output is maintained to within 10 percent of the baseline system lumen output. u 

### In the second case, the consumer is allowed to change the spacing of the fixture. Therefore, light output is normalized and the consumer either installs more or fewer ballasts to maintain light

output.

Candidate standard levels . After identifying the more efficient substitutes for each baseline ballast, DOE develops candidate standard levels (CSLs). DOE based its analysis on two factors: (1) the design options associated with the specific ballasts studied, and (2) the maximum technologically feasible efficiency level. Advance suggested that DOE should consider onl y commercially available systems when developing candidate standard levels due to time constraints. (Advance, Public Meeting Transcript, No. 9 at pp. 131-132) As stated in the screening analysis, DOE believes that all technologies that pass the screening cr iteria are used in commercially available ballasts or working prototypes and therefor e based its engineering analysis on those technologies.

DOE is required by section 325(o) of EPCA to determine the maximum improvement in BEF that is technologically feasible (“max-tech”) for fluorescent lamp ballasts. (42 U.S.C. 6295(o)). To determine th is level, DOE conducted a survey of the fluorescent lamp ballast market and the research fields that support the market. DOE believes that within a given product class, no working products or prototypes exist that have a distinguishably higher BEF than commercially available ballasts. Therefore, the highest CSL presented, which represents the most efficient commercially available ballasts, is the max-tech level that DOE determined for this preliminary rulemaking. However, DOE presents additional research in appendix 5D of the preliminary TSD to explore whether technologies used in products similar to ballasts can be used to improve the efficiency of ballasts currently on th e market. DOE requests comments on this analysis.

NEMA argued that DOE should not es tablish a CSL that would require a proprietary technology, as this would give one company an advantage over another. (NEMA, No. 11 at p. 6; NEMA, Public Meetin g Transcript, No. 9 at p. 130) DOE agrees

t Ballast catalogs usually designate whether the ballast is magnetic or electronic and what diameter lamp it is designed to operate. The catalogs do not, however, specify the quality of components used or all aspects of the circuit design.

u In some instances ( e.g. , when switching from T12 to T8 ballasts), light output goes slightly beyond these limits. These instances are discussed in more depth in chapter 5 of the preliminary TSD.



### 2-35

### and considers proprietary designs in its en gineering analysis only if there are other technology pathways to meet th at efficiency level. DOE does not regard a standard level that can be met by only one proprietary de sign to be economically justified. DOE believes, however, that no CSL in this ru lemaking requires the use of a proprietary technology. DOE requests comments on its c onclusions that no commercially available products use proprietary designs and that CSLs that require the use of proprietary designs are not economically justified.

Price analysis . After identifying both the baseline ballast and the more efficient substitutes at each CSL, DOE generates a bill of materials (BOM) by disassembling multiple manufacturers’ ballasts that span a range of efficiency levels for each of the representative product classes. The BOMs desc ribe the product in detail, including all manufacturing steps required to make and/or assemble each part. DOE then develops a

cost model that converted the BOMs and effi ciency levels into MPCs. By applying derived manufacturer markups to the MPCs , DOE calculated the manufacturer selling prices and constructed industry cost-efficiency curves.

DOE was not able to generate a BOM for all ballasts in the engineering analysis. In this case, DOE evaluated retail prices and estimated a MSP for each ballast. For fluorescent lamps, DOE referenced the retail price in the 2009 Lamps Rule.

2.6.2 Representative Product Classes

As discussed in the market and tec hnology assessment (preliminary TSD chapter 3), DOE revised the existing product classes fo r ballasts to include 70 product classes, as shown in Table 2.6.1. Of these 70 product classes, DOE chose to analyze 10 as representative product classes. DOE chose to analyze at least one representative product class for each lamp type analyzed. For the most prevalent ballast type ( e.g. , for ballasts that operate two 4-foot MB P and 2-foot U-shaped lamps), DOE choose to analyze multiple representative product classes. DOE based the repr esentative product classes on the most common lamp-and-ba llast configurations. Alt hough DOE did not create a separate engineering analysis for every pr oduct class, DOE established standards for these product classes based on the representa tive product classes directly analyzed. For instance, DOE extended its proposal for ballast s that operate two 4-foot T5 MiniBP HO lamps by observing the relationship between test data for ballasts that operate one, three, and four lamps and determinin g an appropriate scaling factor. Section 2.6.5 and chapter 5 of the preliminary TSD provide more inform ation on extending standards to the product classes DOE did not analyze.

2-36

### Table 2.6.1 Representative and Scaled Product Classes for Fluorescent Lamp

Ballasts

Number of Lamps Ballast and Lamp Type Starting

Method Ballast

Factor One Two Three Four Five Six

High Scaled Scaled Scaled Scaled Scaled Scaled

Normal Scaled Representative

Product Class Scaled Representative

Product Class Scaled Scaled IS and

RS

Low Scaled Scaled Scaled Scaled Scaled Scaled

High Scaled Scaled Scaled Scaled Scaled Scaled

Normal Scaled Representative

Product Class Scaled Representative

Product Class Scaled Scaled 4-Foot MBP and 2­

Foot U-shaped

PS

Low Scaled Scaled Scaled Scaled Scaled Scaled

High Scaled Scaled N/A N/A N/A N/A

Normal Scaled Representative

Product Class N/A N/A N/A N/A 4-Foot T5 MiniBP

SO All

Low Scaled Scaled N/A N/A N/A N/A

4-Foot T5 MiniBP

HO All All Scaled Representative

Product Class Scaled Scaled N/A N/A

High Scaled Scaled N/A N/A N/A N/A

Normal Scaled Representative

Product Class N/A N/A N/A N/A 8-Foot SP Slimline All

Low Scaled Scaled N/A N/A N/A N/A

IS and

RS All Scaled Representative

Product Class N/A N/A N/A N/A 8-Foot RDC HO

PS All Scaled Scaled N/A N/A N/A N/A

IS and

RS All Scaled Representative

Product Class Scaled Scaled N/A N/A Residential Ballast, 4-Foot MBP, and 2­

Foot U-Shaped PS All Scaled Scal ed Scaled Scaled N/A N/A

Sign Ballasts All All Scaled Scaled Scaled Representative

Product Class Scaled Scaled



### 2.6.3 Baseline Ballasts and Candidate Standard Levels Analyzed

For each representative product class, DOE selected a baseline model as a reference point against which to measure changes resulting from energy conservation standards. Typically, a baseline ballast is a unit that just meets current Federal energy conservation standards and provides basic consumer utility. To determine energy savings and changes in price, DOE compared each higher energy efficiency level with the

baseline unit.

2-37

### DOE considered the ballast’s characteris tics in choosing the most appropriate baseline ballast for each product class (the baseline ballast exhibits the characteristics of the least efficient and most common ballast.) These characteristics include the ballast’s starting method ( e.g. , rapid start (RS), instant start (IS) , or programmed start (PS)), input voltage (277V vs. 120V), type (electronic vs. magnetic), power factor (PF), total harmonic distortion, ballast fact or (BF), input power, BEF, and whether the ballast can operate at multiple voltages v 

### (universal voltage) or only one (single voltage). Finally, DOE considered whether the ballast just meets existing Federal minimum energy

conservation standards.

After choosing a baseline ballast, DOE surveyed and tested many of the manufacturers’ product offerings for BEF and ballast efficiency to identify the efficiency levels corresponding to the highest number of models. DOE identified the most prevalent BEF values in the range of available pr oducts and established CSLs based on those products. Because the baseline ba llasts have different BEF va lues and represent various design options, CSLs affect only one of the two baseline lamps in some product classes. For example, CSL1 may require a more effi cient T12 ballast than the baseline T12 ballast, but not require a ballast more efficient than the T8 baseline. However, the full range of CSLs ultimately specifies requirement s that are above the BEF values of all the baseline ballasts sold, and therefore affect all baseline ballasts.

The following discussion outlines DOE’s choice of baseline ballasts and CSLs for the two-lamp normal BF IS a nd RS 4-foot MBP product cla ss. For this product class, DOE chose to analyze two baseline ballasts. Ce nsus data indicates that 2001 shipments of 4-foot and 2-foot U-shaped MBP T12 ballast s represented 14 percent of all shipments, while 4-foot and 2-foot U-shaped MBP T8 ballasts represente d 86 percent of all shipments. w 

### Therefore, DOE analyzed both a T12 a nd T8 ballast as a baseline ballast. Because F34T12 lamps are the most common T12 lamps, DOE chose to analyze only those ballasts that operate F34T12 lamps for th is rulemaking. DOE also chose to analyze only those ballasts that operate F32T8 lamps because this lamp is the most common 4­ foot MBP T8 lamp.

The Federal minimum energy conservation standards for ballasts that operate two F34T12 lamps became effectiv e for ballasts manufactured on or after July 1, 2009. (10 CFR Part 430.32 (m)(5)) This energy conserva tion standard effectively allowed only electronic F34T12 ballasts. Therefore, DOE chose an electronic ballast as the F34T12 baseline ballast. To determine the BEF of the baseline ballast, DOE tested multiple ballasts operating a reference F34T12 lamp. Table 2.6.2 shows the BEF, BF, and input power of the most common T12 ballast that just meets the minimum energy conservation standard of 1.35. The majority of T12 electr onic ballasts in product catalogs are RS, are single voltage, have a high PF (around 0.98), and have a THD less than 20 percent. The ballast that just meets the energy conservation standard also exhibits these characteristics.

v Universal voltage ballasts can operate at 120V or 277V.

w More recent Census data for ballasts is available. However, shipments of T12 ballasts have not been publicly released after 2001.



### 2-38

### DOE also chose a ballast that has an input voltage of 277V ballast because the majority of ballasts operate in comme rcial buildings at 277V.

There is no Federal minimum energy conservation standard for ballasts that operate F32T8 lamps. Therefore, DOE chose the most common, least efficient ballast on the market as the baseline ballast for this lamp type. DOE tested a range of F32T8 ballasts from multiple ba llast manufacturers and found that the least efficient but most

common ballast exhibited the characteristics shown in Table 2.6.2. The vast majority of T8 ballasts are IS, are electronic, and have a high PF (around 0.98). Furthermore, the least efficient T8 ballasts are single voltage and have a THD less than 20 percent. Finally, DOE chose a ballast that has an input voltage of 277V, because the majority of ballasts operate in commercial buildings at 277V.

Table 2.6.2 Baseline Ballasts for Two-Lamp Four-Foot and Tw o-Foot U-Shaped

MBP IS & RS Normal BF Product Class

For operation

of Starting Method, Input Voltage, Ballast Type, PF, THD Ballast Efficiency BF Input

Power BEF Federal Energy

Conservation

Standard

Two

F34T12

lamps RS, 277V, Electronic, Single Voltage 0.98 PF,

<20% THD 80.1%* 0.86 63.5 1.359 1.35

Two

F32T8 lamps IS, 277V, Electronic, Single Voltage, 0.98

PF, <20% THD 85.4%* 0.88 60.4 1.450 N/A

* DOE was unable to test the ballast efficiency of these particular ballasts. DOE estimates are based on a measured BEF value and the established relationship between BEF and ballast efficiency determined by the active mode test procedure. For the IS and RS representative product class, the BEF of a ballast is related to ballast efficiency in the following manner:

BEF=1.697*BE.



### As discussed in the screening analysis (chapter 4 of the preliminary TSD), DOE used design options that achieve a higher BEF than the baseline ballast. Because the

baseline ballast is an electr onic ballast, improvements require d the use of the following design options: lamp diameter, improved components, and improved circuit design. The following discussion outlines the candidate standard levels associated with the two-lamp

normal BF IS and RS 4- foot MBP product class.

CSL1 . BEF: 1.450; Efficiency: 85.4 percent

This level affects the F34T12 baseline balla st but not the F32T8 baseline ballast. It requires the use of improved lamp diameter s (T8 instead of T12). Therefore, no T12

ballasts meet this level. In addition, ballasts must use improve d circuit designs (a starting method that is IS rather than RS).

CSL2 . BEF: 1.535; Efficiency: 90.5 percent

2-39

### This level affects both baseline ballasts. Ho wever, no T12 ballast that is commercially available can meet this level. Ballasts at this level use better components and more efficient circuit designs than those ballasts that just meet CSL1.

CSL3 . BEF: 1.561; Efficiency: 92.0 percent

This level again affects both baseline ballasts and represents the maximum technologically feasible level. This level re presents a modest improvement in efficiency over CSL2. Ballasts at this level again use s lightly better component s and circuit designs than those ballasts that just meet CSL2.

Chapter 5 of the preliminary TSD provides a more detailed discussion on how DOE selected baselines and CSLs for all representative product class, which technologies they represent, and which design option lamps DOE used at these CSLs for each representative unit. Table 2.6.3 outlines the CSLs for all representativ e product classes:

Table 2.6.3 Summary of Proposed Candidate Standard Levels for Representative Fluorescent Lamp Ballast Product Classes

Representative Product Class CSL1 CSL2 CSL3

BEF BEF BEF Two-Lamp Normal BF 4-Foot MBP IS & RS 1.450 1.535 1.561 Two-Lamp Normal BF 4-Foot MBP PS 1.518 N/A N/A Four-Lamp Normal BF 4-Foot MBP IS & RS 0.781 N/A N/A Four-Lamp Normal BF 4-Foot MBP PS 0.755 N/A N/A Two-Lamp Normal BF 4-Foot T5 MiniBP SO 1.441 1.482 N/A Two-Lamp 4-foot T5 MiniBP HO 0.791 0.837 N/A Two-Lamp Normal BF 8-Foot SP Slimline 0.807 N/A N/A Two-Lamp Normal BF 8-Foot RDC HO IS & RS 0.500 0.549 N/A Two-Lamp Low BF 4-Foot MBP IS & RS Residential 1.457 1.492 N/A Four-Lamp Sign Ballasts 0.238 N/A N/A



### 2.6.4 Results

As discussed above, DOE ev aluated multiple baseline ballasts for the relevant product classes to provide a comprehensive understanding of the consumer economics. DOE based its engineering analysis on two s ubstitution cases. In the first case, the consumer is not allowed to change the spacin g of their fixtures and therefore replaces one baseline ballast with a more efficacious ballast. In this case, light output is maintained to within 10 percent of the baseline system lume n output. Percentage change in mean lumen output is show in each table below. In the se cond case, the consumer is allowed to change the spacing of the fixture. To show how energy savings would change due to this change, DOE shows the normalized system input pow er. The following formula is used to normalize the system input power of the standards-case system to the mean lumen output of the baseline system:

2-40

### MLO Baseline 

### NormalizedInputPower = ∗ InputPower S tan dardsCase S tan dardsCase 

### MLO S tan dardsCase 

### Equation 2.6.1

NormalizedInputPower S 

### = Input power of the standards-case system that

tan dardsCase 

### matches the light output of the baseline system

MLO Baseline 

### = Mean lumen output of the baseline system

MLO S 

### = Mean lumen output of the standards-case system

tan dardsCase 

### InputPower S tan 

### = Input power of the standards-case system dardsCase



### The results tables also present the retail price of the replacement lamps ( e.g. , if it is a two-lamp system the retail price is th e price of two lamps). Table 2.6.4 presents the engineering characteristics of the ballast replacement options for the baseline F32T8 system in the two-lamp 4-foot MBP normal BF RS and IS product class. Because the BFs of the standards-case systems are slightly lower than the baseline system, the normalized input power is slightly higher than the meas ured input power. If a direct substitution is made, mean lumen output does not change by more than 2 percent relative to the mean lumen output of the baseline system.

For all F32T8 ballasts, DO E generated an MSP from teardowns. As shown in Table 2.6.5, physical teardown information sugge sts that the F32T8 ballast at CSL3 is less costly than the less efficient CSL2 ballast, but both CSL2 and CSL3 are more costly

than CSL1.

2-41Table 2.6.4 Two-Lamp Four-Foot MBP RS andIS Product Class with F32T8 Baseline

Candidate Standard Level For Operation of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor Input Power BEF Ballast Efficiency System Initial Light Output System Mean Light Output Percentage Change Mean Lumen Output Ballast Manufacturer Selling Price Lamp Retail Price Normalized Input PowerVWlmlm%$$WBaseline/CSL1Two F32T8LampsElectronicIS277Single>0.98<20%0.8860.41.45085.4%*5,2504,988N/A7.435.6560.4CSL2Two F32T8LampsElectronicIS277Universal>0.98<10%0.8656.01.53590.5%5,1614,903-1.7%10.015.6557.0CSL3Two F32T8LampsElectronicIS277Universal>0.97<10%0.8756.41.56192.0%5,2424,980-0.2%8.935.6556.5*DOE was unable to test the efficiency of these particular ballasts. DOE estimates are based on the relationship between BEF and ballast efficiency determined by theactive mode test procedure. For the IS and RS representative product class, the BEF of a ballast is related to ballast efficiency in the following manner: BEF=1.697*BE.Table 2.6.5 presents the engineering characteristics of the ballastreplacement options for the baseline F34T12 system in the two-lamp4-foot MBP normal BF RS and ISproduct class. If a direct substitution is made, mean lumen output does not change by more than3percent from that of the baseline system. For the F34T12 baselineballast, DOE used the online price scaling technique to develop aprice. DOE found that the MSP for the F34T12 ballast was higherthan for any of the F32T8 ballasts. The F34T12 electronic ballast issold at lower volumes than the electronicF32T8 ballasts represented by CSL1, CSL2, and CSL3. DOE attributes the smaller shipmentvolume to its high cost relative to efficiency.2-42Table 2.6.5 Two-Lamp Four-Foot MBP RS andIS Product Class with F34T12 Baseline

Candidate Standard Level For Operation of Ballast Type Starting Method Input Voltage Universal or Single Voltage Power Factor THD Ballast Factor Input Power BEF Ballast Efficiency System Initial Light Output System Mean Light Output Percentage Change Mean Lumen Output Ballast Manufacturer Selling Price Lamp Retail Price Normalized Input PowerVWlmlm%$$WBaseline2 F34T12LampsElectronicRS277Single>0.98<20%0.8663.51.35980.1%*5,4124,872N/A10.2611.6563.5CSL12 F32T8LampsElectronicIS277Single>0.98<20%0.8860.41.45085.4%*5,2504,9882.4%7.435.6559.0CSL22 F32T8LampsElectronicIS277Universal>0.98<10%0.8656.01.53590.5%5,1614,9030.6%10.015.6555.7CSL32 F32T8LampsElectronicIS277Universal>0.97<10%0.8756.41.56192.0%5,2424,9802.2%8.935.6555.2*DOE was unable to test the efficiency of these particular ballasts. DOE estimates are based on the relationship between BEF and ballast efficiency determined by theactive mode test procedure. For the IS and RS representative product class, the BEF of a ballast is related to ballast efficiency in the following manner:BEF=1.697*BE.2-43

### Chapter 5 of the preliminary TSD presents results for all other product classes.

2.6.5 Scaling Between Product Classes

As discussed earlier, DOE reduced the analytic al burden associated with fluorescent lamp ballasts by identifying and studying select representative units for analysis. DOE then extrapolated the findings from those representative ballasts to ot her covered product classes that were not analyzed.

At the public meeting, DOE discussed sca ling to other product cl asses and requested

comments. NEMA advised DOE to be careful wh en extrapolating efficiency metrics from one product type to another, particularly with respect to BEF as BEF is lamp dependent. (NEMA, No. 11 at pp. 5-6) Therefore, DOE is establishing a test procedure that requires manufacturers to use one type of load if opera ting a specific type of lamp ( e.g. , a 4-foot MBP T8 lamp). For more information on that test procedure, see section 2.2.2. DOE also recognizes that BEF depends on a variety of other factors, like the number of lamps a ballast operates. Theref ore, in scaling product classes, DOE will examine test data to develop scaling relationships for all factors that affect the BEF of the ballast, including dependence on the lamp. Chapter 5 of the preliminary TSD presents detail on the scaling relationships between product classes and DOE’s methodology.

DOE invites comments on the use of this scalin g relationship to extrapolate findings from the representative product classes to other product classes.

2.6.6 Price Analysis

Developing the manufacturer selling price for different fluorescent lamp ballasts involved two main inputs, a teardown analysis to de velop the manufacturer pr oduct costs and a markup analysis to arrive at the MSP. Figure 2.6.1 shows the general breakdow n of costs and profit associated with manufacturing and selling a product. The full cost of production is broken down into two main costs, the full production costor manufacturing production cost, and the nonproduction cost. The non-production cost is equal to the manufacturer markup minus profits.

DOE totaled the cost of material s, labor, and direct overhead used to manufacture a product in

order to calculate the MPC. x

x When viewed from the company-wide perspective, the su m of all material, labor, and overhead costs equals the company’s sales cost, also referred to as the cost of goods sold (COGS).



### 2-44

### Figure 2.6.1 Full Production Costs

The MPC is composed of direct labor, direct material, and ove rhead costs. Direct material costs represent the direct purchase price of components (resistors, connecting wires, etc.). To estimate direct material and labor costs for early 2009 (the time at which the ballast teardowns occurred), DOE obtained customized teardown analyses for certain fluorescent lamp ballasts. DOE estimated the manufacturer overhead from a representative electronic fabrication company’s U.S. Securities and Exchange Commission (SEC) 10-k’s aggregated confidential manufacturer selling prices.

NEMA expressed concern that a change in commodity materials prices would affect payback calculations for ballasts. (NEMA, No. 11 at p. 6; Advance, Public Meeting Transcript, No. 9 at p. 133) DOE understands that prices for ballast components have fl uctuated in the past. To establish the price for an average ballast, DOE determined the January 2009 commodity price index and a 5-year average commodity pric e index (spanning 2004 through 2008) for each component from the Bureau of Labor St atistics Producer Price Indices (PPIs). y 

### DOE then evaluated how the January 2009 material costs for ballasts varied from the 5-year average price for all ballasts. Although there was a large differe nce in cost for some components, overall, the difference in ballast price between the 2009 index and the 5-year average was negligible. Therefore, DOE believes that the prices in the engineering analysis as estimated in 2009 reflect a long-term average for commodity prices. For more information on this analysis, see chapter 5 and appendix 5A of the preliminary TSD. DOE requests comments on this analysis.

DOE carefully selected ballasts for the teardown analysis to create useful data to estimate manufacturer production costs. DOE mapped out a matrix of product specifications and selected ballasts so that comparisons could be made amon g ballasts that differed by only one characteristic (such as starting method or input vol tage). Ballasts are described by a long list of specifications, so DOE concentrated on the specificati ons that were expected to have the greatest impact on efficiency—high versus regular adve rtised efficiency, maximum number of lamps driven, starting method, and universal versus si ngle input voltage. DOE submitted 13 ballasts for teardowns. For the CSLs that these ballasts just met, DOE assigned the MPC from the teardown directly to the CSL.

y U.S. Department of Labor, Bureau of Labor Statis tics, Producer Price Indices. Last accessed May 13, 2009.

< http://www.bls.gov/ppi>.



### 2-45

### DOE was able to select only unpotted ballast s for the teardown analysis. Some ballast manufacturers add potting, a type of black pitch, to the ballast enclosure to improve durability and manage heat distribution. Because the sticky potting inhibits visual observation of the components, DOE was unable to reverse engineer many ballasts through a teardown analysis.

To estimate MPCs for ballasts that were not submitted for teardowns, DOE used online ballast supplier pricing to develop ratios relatin g online prices to teardown-sourced MPCs. After developing a ratio specific to each manufacturer, DOE could then estimate the MPC for a particular CSL. DOE identified ballasts from multiple manufacturers that just meet the CSL and then marked down the online prices to the MPC using the manufacturer-specific MPC ratio. DOE averaged the MPCs for all the ballasts just meeting the CSL to calculate the MPC.

Once MPCs were assigned to each CSL, DOE developed a markup to scale the MPC to the manufacturer selling price. DOE relied on in come statements found in 10-K reports from publicly owned ballast manufacturing companies. Using multi-year average financial data, DOE used the ratio of net sales to cost of g oods sold to mark up the MPC to the MSP.

As NEMA suggested at the framework public meeting, DOE also contacted individual manufacturers for price data on a confidential basis. (NEMA, Public Meeting Transcript, No. 9 at

p. 141) Using this confidential data, DOE was able to verify scaled prices and appropriate markup and overhead estimates. The Joint Comment recommended that when using manufacturer data, DOE should use the minimum co st data submitted rather than the average cost data because the low-cost manufacturer determines prices in a market in equilibrium. (Joint Comment, No. 12 at p. 13) Because DOE used a “bottom up” approach by generating MPCs from BOMs and marking up the MPC to an MSP, DOE did not need to choose between minimum cost and average cost data. When calculating the MPC through the BOM, DOE assigned prices to components based on high volume purchasing. DOE believes this method generated an accurate estimation of the MSP.

The Joint Comment urged DOE to review rev ealed pricing for the 2000 Ballast Rule to calibrate the accuracy of DOE price predicti ons. In addition, the Joint Comment recommended that in developing a calibration of revealed prices, DOE should separate commodity price impacts from impacts associated with a new effici ency standard. (Joint Comment, No. 12 at p. 13)

DOE believes that it should not calibrate pric es based on revealed historical pricing for two reasons. First, DOE is not using same pr icing methodology as it used in the 2000 Ballast Rule. The methodology in the 2000 Ballast Rule re lied on surveying distribut ors of magnetic and

electronic ballasts to determine the appropriate distributor pri ce and then using one markup to reflect the end user price. z 

### Because DOE is using a different methodology to develop ballast prices (a reverse engineering cost estimate), DOE feels a calibration would be inappropriate. Second, DOE believes that conditions may be sign ificantly different for the 2000 Ballast Rule

z U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy. Energy Conservation Program for Consumer Products: Technical Support Document: Energy Conservation Standards for Consumer Products: Fluorescent Lamp Ballasts. Chapter 3: Engineering Analysis. September 2000. Washington, D.C. < http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/chap3.pdf >



### 2-46

### than they are today. For example, there have be en substantial fluctuations in energy prices; pressure to move manufacturing facilities out of the United States; and changes in distribution channels, such as the dominance of “big box” retailers. For similar reasons, markups may not follow past behavior because numerous factors influence business costs and decisions on profit margins throughout the distribution chain. For these reasons, DOE does not believe it should calibrate the prices in this analysis according to historical pricing. For more information on DOE’s price analysis, see chap ter 5 of the preliminary TSD.

2.6.7 Other Key Issues

NEMA expressed concern that several possi ble upcoming regulations would affect the engineering and LCC analysis for fluorescent lamp ballasts. Specifically, NEMA is concerned about four possible regulations: safety requirements for system interconnects, safety requirements for lamp end-of-life protection, electromagnetic fiel d requirements, and hazardous material regulation. NEMA stated that these pot ential requirements could result in lower ballast efficiency and affect payback calculations (NEMA, No. 11 at p. 6; NEMA, Public Meeting Transcript, No. 9 at pp. 133-134)

DOE agrees that safety requirements for syst em interconnects and lamp end-of-life might lower the efficiency of commercially available ba llasts. However, DOE is not able to account for this lower efficiency until the requirements are established. For DOE to prepare for this possible regulation, DOE requests comments on how these re quirements will affect the efficiency of commercially available ballasts. DOE also reques ts information on how safety requirements may affect the cost of both low and high efficien cy ballasts so that DOE can assess how these requirements might affect payback calculations.

NEMA also expressed concern about possi ble electromagnetic field regulations. Specifically, NEMA is concerned that current internationally accepted electromagnetic interference (EMI) levels may be modified. (NEM A, No. 11 at p. 6; Advance, Public Meeting Transcript, No. 9 at pp. 133-134) DOE believes that if EMI levels are modified, the efficiency of commercially available ballasts ma y be lowered. However, DOE is not able to account for this lower efficiency until the requirements are established. Again, to prepare for this potential regulation, DOE requests comments on how these re quirements will affect the efficiency of commercially available ballasts. DOE also requests information on the cost of both low and high efficiency ballasts that meet these regulations so that DOE can assess how these requirements may affect payback calculations.

Finally, NEMA expressed concern that hazardous material regulations may be implemented. If impleme nted, NEMA believes these regula tions could affect component availability and payback calculations. (NEMA, No. 11 at p. 6; NEMA, Public Meeting Transcript, No. 9 at p. 133) DOE believes that if hazardous material regulations are implemented, the cost of ballasts may be higher . If costs increase more or less for higher efficiency ballasts than for lower efficiency ballasts, then payback calculations will be affected. As stated above, however, DOE cannot account for this effect unless regulations are established. DOE requests comments on when NEMA believe s hazardous material regulations may be

2-47

### adopted and how these requirements will affect the cost or efficiency of commercially available

ballasts.

2.7 ENERGY USE AND END-USE LOAD CHARACTERIZATION

The energy use characterization provides estimates of annual energy use for representative lamp-and-ballast systems that DOE evaluates in the LCC and PBP analyses and the NIA. To develop annual energy use es timates, DOE multiplied a nnual usage (in hours per year) by the system input power (in watts).

DOE selected the most common fluorescent lamp used with each analyzed ballast to develop representative lamp-and-ballast systems. Fluorescent lamps will not be regulated under the proposed ballast rulemaking; however, the in put power of the comp lete lamp-a nd-ballast system is considered for the energy use analys is because ballasts are not intended to operate without lamps. DOE developed the system input power estimates in the engineering analysis (chapter 5 of the preliminary TSD). To charact erize the country’s average use of lamp-andballast systems for a typical year, DOE develope d annual operating hours by sector, using data published in the U.S. Lighting Market Characterization: Volume I (LMC), Residential Energy Consumption Survey (RECS), the Commercial Bu ilding Energy Consumption Survey (CBECS), and the Manufacturer Energy Consumption Survey (MECS).

Lighting controls can reduce operating hours for affected lamp-and-ballast systems. At the public meeting, NYSERDA asked if DOE would consider lighting controls in its analyses (NYSERDA, Public Meeting Transcript, No. 9 at p. 151). With the exception of PS ballasts— which are often paired with occupancy sensors to maintain or extend lamp life—DOE did not modify the operating hour data from LMC for ot her ballast product cla sses in the preliminary analyses. While DOE recognizes that there probably are more lighting controls in use today, DOE does not believe the level of penetration wo uld be significantly different from LMC, which was published in 2002. Further, DOE believes the ove rall national leve l of penetrati on of lighting controls at the individual level ( i.e. , those that would respond to one individual’s office) is still relatively low. Finally, DOE is unsure how it w ould account for lighting controls, as there is uncertainty about which control systems are being recommended, and DOE was not able to identify nationally representative data sources on the impact of lighting controls. However, DOE invites additional comments on this issue, partic ularly on the type, prevalence, and operating hour reductions due to lighting controls used se parately in the commerc ial, industrial, and

residential sectors.

In the case of PS ballasts operating 4-foot MB P T8 lamps, DOE assumed these lamp-andballast systems are operated on occupancy sensor s in the commercial sector. Based on the range of estimated energy savings from occupancy sensors, DOE assumed energy savings of 30 percent and accounted for these energy savings with a 30 percent reduction in average operating hours for affected lamp-and-ballast systems. aa

aa

E Source. Purchasing Advisor Web Page – Lighting: Occupancy Sensors. 2009. (Last Accessed May 5, 2009.)

< http://www.esource.com/BEA/demo/BEA_esource/PA_10.html >



### 2-48

### See chapter 6 of the preliminary TSD for additional detail on the energy use

characterization.

2.8 MARKUPS ANALYSIS

In this rulemaking, DOE performed teardo wn analyses and a manufacturer markup analysis to develop MSPs for representative ballast designs (chapter 5 of the preliminary TSD). DOE then applied distribution channel markups and sale s tax to derive end-user prices. By combining the engineering analysis results and the distribution channel markups analysis, DOE derived typical inputs for use in the LCC analysis and the NIA.

The end-user equipment price depends on how the end-user purchases the equipment. As illustrated in Figure 2.8.1, two types of distribu tion channels describe how most ballasts pass from the manufacturer to the end-user. The first distribution channel applies to ballasts installed in fixtures. In this distribution channel, the manufacturer sells the ballast to an original equipment manufacturer (OEM)—in this case, th e fixture manufacturer—who in turn sells it to an electrical wholesaler ( i.e. , distributor), then to a contractor , and finally to the end-user. The second distribution channel applies to ballasts not installed in fixtures ( e.g. , replacement ballasts). In this distribution channel, the ma nufacturer sells the ballast to an electrical wholesaler, then to a contractor , and finally to the end-user.

Figure 2.8.1 Ballast Distribution Channels

Publicly owned companies are required to disclose financial information on a regular basis by filing different forms with the U.S. Securities and Exchange Commission (SEC). Filed annually, SEC form 10-K provides a comprehens ive overview of the company’s business and

financial conditions. To estimate OEM and wholesaler markups, DOE used financial data from

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### 10-K reports from publicly owned lighting fixtur e manufacturers and electrical wholesalers, respectively. DOE assumed a contractor markup c onsistent with that used in the 2000 Ballast Rule, and developed sales tax values using current State and local sales tax data. Chapter 7 of the preliminary TSD provides details of the markups analysis.

2.9 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES

Energy conservation standards on equipmen t usually reduce operating expenses and increase end-user prices. DOE analyzed the net effect of amended standards on end-users by evaluating the net LCC using the cost-efficiency relationship derived in the engineering analysis, as well as the energy usage and costs derived fro m the energy use characterization. Inputs to the LCC calculation include the installed cost to the end-user (purchase price plus installation cost), disposal costs (ballast and lamp recycling) , operating expenses (energy expenses and maintenance costs), the lifetime of the ballast, and a discount rate. Chap ter 8 of the preliminary TSD describes these inputs.

At the framework public meeting, Osram Sylvania commented that installation and

maintenance costs should not differ between the baseline and standards-case ballast designs. (Osram Sylvania, Public Meeting Transcript, No. 9 at p. 165) DOE agrees, but distinguished the ballast replacement and new construction/renovation purchasing even ts by adding 2.5 minutes of labor time for installing a luminai re disconnect in the new cons truction/renovation case. This additional labor time and cost are not related to ballast design, but instead reflect current National Electric Code requirement s for new fixture installations.

When a ballast or fluorescent lamp fails, some consumers choose to recycle the system components. The cost of recycling the ballast or la mp is its disposal cost. Ballast recycling rate data were not available, so DOE conservatively assumed 5 perc ent of ballasts used in the

commercial and industrial sector s were recycled, and that no ballasts are recycled in the

residential sector. One commenter noted that DOE should address the energy consumption required for ballast disposal and recycling in its LCC and PBP analyses, (Farrior, No. 10 at p. 2) DOE was not, however, able to obtain sufficiently detailed information on ballast recycling rates

or methods to estimate associated energy consumption and costs.

DOE estimates electricity prices for commercial, industrial, and residential consumers by using Energy Information Administration (EIA) data. EIA’s Annual Energy Outlook (

AEO2009 ) was the default source of projections for future electricity prices. DOE received a number of comments on the potential effects of energy-efficient ballast designs on electricity demand charges and how DOE accounts for these effects in its LCC and PBP analyses. (ASAP, Public Meeting Transcript, No. 9 at pp. 159, 161–162; Jo int Comment, No. 12 at p. 12; NYSERDA, Public Meeting Transcript, No. 9 at p. 161; Osram Sylvania, Public Meeting Transcript, No. 9 at pp. 160, 162) Similarly, the Joint Comment discus sed how DOE’s approach to forecasting energy prices does not consider impacts of amended standards on utility infrastructure, natural gas demand, or overall electricity cost s. (Joint Comment, No. 12 at pp. 11–12)

Factors such as infrastructure impacts and demand charge effects would primarily be addressed in the utility impacts analysis. DOE bases this analysis on the Buildings version of the

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### National Energy Modeling System (NEMS-BT), which does not have the capability to address demand load profiles ( i.e. , usage by time of day). Therefore, DOE is unable to quantify the potential impacts on peak demand for electricity fr om changes in product efficiency. DOE also considered reporting overall na tural gas and electricity price impacts but found that the uncertainty of price projections, together with th e fairly small anticipated impact of the amended standards relative to total electricity demand, ma kes these price changes highly uncertain. Given the current complexity of utility regulation in the United States (with significant variances among States), it does not seem appropriate to attempt to measure impacts on infrastructure costs and prices where there is likely to be significant overlap. As a result, DOE believes that they should not be weighed heavily in the de cision concerning the standard level.

Several commenters noted that DOE should c onsider whether energy-efficient ballasts have a longer lifetime, based on presumed cooler operating temperatures. (ASAP, Public Meeting Transcript, No. 9 at pp. 166–167; Joint Comment, No. 12 at p. 8; Philips, Public Meeting Transcript, No. 9 at pp. 167–168) Philips al so commented on the trend toward compact design in the lighting industry and how this would result in higher operating temperatures. (Philips, Public Meeting Transcript, No. 9 at p. 168) DOE acknowledges the trend toward compact design in energy-efficient ballasts and fixtures, and assumes a compact format will result, on average, in ballast operating temperatures equal to or greater than those for current ballast designs. Consequently, DOE assumes no ex tended life for energy efficient ballast designs in this rulemaking. NEMA and Osram Sylvania commented that energy efficient ballast designs should not affect lamp life. (NEMA, No. 11 at p. 8; Osram Sylvania, Public Meeting Transcript, No. 9 at pp. 165–166) DOE agrees with these comments and did not assume any extended lamp life in its LCC and PBP analyses.

DOE developed discount rates by estimating the cost of capital to end users that purchase the ballasts covered under this rulemaking. For commercial and industrial end users, DOE used the cost of capital to estimate the present va lue of cash flows to be derived from a typical company project or investment. Most companie s use both debt and equity capital to fund investments, so the cost of capital is the weighted -average cost to the firm of equity and debt financing. This corporate finance approach is referr ed to as the weighted-average cost of capital. DOE used currently available economic data in developing discount ra tes and will update the data as appropriate for the NOP R stage of this rulemaking.

For residential end users, DOE derived the discount rates from estimates of the interest or “finance cost” to purchase residential products. The finance cost of raising funds to purchase residential products can be interpreted as (1) the financial cost of any debt incurred to purchase residential products, princi pally interest charges on debt; or (2 ) the opportunity cost of any equity used to purchase residential products, princi pally interest earnings on household equity. Household equity is represented by holdings in a ssets such as stocks and bonds, as well as the return on homeowner equity. DOE obtained data required to determine th e cost of debt and equity from the Federal Reserve Board’s triennial Survey of Consumer Finances

.

For more detail on the LCC and PBP analyses, see chapter 8 of the preliminary TSD.

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### 2.10 SHIPMENTS ANALYSIS

Shipments of ballasts are key inputs to the na tional energy savings and net present value calculations in the NIA model. Shipments are also a necessary input to the MIA, which DOE will conduct for the NOPR stage of this rulemaking . DOE requested but was not able to obtain manufacturer historical shipments data for the preliminary analysis. Consequently, DOE followed a three-step process to forecast ballast sh ipments. First, DOE used historical shipment

data from the U.S. Census Bureau to estimate the total historical shipments of each ballast type analyzed. Second, DOE calculated an installed stoc k for each ballast type based on the average service lifetime of each ballast type. Third, by modeling ballast purchasing events, such as replacement and new construction, and applying growth rate, replacement rate, and emerging technologies penetration rate assumptions, DOE developed annu al shipment projections.

At the public meeting, Philips and Osram Sylvania commented on anticipated impacts of emerging technologies ( e.g. , solid-state lighting), lighting c ontrols, and daylight harvesting on future ballast shipments. (P hilips, Public Meeting Transcript, No. 9 at pp. 176, 189–191; Osram Sylvania, Public Meeting Transcript, N o. 9 at pp. 193–194) DOE addressed emerging technologies in its shipments analysis using assumptions and methodology from the 2009 Lamps Rule. To address lighting controls ( e.g. , occupancy sensors), DOE modeled the growing market for 4-foot T8 MBP systems using PS ballasts but lacked sufficient information to model the market effects of other control types, including th ose used for daylight harvesting. Acuity Brands Lighting commented that DOE should consider th e effects of California energy efficiency regulations on future ballast shipments. (Acuity Brands Lighting, Public Meeting Transcript, No. 9 at p. 200) For its preliminary analyses, DOE conducted manufacturer in terviews to help identify future shipment trends, and assumes that these trends integrate various regulatory and non-regulatory initiatives in the lighting marketplace.

To determine the cumulative NES and NPV of amended standards, DOE compared forecasted shipments of a base to a standards case over the NIA analysis period. Chapter 9 of the preliminary TSD provides details on the shipments analysis.

2.11 NATIONAL IMPACT ANALYSIS

The national impact analysis assesses the net present value of total end-user LCC and NES. DOE determined both the NPV and NES for the performance levels considered for the ballast product classes analyzed. To make the analysis more tran sparent to all interested parties, DOE prepared an NES spreadsheet model to fo recast energy savings and the national economic costs and savings resulting from amended standards. The NES model does not use probability distributions for inputs or outputs. To assess the impact of input uncertainty on the NES and NPV results, DOE can conduct sensitivity analyses by running scenarios on input variables relevant to interested parties. DOE assessed the aggregate economic impacts at the national level for this preliminary analysis.

The Joint Comment noted that DOE’s current NIA methodology does not sufficiently address energy price impacts, environmental externalities, or other broad consumer impacts. (Joint Comment, No. 12 at p. 11) DOE acknowledg es that there may be certain “external”

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### benefits resulting from the improved efficiency of ballasts that are not captured by equipment users. These include both environmental and energy security-related externalities that are not already reflected in energy prices, such as reduced emissions of greenhouse gases and reduced use of natural gas and oil for electricity generation. DOE inv ites comments on the nature and magnitude of these impacts.

2.11.1 National Energy Savings Analysis

The inputs for determining NES are (1) annual energy consumption per unit; (2) shipments; (3) equipment stock; (4) national en ergy consumption (calculated from consumption per unit and equipment stock); (5) site-to-source conversion factors; (6) a heating, ventilation, air conditioning (HVAC) factor; and (7) rebound rates.

DOE calculated the national energy consumption by multiplying the number of units, or stock, of lamp-and-ballast systems (by vintage, wh ich represents the age of the ballasts) by the unit energy consumption (also by vintage). The n, DOE calculated national annual energy savings from the difference between national energy c onsumption in the base case (without amended efficiency standards) and in each higher-eff iciency standards case. DOE estimated energy consumption and savings based on site energy, and converted th e electricity consumption and savings to source energy. DOE also examined potential energy savings due to HVAC interactions, as well as rebound effects (an energy savings “take-back”) based on consumer usage patterns. Cumulative energy savings are the sum of the annual NES, which DOE determined over specific time periods.

2.11.2 Net Present Value Analysis

The inputs DOE used to determine the NPV were (1) total annual inst alled cost, (2) total annual operating cost savings, (3) discount factor , (4) present value of costs, and (5) present value of savings. DOE calculates net savings ea ch year as the difference between total operating cost savings and increases in total installed co sts (including equipmen t price and installation cost). DOE calculates savings over the life of th e equipment, accounting for differences in yearly energy rates. DOE calculates NPV as the difference between the present value of operating cost savings and the present value of increased total installed costs. DOE discounts future costs and savings to the present with a discount factor.

DOE calculated increases in total installed co sts as the product of the difference in the

total installed cost between th e base case and standards case and the annual shipments in the standards case. Because purchase costs of the higher-efficiency equipment in the standards case are generally greater than the purchase costs of equipment in the base case, price increases appear as negative values in the NPV. DOE expressed operating cost savings as decreases in operating costs associated with the lower energy consumption of equipment in the standards case compared to the base efficiency case. Total opera ting cost savings are the product of savings per unit and the number of units of each vintage surviving in a particular year.

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### The Joint Comment urges DOE to give prima ry weight to NPV results based on the 3­ percent discount factor, citing academic research th at indicates appr opriate societal discount rates of 3 percent or less. (Joint Comment, No. 12 at p. 13) In its preliminary analyses, DOE estimated national impacts with both a 3-per cent and 7-percent real discount rate, per OMB guidelines on discount factors used in regulatory analyses. (OMB Circular A-4 (September 17, 2003), particularly section E, “Identif ying and Measuring Benefits and Costs”) Consistent with this guidance, DOE will use 3-percent and 7-percent real discount rates for rele vant calculations in the NOPR stage of this rulemaking.

2.11.3 Efficiency Scenarios and Trends

Several of the inputs for th e determination of NES ( e.g. , the annual energy consumption per unit) and NPV ( e.g. , the total annual installed cost a nd the total annual operating cost savings) depend on equipment efficiency. Thus, DOE developed base ca se and standards case efficiency trends. These trends specified the a nnual historical and forecasted shipment-weighted average equipment efficiencies.

For ballasts, DOE developed tw o shipment scenarios: “roll up” and “shift.” The roll-up scenario represents a standards case in which all product efficiencies in the base case that do not meet the standard would roll up to meet the new st andard level. Consumers in the base case who purchase ballasts above the standard level are not affected as they are assumed to continue to purchase the same base-case ballast or lamp -and-ballast system. The roll-up scenario characterizes consumers primarily driven by th e first-cost of the analyzed equipment.

In contrast, the shift scenario models a standards case in which the standard affects all base-case consumer purchases (regardless of whether their base-case efficiency is below the standard). In this scenario, any consumer may purchase a more efficient ballast. As the standard level increases, market share incrementally accumulates at the highest standard level because it represents max tech ( i.e. , moving beyond this efficiency level is not achievable with today’s technology). The shift scenario characterizes consumers primarily concerned with system energy consumption and reflects an upper bound scenario.

Chapter 10 of the preliminary TSD provides additional details on the national impacts analysis.

2.12 LIFE-CYCLE COST SUBGROUP ANALYSIS

The LCC subgroup analysis evaluates economic impacts on selected groups of consumers who might be adversely affected by a change in the national energy conservation standards for the considered products. DOE evaluates impacts on pa rticular subgroups of consumers in part by analyzing the LCC impacts and PBP for those particular consumers.

DOE will use the LCC spreadsheet model to evaluate impacts on consumer subgroups. DOE can analyze the LCC for any subgroup by applying the LCC spreadsheet model to only that subgroup. DOE is particularly sensitive to increas es in the consumer price of the considered

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### products as it wishes to avoid a negative econo mic impact on any identified consumer subgroup. See chapter 11 of the preliminary TSD for more information on the LCC subgroup analysis.

2.13 MANUFACTURER IMPACT ANALYSIS

The purpose of the MIA is to identify the lik ely impacts of higher energy conservation

standards on manufacturers. The Process Rule provides guidance for conducting this analysis with input from manufacturers and other interested parties. DOE will apply this methodology to its evaluation of standards for fluorescent lamp ba llasts. The Process Rule gives guidelines for considering financial impacts and a wide rang e of quantitative and qua litative industry impacts that might occur after adoption of a standard. Fo r example, a particular standard level could require changes to manufacturing practices of fluorescent lamp ballasts. DOE will identify and discuss these impacts in interviews with manufacturers and other interested parties during the NOPR stage of the analysis.

DOE will conduct the MIA in three phases, and will further tailor the analytical

framework based on the comments it receives. In Phase I, DOE creates an industry profile to characterize the industry and identify important i ssues that require consideration. In Phase II, DOE prepares an industry cash-flow model and an interview questionnaire to guide subsequent discussions. In Phase III, DOE interviews manufa cturers, and assesses the impacts of standards both quantitatively and qualitativ ely. DOE assesses industry and subgroup cash flow and NPV using the Government Regulatory Impact Model (GRIM). DOE then assesses impacts on competition, manufacturing capacity, employment, and regulatory burden based on manufacturer

interview feedback and discussions.

Until recently, DOE reported MIA results in its standards rulemakings only in the NOPR phase of the rulemaking. However, DOE is now evaluating and reporting preliminary MIA information at this preliminary analytical phase. DOE gathered the information for the analysis during the manufacturer interviews conducted af ter the engineering analysis. See chapter 12 of the preliminary TSD for more detail on the MIA.

2.13.1 Sources of Information for the Manufacturer Impact Analysis

Many of the analyses described above provi de important informati on applicable to the MIA. Such information includes manufacturing costs and prices from the engineering analysis, retail price forecasts, and shipment forecasts . DOE will supplement this information with company financial data and other information ga thered during interviews with manufacturers.

The interview process plays a key role in the MIA. DOE aggregates information across manufacturers, creating a combined opinion or estimate for DOE.

DOE conducts detailed interviews with manufacturers to gain insight into the range of potential impacts of standards. Typically, DOE solicits both quantitative and qualitative information during the interviews on the potential impacts of efficiency levels on sales, direct employment, capital assets, and industry competitiveness. DOE pref ers an interactive interview process, rather than a written response to a que stionnaire, because it help s clarify responses and

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### identify additional issues. Before the intervie ws, DOE will circulate a draft document showing estimates of the financial parameters based on publicly available information. DOE will solicit comments on these estimates during the interviews. See chapter 12 of the preliminary TSD for more detail on the methodology used in the MIA.

2.13.2 Industry Cash-Flow Analysis

The industry cash-flow analysis relies primarily on the GRIM. DOE uses the GRIM to analyze the financial impacts of more stringent energy conservation standards on the industry.

The GRIM analysis uses several factors to determine annual cash flows from an amended energy conservation standard: annual expected re venues; manufacturer costs, including cost of goods sold, depreciation, research and devel opment, selling, and general and administrative expenses; taxes; and conversion capital expenditures. DOE compares the results against base case projections that involve no amended energy conservation sta ndards. The financial impact of amended energy conservation standards is the di fference between the two sets of discounted annual cash flows. Other performance metrics, such as return on invested capital, also are available from the GRIM. See chapter 12 of the preliminary TSD for more information on the industry cash-flow analysis.

2.13.3 Manufacturer Subgroup Analysis

Industry cost estimates are inadequate to assess differential impacts among subgroups of manufacturers because these subgroups may have different cost structures or regulatory frameworks that affect their respective business models. For example, small and niche manufacturers, or manufacturers whose cost st ructure differs significantly from the industry average, could experience a more negative impact. Ideally, DOE would consider the impact on every firm individually; however, because this usually is not possible, DOE typically uses the results of the industry characterization to group manufacturers exhibiting similar characteristics.

During the interview process, DOE will discuss the potential subgroups and subgroup members it has identified for the analysis. DOE will encourage manufacturers to recommend subgroups or characteristics that are appropriate for the subgroup analysis. See chapter 12 of the preliminary TSD for more detail on the manufacturer subgroup analysis.

2.13.4 Competitive Impacts Assessment

Section 342 (6)(B)(i)(V) of EPCA directs DOE to consider any lessening of competition likely to result from imposition of standards. DOE will consider whether an amended energy conservation standard is likely to reduce industr y competition and will ask the Attorney General to determine the impacts, if any. The assessment will be based on manufacturing cost data and

information collected from manufacturer interviews. DOE will make a determined effort to gather and report firm-specific fi nancial information and impacts.

2.13.5 Cumulative Regu latory Burden

DOE recognizes and seeks to mitigate the overlapping effects on manufacturers of new or amended DOE standards and other regulatory actions affecting the same equipment. DOE will

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### analyze and consider the impact on manufacturers of multiple, equipment-specific regulatory

actions.

During the public meeting, several manu facturers raised concerns about existing regulations. Advance stated that California is very active and aggressive in writing legislation for energy efficiency for lighting products. Manufact urers look to the Federal government to keep

the same standards across all 50 states. DOE should keep abreast of California's regulations to ensure that the same standards are in place across all States. (Advance, Public Meeting Transcript, No. 9 at pp. 200-201) Acuity Brands Lighting commented that section 3313(g) of EISA 2007 requires that the Administrator of Gene ral Services purchase more energy efficient lighting products that adhere to the Buy America Act. Because efficient electronics for lighting products are produced abroad, Acuity Brands Li ghting suggested that DOE obtain an exemption from the Buy American provision of EISA 2007 for certain lighting equipment. (Acuity Brands Lighting, Public Meeting Tr anscript, No. 9 at pp. 93-94)

In response to these comments, DOE investigated the regulations manufacturers

mentioned in the market and technology assessment (chapter 3 of the preliminary TSD). In investigating the provisions in section 3313 (g) of EISA 2007, DOE agrees that the legislation may be burdensome for manufacturers but EPCA does not authorize DOE to allow for such an exemption. During the NOPR, however, DOE plan s to further investigat e overlapping burdens

on the manufacturers of fl uorescent lamp ballasts.

2.13.6 Preliminary Results for the Manufacturer Impact Analysis

DOE conducted a series of preliminary interv iews with manufacturers to discuss impacts that may result from a regulatory standard for fluorescent lamp ballasts. In general, manufacturers and other parties identified three areas of concern: (a) impacts on profitability, (b) product conversion costs/diminishing return s to consumers, and (c) product innovation.

2.13.7 Impacts on Profitability

Some manufacturers commented that pr ofit margins would decrease with the implementation of amended energy conservation standards, especial ly for the original equipment manufacturer (OEM) distribution channels. For example, a higher standard could cause consumers to switch from residential ballasts, which are more price sensitive, to less efficient lighting products. According to the manufacturers DOE interviewed, consistent profitability is not common across all types of fluorescent lamp ba llasts. Manufacturers also noted that pricing is extremely variable depending on the appli cation (commodities, ol d products, new products, niche, etc). Some products are sold at a loss, some are sold at cost to load overhead, and some are sold for a profit.

2.13.8 Product Conversion Costs/Diminishing Returns to Consumers

Certain manufacturers commented that raising existing energy conservation standards would force them to purchase more expensive and energy efficient components to improve existing lines as well as design new product lin es. The majority of those costs would be

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### attributed to engineering and education. Due to higher conversion costs associated with increasing energy conservation standards, consumer s would eventually be confronted with more expensive products.

2.13.9 Product Innovation

Manufacturers also expressed concern over the impact amended energy conservation standards would have on produc t innovation. Because personnel may be spending more time redesigning products to comply w ith standards, the resources av ailable for the development of new products would significantly decrease.

2.14 UTILITY IMPACT ANALYSIS

The utility impact analysis includes an analysis of the effect of amended energy conservation standards on the electric and the ga s utility industries. For this analysis, DOE will use a variant of NEMS, a large multi-sectoral, partial-equilibrium model of the U.S. energy sector that the EIA has developed throughout th e past decade, primarily for preparing EIA’s

AEO . In previous rulemakings, a variant of NEMS (currently termed NEMS-BT, BT referring to the DOE’s Building Technologies Program version of NEMS), was developed to better address the specific impacts of an energy conservation standard.

Available in the public domain, NEMS produ ces a widely-recognized baseline energy forecast for the United States through 2030. Th e typical NEMS outputs include forecasts of electricity sales, prices, a nd electric generating capacity. DOE conducts the utility impact analysis as a scenario that departs from the latest AEO reference case. In other words, the energy savings impacts from amended energy conserva tion standards are modeled using NEMS-BT to generate forecasts that deviate from the AEO reference case.

ASAP and the Joint Comment stated that DOE should address the impacts of amended standards on energy commodity prices. (ASAP, P ublic Meeting Transcript, No. 9 at p. 96; Joint Comment, No. 12 at pp. 9–11) For electric products such as fluorescent lamps and ballasts, DOE considered reporting gas and electricity price imp acts but found that the uncertainty of price projections, together with the fairly small impact of the standards relative to total electricity demand, makes these price changes highly uncertai n. As a result, DOE believes that changes to energy commodity prices should not be weighed h eavily in the decision concerning the standards level. Given the current complexity of utility regulation in the United States, with significant variation among States, DOE did not believe it was appropriate to measure impacts on infrastructure costs and prices where there is likely to be significant overlap and uncertainty.

DOE also received comments on the potential ef fects of amended standards on external benefits such as energy security ( e.g. , reduced natural gas usage), utility infrastructure, and pollution reductions. (ASAP, P ublic Meeting Transcript, No. 9 at pp. 95–96, 202–203; Joint Comment, No. 12 at pp. 9, 11–12) Historically, DOE’ s approach to the utility impact analysis, based on NEMS, has been to evaluate the impact of standards only on utility energy sales. NEMS is not suited to characterizing impacts of standards on utilities other than those measured by sales, and DOE is unaware of any analytical to ols that would enable an analysis of financial

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### impacts on utilities at a national level. Therefore, DOE plans to continue using NEMS for the utility impact analysis, but it invites input from in terested parties on the potential use of other tools for such analysis.

As discussed in section 0, DOE acknowledge s external benefits of amended standards— such as energy security and pollution reductions—that are not captured solely by utilities or ballast end users, but also by the public. DOE invites comments on the na ture and magnitude of

these benefits.

Chapter 13 of the preliminary TSD provides additional details on the utility impact analysis.

2.15 EMPLOYMENT IMPACT ANALYSIS

The imposition of standards can affect employ ment both directly a nd indirectly. Direct employment impacts are changes in the number of employees at the plants that produce the covered equipment and at affiliated distribution and service companies. DOE evaluates the direct employment impacts in the MIA. Indirect employment impacts may result from expenditures shifting between goods (the substitution effect) and changes in income and overall expenditure levels (the income effect). As part of the NO PR stage of this rulemaking, DOE will seek input from interested parties on the potential employment impact. and DOE will investigate the combined direct and indirect employment impacts in the employment impact analysis using the Pacific Northwest National Laboratory’s “Impact of Sector Energy Technologies” (ImSET) model. The ImSET model was developed for DOE’s Office of Planning, Budget, and Analysis to estimate the employment and income effects of energy-saving technologies on buildings, industry, and transportation. Compared to simp le economic multiplier appr oaches, ImSET allows for more complete and automated analysis of the economic impacts of energy conservation investments. Details can be found in chapter 14 of the preliminary TSD.

2.16 ENVIRONMENTAL ASSESSMENT

The intent of the environmental assessment is to quantify and consid er the environmental effects of amended energy conservation standa rds for fluorescent lamp ballasts. The primary environmental effects of these standards would be reduced power plant emissions resulting from reduced consumption of electricity. DOE will assess these environmental effects by using NEMS-BT to provide key inputs to its analysis . The portion of the environmental assessment that will be produced by NEMS-BT considers carbon dioxide (CO 2 

### ), nitrogen oxides (NO X 

### ), and mercury (Hg). The environmental a ssessment also considers impacts on SO 2 

### emissions. After a brief discussion of general methodology, this sect ion will address each of th e relevant emissions. This section then explains how DOE plans to m onetize the benefits asso ciated with emissions

reductions.

2.16.1 Carbon Dioxide

In the absence of any Federal emissions cont rol regulation of power plant emissions of

CO 2 

### , a DOE standard is likely to result in reductions of these emissions. The CO 2 

### emission

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### reductions likely to result from a standard will be estimated using NEMS-BT and national energy savings estimates drawn from the NIA spreadsheet model. The net benefit of the standard is the difference between emissions estimated by NEMS-BT at each standard level considered and the

AEO Reference Case. NEMS-BT tracks CO 2 

### emissions using a deta iled module that provides results with broad coverage of all sector s and inclusion of interactive effects.

2.16.2 Sulfur Dioxide

DOE has preliminarily determined that SO 2 

### emissions from affected Electric Generating Units (EGUs) are subject to nationwide and regional emissions cap and trading programs that are likely to eliminate the standards’ impact on SO 2 

### emissions. The costs of meeting such emission cap requirements are reflected in the electricity prices and forecasts used in DOE’s analysis of

the standards. Title IV of the Clean Ai r Act sets an annual emissions cap on SO 2 

### for all affected

EGUs. SO 2 

### emissions from 28 eastern States and the District of Columbia (DC) are also limited under the Clean Air Interstate Rule (CAIR, published in the Federal Register on May 12, 2005. 70 FR 25162 (May 12, 2005)), which creates an allowance-based trading program that will gradually replace the Title IV program in thos e States and DC. (The recent legal history surrounding CAIR is discussed below.) The attainme nt of the emissions caps is flexible among EGUs and is enforced through the use of emissions allowances and tradable permits. Under existing EPA regulations, any excess SO 2 

### emission allowances resulting from the lower electricity demand caused by the imposition of an efficiency standard could be used to permit offsetting increases in SO 2 

### emissions by any regulated EGU. However, if the standard resulted in a permanent increase in the quantity of unused emission allowances, there would be an overall

reduction in SO 2 

### emissions from the standards. While th ere remains some uncertainty about the ultimate effects of efficiency standards on SO 2 

### emissions covered by the existing cap and trade system, the NEMS-BT modeling system that DOE plans to use to forecast emissions reductions currently indicates that no phys ical reductions in power sector emissions would occur for SO 2



### .

Even if there is no significant redu ction in the overall emissions of SO 2 

### that results from the standard, there may still be some ec onomic benefit from reduced demand for SO 2 

### emission allowances that is not fully reflected in the co st savings experienced by individual consumers. Electricity savings that decrease the overall demand for SO 2 

### emissions allowances could lower allowance prices and thereby result in some econo mic benefits for all electricity consumers, not just those that reduced their electricity use as a result of an efficiency standard. These lowered allowance prices were noted in ASAP’s comments. (ASAP, Public Meeting Transcript, No. 9 at pp. 206–207) DOE does not plan to monetize this par ticular benefit because the effect on the SO 2 

### allowance price from any single energy conservati on standard is likely to be small and highly

uncertain.

2.16.3 Nitrogen Oxides

NEMS-BT also has an algorithm for estimating NO X 

### emissions from power generation. The impact of these emissions, however, will be affected by the CAIR, which the Environmental Protection Agency (EPA) issued on May 12, 2005. CAIR will permanently cap emissions of

NO X 

### in 28 eastern states and the District of Columbia. 70 FR 25162 (May 12, 2005).

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### Much like SO 2 

### emissions, a cap on NO X 

### emissions means that the amended fluorescent lamp ballast standards may have little or no physical effect on these emissions in the 28 eastern States and the DC covered by CAIR. Although CA IR has been remanded to the EPA by the DC Circuit, it will remain in effect until it is replaced by a rule cons istent with the Court’s July 11, 2008, opinion in North Carolina v. EPA. 531 F.3d 896 (DC Cir. 2008); see also North Carolina

v. EPA, 550 F.3d 1176 (DC Cir. 2008). Because all States covered by CAIR opted to reduce

NO X 

### emissions through participation in cap-and- trade programs for electric generating units, emissions from these sources are capped across the CAIR region.

Standards may produce an envir onmental-related econo mic benefit in the form of lower prices for emissions allowance credits, as noted in ASAP’s comments. (ASAP, Public Meeting Transcript, No. 9 at pp. 206–207) As with SO 2 

### allowance prices, DOE does not plan to monetize this particular benefit because the effect on the NO X 

### allowance price from any single energy conservation standard is likely small and highly uncertain.

Earth Justice requested that DOE quantify NO X 

### emission reductions outside of areas where allowance trading occurs. (Earth Justice, Public Meeting Transcript, No. 9 at pp. 204–205) Accordingly, DOE plans to use NEMS-BT to es timate the emissions reductions from possible

standards in the 22 States wh ere emissions are not capped.

2.16.4 Mercury

Similar to emissions of SO 2 

### and NO X 

### , future emissions of Hg would have been subject to emissions caps. In May 2005, EPA issued th e Clean Air Mercury Rule (CAMR). 70 FR 28606 (May 18, 2005). CAMR would have permanently capped emissions of mercury for new and existing coal-fired power plants in all States by 2010. However, on February 8, 2008, the DC

Circuit issued its decision in New Jersey v. Environmental Protection Agency , in which the DC Circuit, among other actions, vacated th e CAMR. 517 F.3d 574 (DC Cir. 2008). EPA has decided to develop emissions standards for pow er plants under the Clean Air Act (Section 112),

consistent with the DC Circ uit’s opinion on the CAMR. See http://www.epa.gov/air/mercuryr ule/pdfs/certpetition_withdrawal.pdf . Pending EPA's forthcoming revisions to the rule, DOE is excluding the CAMR from its Environmental Analysis. In the absence of CAMR, a DOE sta ndard would likely reduce Hg emissions and DOE plans to use NEMS-BT to estimate these emission reductions.

2.16.5 Particulate Matter

DOE acknowledges that particulate matter (PM) impacts are of concern due to human exposures that can impact health. But impact s of PM emissions reduction are much more difficult to estimate than other emissions reductions due to the complex interactions between PM, other power plant emissions, meteorology, and atmospheric chemistry that impact human exposure to particulates. Human exposure to PM us ually occurs at a significant distance from the power plants that are emitting particulates and particulate precursors. When power plant emissions travel this distance, they undergo highly complex atmospheric chemical reactions. Although the EPA does keep inventories of direct PM emissions of power plants, in its source attribution reviews, the EPA doe s not separate direct PM emissions from power plants from the

2-61

### sulfate particulates indirectly produced through complex atmos pheric chemical reactions. The great majority of PM emissions from power plan ts are of these seconda ry particles (secondary sulfates). Thus, it is not useful to examine how the amended standard impacts direct PM emissions independent of indir ect PM production and atmospheric dynamics. Therefore, DOE is not planning to assess the impact of these standa rds on particulate emissions. Further, even the cumulative impact of PM emissions from power plan ts and indirect emissions of pollutants from other sources is unlikely to be significant.

2.16.6 Monetization of Emissi ons Reduction Benefits

Several commenters noted that there are also external benefits to pollutant emission

reductions that should be monetized and we ighed in DOE’s deter mination of maximum efficiency levels for ballasts. (ASAP, Public Meeting Transcript, No. 9 at p. 95; Joint Comment, No. 12 at pp. 9–10) For those emissions for which real national e mission reductions are anticipated (CO 2 

### , Hg, and NO X 

### for 22 states), only ranges of estimated economic values based on environmental damage studies of varying quality and applicability are available. Therefore, DOE plans on reporting estimates of monetary benefits derived using these values and plans to consider these benefits in weighing the costs and benefits of each of the standard levels

considered.

In order to estimate the monetary value of benefits resulting from reduced emissions of

CO 2 

### emissions, it is DOE’s intent to use in its an alysis the most current Social Cost of Carbon (SCC) values developed a nd/or agreed to by interagency reviews. The SCC is intended to be a monetary measure of the incremental damage resulting from greenhouse gas (GHG) emissions, including, but not limited to, net agricultural productivity loss, human health effects, property damage from sea level rise, and changes in ecosy stem services. Any effort to quantify and to monetize the harms associated with climate change will raise serious questions of science, economics, and ethics. But with full regard for the limits of both quantifi cation and monetization, the SCC can be used to provide estimates of the social benefits of reduc tions in GHG emissions.

At the time of this notice, the most recen t interagency estimates of the potential global benefits resulting from reduced CO 2 

### emissions in 2010 were $4.7, $21.4, $35.1, and $64.9 per

metric ton in 2007 dollars. These values are then adjusted to 2009$ using the standard GDP deflator value for 2008 and 2009. For emissions (or emission reductions) that occur in later years, these values grow in real terms over time. Additionally, the interagency group determined that a range of values from 7 percent to 23 per cent should be used to adjust the global SCC to calculate domestic effects, although preference will be given to consideration of the global benefits of reducing CO2 emissions. See appendix EA-SCC to the environmental assessment report in the preliminary TSD for the full ra nge of annual SCC estimates from 2010 to 2050. To calculate a present value of the stream of monetary values, DOE will discount the values in each of the four cases using the discount rates that had been used to obtain the SCC values in each

case.

DOE recognizes that scientific and economic kno wledge continues to evolve rapidly as to

the contribution of CO 2 

### and other GHG to changes in the fu ture global climate and the potential resulting damages to the world economy. Thus, these values are subject to change.

2-62

### DOE also intends to estimate the potential monetary benefit of reduced NO X 

### , and Hg emissions resulting from the standard levels it considers. For NO X 

### emissions, available estimates suggest a very wide range of monetary values for NO X 

### emissions, ranging from $370 per ton to $3,800 per ton of NO X 

### from stationary sources, measured in 2001$ (equivalent to a range of $442 to $4,540 per ton in 2008$). Refer to the OMB, Office of Information and Regulatory Affairs, “2006 Report to Congre ss on the Costs and Benefits of Federal Regulations and Unfunded Mandates on State, Local, and Trib al Entities,” for additional information.

For Hg emissions reductions, DOE has previous ly determined that the impact of mercury emissions from power plants on humans is c onsidered highly uncertain. However, DOE identified two estimates of the environmental damage of mercury based on two estimates of the adverse impact of childhood exposure to methyl mercury on intelligence quotient (IQ) for American children, and subsequent loss of life time economic productivit y resulting from these IQ losses. The high-end estimate is based on an estimate of the current aggregate cost of the loss of IQ in American children that results from ex posure to mercury of U.S. power plant origin ($1.3 billion per year in year 2000$), which wo rks out to $33.3 million per ton emitted per year (2008$). Refer to L. Trasande et al ., “Applying Cost Analyses to Drive Policy that Protects Children,” 1076 Ann. N.Y. Acad. Sci. 911 (2006) for additional information. The low-end estimate is $0.66 million per ton emitted (i n 2004$) or $0.745 million per ton in 2008$. DOE derived this estimate from a publis hed evaluation of mercury contro l using different methods and assumptions from the first study but also based on the present value of the lifetime earnings of children exposed to mercury. See Ted Gaye r and Robert Hahn, “Designing Environmental Policy: Lessons from the Regulation of Mercury Emissions,” Regulatory Analysis 05–01, American Enterprise Institute-Brookings Joint Center for Regulatory Studies, Washington, DC (2004). A version of this paper was publishe d in the Journal of Regulatory Economics in 2006. The estimate was derived by back-calculating the annual benefits per ton from the net present value of benefits reported in the study.

In accordance with U.S. Office of Management and Budget (OMB) guidance, DOE will

conduct two calculations of the m onetary benefits derived using each of the economic values

used for NO X 

### and Hg, one using a real discount rate of 3 percent and another using a real

discount rate of 7 percent. bb



### For more detail on the environmental assessment, refer to the environmental assessment report in the preliminary TSD.

2.17 REGULATORY IMPACT ANALYSIS

In the NOPR stage of this rulemaking, DOE expects to prepare a regulatory impact analysis (RIA) pursuant to Executive Order 12866 , “Regulatory Planning and Review,” 58 FR 51735 (October 4, 1993), which is subject to review under the Executive Order by the Office of Information and Regulatory Affairs at the Offi ce of Management and Budget. The RIA addresses the potential for non-regulatory approaches to supplant or augment energy conservation

bb OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003).



### 2-63

### standards to improve the energy efficiency or reduce the energy consumption of ballasts covered under this rulemaking.

Voluntary and other non-regulatory efforts by manufacturers, utilities, and other interested parties can result in substantial improvements to energy efficiency or reductions in energy consumption. DOE intends to consider th e likely effects of non-regulatory initiatives on ballast energy use, consumer utility, and LCCs. DOE will base its assessment on the actual impacts of any such initiatives to date, but also will consider information about the impacts that any existing initiative might have in the future.

In the framework document, DOE identified tw o sources of market failures: lack of consumer information and/or information pro cessing capabilities about energy efficiency opportunities in the lighting market, and asymmetric information and/or high transaction costs. The Joint Comment stated that DOE has accurately characterized some of the market failures in the framework document. However, the Joint Comment noted that other market failures characterized in a recent paper by ACEEE and ASAP might apply. The Joint Comment also emphasized that a market failure occurs when firms tend to consider capital costs and operating costs independently. For example, decision makers face more pressure to reduce capital costs than operating costs due to financial procedures or the time horizon of the current management. (Joint Comment, No. 12 at pp. 8-9)

DOE agrees with many of the market failu res identified in the recent paper by ACEEE, which the Joint Comment suggested DOE study. cc 

### In the framework document, DOE addressed many of the demand-side barriers characterized in the paper. These barriers include lack of awareness and uninformed decision makers (both symptoms of lack of consumer information and/or information processing capabilities), and third-party decision makers (a type of high transaction cost). However, DOE did not addre ss all barriers identified in the paper. These include financial procedures (or the time horizon of management) that over-emphasize initial costs and de-emphasize operatin g costs (as discussed in the Joint Comment), small per unit savings, limited stocking of effi cient products, efficiency bundled into premium products only, and manufacturer price competition. DOE agrees that all of these are potential market failures for fluorescent lamp ballasts that warrant agency action. As ASAP noted, it is important to examine market data rather than rely on theoretical a ssumptions about the marketplace. (ASAP, Public Meeting Transcript, No. 9 at p. 93) DOE agrees a nd therefore is continuing to seek data that

would enable it to conduct tests of these mark et failures. DOE requests comments and data on potential market failures for fluorescent lamp ballasts. For more information, refer to the regulatory impact analysis report in the preliminary TSD.

cc S. Nadel, A. DeLaski, M. Eldridge, and J. Kliesch, “Leading the Way: Continued Opportunities for New State Appliance and Equipment Efficiency Standards,” 2006. <http://www.standardsasap.org/documents/a062.pdf>.



### 2-64

### CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT

TABLE OF CONTENTS

3.1 INTRODUCTION

........................................................................................................... 3-1

3.1.1 Definitions

............................................................................................................ 3-1

3.1.2 Ballast Efficacy Factor

......................................................................................... 3-1

3.1.3 Fluorescent Lamp

................................................................................................. 3-2

3.1.4 Fluorescent Lamp Ballast

.................................................................................... 3-2

3.1.5 Replacement Ballast

............................................................................................. 3-4

3.2 MARKET ASSESSMENT

.............................................................................................. 3-4

3.2.1 Trade Associations

............................................................................................... 3-4

3.2.2 Manufacturers and Ma rket Share

......................................................................... 3-5

3.2.2.1 Small Businesses

...................................................................................... 3-5

3.2.3 Regulatory Programs

........................................................................................... 3-2

3.2.3.1 Federal Energy Conservation Standards

.................................................. 3-2

3.2.3.2 California Energy Commission

................................................................ 3-5

3.2.3.3 Canadian Energy Effici ency Standards

................................................... 3-5

3.2.3.4 European Energy Effici ency Standards

................................................... 3-7

3.2.4 Non-Regulatory Initiatives

................................................................................... 3-7

3.2.4.1 Federal Energy Management Program

.................................................... 3-7

3.2.4.2 Consortium for Energy Efficiency

........................................................... 3-8

3.2.4.3 NEMA Premium

...................................................................................... 3-9

3.2.4.4 ENERGY STAR

...................................................................................... 3-9

3.2.4.5 Energy Efficient Commercia l Building Deduction

.................................. 3-9

3.2.4.6 Northeast Energy Efficiency Partnerships

............................................. 3-10

3.2.5 Historical Shipments

.......................................................................................... 3-10

3.3 TECHNOLOGY ASSESSMENT

.................................................................................. 3-16

3.3.1 Basic Structure of Fluorescent Lamps

............................................................... 3-16

3.3.2 Electrical Characteristics of a Fl uorescent Discharge Lamp

............................. 3-17

3.3.3 Fluorescent Lamp Ballast Overview

.................................................................. 3-18

3.3.3.1 Starting Method

..................................................................................... 3-19

3.3.3.2 Ballast Factor

......................................................................................... 3-20

3.3.3.3 Ballast Efficacy Factor

........................................................................... 3-20

3.3.3.4 Power Factor

.......................................................................................... 3-20

3.3.3.5 Total Harmonic Distortion

..................................................................... 3-21

3.3.3.6 Electromagnetic In terferen ce

................................................................. 3-21

3.3.3.7 Safety

..................................................................................................... 3-22

3.3.4 Fluorescent Lamp Ballast Technology Options

................................................. 3-22

3.3.4.1 Magnetic Ballasts

................................................................................... 3-22

3.3.4.2 Electronic Ballasts

................................................................................. 3-23

3.3.4.3 Lamp Diameter

...................................................................................... 3-27

3.3.4.4 Improved Components

........................................................................... 3-27

3.3.4.5 Improved Circuit Design

........................................................................ 3-29

3.4 PRODUCT CLASSES

................................................................................................... 3-30

3-i

### 3.4.1 Lamp Length

...................................................................................................... 3-31

3.4.2 Lamp Diameter

.................................................................................................. 3-31

3.4.3 Ballast Factor

..................................................................................................... 3-32

3.4.4 Lumen Package

.................................................................................................. 3-32

3.4.5 Maximum Number of Lamps Operated

............................................................. 3-33

3.4.6 Starting Method

................................................................................................. 3-33

3.4.7 Input Voltage

..................................................................................................... 3-33

3.4.8 Universal Voltage

.............................................................................................. 3-34

3.4.9 Residential Ballasts

............................................................................................ 3-34

3.4.10 Sign Ballasts

....................................................................................................... 3-34

3.4.11 Product Classes

.................................................................................................. 3-35

REFERENCES

..................................................................................................................... ..... 3-36

LIST OF TABLES

Table 3.2.1 EPCA Standards for Fl uorescent Lamp Ballasts

...................................................... 3-2

Table 3.2.8 Shipments of Four-Foot T8 MBP and Two-Foot T8 U-Shaped Ballasts and Lamps

Table 3.2.9 Shipments of Eight-Foot Slimline T8 and Eight-Foot SP Slimli ne T12 Ballasts and

Table 3.3.2 Basic Building Blocks of a Fixed- Light Output Fluorescent Lamp Ballast and

Table 3.4.1 EPCA Product Classes Established by NAECA 1988 for Fluorescent Lamp Ballasts

Table 3.4.2 EPCA Product Classes Established by EPACT 2005 for Fluorescent Lamp Ballasts3­ Table 3.2.2 2000 Ballast Rule Standards for Fluorescent Lamp Ballasts

.................................... 3-3

Table 3.2.3 EPACT 2005 Standards for Fluorescent Lamp Ballasts

........................................... 3-4

Table 3.2.4 Canadian Standards for Fluorescent Lamp Ballasts

................................................. 3-6 Table 3.2.5 Federal Energy Management Pr ogram Efficiency Recommendation

...................... 3-8 Table 3.2.6 CEE High-Performance T8 Ballast Specifications

................................................... 3-8 Table 3.2.7 CEE Reduced Wattage T8 Ballast Specifications

.................................................... 3-9

and Four-Foot T12 MBP and Two-Foot U-Shaped Ballasts and Lamps

................................... 3-13

Lamps

.......................................................................................................................... ............... 3-14 Table 3.2.10 T12 High-Output Ballast Market Share

................................................................ 3-15

Table 3.3.1 Common Linear Fluoresce nt Lamp Nomenclature

................................................ 3-17

Associated Characteristics

..................................................................................................... .... 3-25

............................................................................................................................... ..................... 3-30

30 Table 3.4.3 Preliminary Produc t Classes for Fluorescent Lamp Ballasts

.................................. 3-35

LIST OF FIGURES

Figure 3.2.1 2005 Ballast Market Share

.................................................................................... 3-11 Figure 3.2.2 Magnetic and Electroni c Ballast Market Share

..................................................... 3-12 Figure 3.2.3 Shipments of Ballasts that Operate Four-Foot MBP Lamps

................................. 3-13

3-ii

### Figure 3.2.4 Shipments of Eight-Foot Slimline T8 and Eight-Foot SP S limline T12 Ballasts . 3-14 Figure 3.2.5 Shipments of Re sidential Ballasts

......................................................................... 3-15 Figure 3.2.6 Shipments of T5 High-Output Ballasts

................................................................. 3-16 Figure 3.3.1 Electrical Characteristic of a Gas Discharge Lamp

............................................... 3-18 Figure 3.3.2 Cutaway View of a Typical Magnetic Fluorescent Ballast

................................... 3-23 Figure 3.3.3 Fluorescent Lamp Efficacy vs . Operating Frequency of Lamp

............................ 3-24 Figure 3.3.4 Cutaway View of an Electronic Fluorescent Ballast

............................................. 3-24 Figure 3.3.5 Fixed-Light Output Electronic Fluorescent Ballast Block Diagram

..................... 3-25

3-iii

### CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT

3.1 INTRODUCTION

This chapter details the market and technolog y assessment that the U.S. Department of Energy (DOE) has conducted in support of the on going energy conservatio n standards and test procedure rulemakings for fluorescent lamp ba llasts. These rulemakings are mandated by the Energy Policy and Conservation Act (EPCA), as amended, and are effective for ballasts manufactured during and after 2014.

This chapter consists of three sections: the market assessment, the technology assessment, and product classes. The market a ssessment provides an overall picture of the market for the products concerned, including the na ture of the products, industry structure, and manufacturer market shares; regulatory and non- regulatory efficiency improvement programs; and market trends and quantitie s of products sold. The tec hnology assessment identifies a preliminary list of technologies to consider in the screening analysis. The product classes section discusses the product classes DOE considered us ing for this rulemaking and how they were developed.

The information DOE gathers from the mark et and technology assessment serves as resource material for use throughout the ru lemaking. DOE considers both quantitative and qualitative information from publicly availa ble sources and interested parties.

3.1.1 Definitions

Section 321 of EPCA contains definitions for fluorescent lamp ballast and associated

terms. DOE codified in the Code of Federal Regulations (CFR) the statutory definitions and definitions of supplementary terms for fluor escent lamp ballasts in 10 CFR 430.2. Appendix 3A

lists these terms and their definitions.

As part of this energy conservation standa rds rulemaking, DOE is considering extending coverage to additional fluores cent lamp ballasts. (42 U.S.C. 6295(g)(7)(B)) The following

sections describe in more deta il the definitions in EPCA for fluorescent lamp ballasts and note DOE’s interpretation of the definitions. Please se e chapter 2 of this preliminary technical support document (TSD) for more discussion on DOE’s c onsideration of additional fluorescent lamp ballasts and its interpretati on of EPCA’s definitions.

3.1.2 Ballast Efficacy Factor

Section 321(30)(A) of EPCA (42 U.S.C. 6291( 30)(A)) defines ballast efficacy factor (BEF) as:

Ballast efficacy factor means the relative light output divided by the power input of a fluorescent lamp ballast, as measured under test conditions specified in ANSI Standard

C82.2–1984.

3-1

### DOE is conducting concurrent rulemakings fo r an active mode test procedure and a standby mode test procedure for fluorescent lamp ballasts. Information on these rulemakings can

be found on DOE’s website. a 

### The test procedures specify how manufacturers measure and calculate ballast efficacy factor.

3.1.3 Fluorescent Lamp

Section 321(30)(A) of EPCA (42 U.S.C. 6291(30)(A)) defines a fluorescent lamp:

Fluorescent lamp means a low pressure mercury electric-discharge source in which a fluorescing coating transforms some of the ultraviolet energy generated by the mercury discharge into light, including only the following:

(1) any straight-shaped lamp (commonly referre d to as 4-foot medium bipin lamps) with medium bipin bases of nominal overa ll length of 48 inches and rated wattage of 25 or more; (2) any U-shaped lamp (commonly referred to as 2-foot U-shaped lamps) with medium bipin bases of nomin al overall length between 22 and 25 inches and rated wattage of 25 or more; (3) any rapid start lamp (commonly referred to as 8-foot high output lamps) with recessed double contact (RDC) bases of no minal overall length of 96 inches; (4) any instant start lamp (commonly referred to as 8-foot slimline lamps) with single pin bases of nominal overall length of 96 inches and rated wattage of 52 or more; (5) any straight-shaped lamp (commonly referred to as 4-foot miniature bipin standard output lamps) with miniature bipin bases of nomin al overall length

between 45 and 48 inches and rate d wattage of 26 or more; and (6) any straight-shaped lamp (commonly re ferred to 4-foot miniature bipin high output lamps) with miniature bipin base s of nominal overall length between 45

and 48 inches and rated wattage of 49 or more.

This definition, codified at 10 CFR 430.2, reflects the version adopted in the final rule for general service fluorescent lamps (the 2009 Lamps Rule). b 

### 74 FR 34080, 34176-77 (July 14, 2009).

3.1.4 Fluorescent Lamp Ballast

Fluorescent lamp ballast means a device that is used to start and operate fluorescent lamps by providing a starting voltage and current and limiting the current during normal operation.

a DOE’s website for fluorescent lamp ballasts can be found at http://www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_ballasts.html

. b The 2009 Lamps Rule was published in the Federal Register on July 14, 2009 and is available at http://www1.eere.energy.gov/buildings/appliance_standards/residential/incandescent_lamps.html

3-2

### As part of this rulemaking, under the authority of 42 U.S.C. 6295(i)(5), DOE is considering extending coverage to additional fluorescent lamp ballasts. In chapter 2 of the preliminary TSD, DOE considers extending energy conservation st andards coverage to the following list of fluorescent lamp ballasts:

(1) ballasts that operate one, two, three, fo ur, five, or six straight-shaped lamps (commonly referred to as 4-foot medium bi pin lamps) with medium bipin bases, a nominal overall length of 48 inches, a rated wattage c 

### of 25 watts (W) or more, and an input voltage at or between 120 volts (V) and 277V; (2) ballasts that operate one, two, three, four, five, or six U-shaped lamps (commonly referred to as 2-foot U-shaped lamps) w ith medium bipin bases, a nominal overall length between 22 and 25 inches, a rated wattage of 25W or more, and an input voltage at or between 120V and 277V; (3) ballasts that operate one or two rapid start lamps (commonly referred to as 8-foot high output lamps) with recessed double c ontact bases, a nominal overall length of 96 inches and an input voltage at or between 120V and 277V; (4) ballasts that operate one or two instant start lamps (commonly referred to as 8­ foot slimline lamps) with single pin bases, a nominal overall length of 96 inches, a rated wattage of 52W or more, and an input voltage at or between 120V and 277V; (5) ballasts that operate one or two straight-shaped lamps (commonly referred to as 4­ foot miniature bipin standard output lamps) with miniatu re bipin bases, a nominal length between 45 and 48 inches, a rated wattage of 26W or more, and an input voltage at or between 120V and 277V; (6) ballasts that operate one, two, three, or four straight-shaped lamps (4-foot miniature bipin high output lamps) with miniature bipin bases, a nominal length between 45 and 48 inches, a rated wattage of 49W or more, and an input voltage at or between 120V and 277V; (7) ballasts that operate one, two, three, or four straight-sha ped lamps (commonly referred to as 4-foot medium bipin lamp s) with medium bipin bases, a nominal overall length of 48 inches, a rated wattage of 25W or more , an input voltage at or between 120V and 277V, a power factor (PF) of less than 0.90, and that are designed and labeled for use in residential applications; and (8) ballasts that operate one, two, three, four , five, or six rapid start lamps (commonly referred to as 8-foot high output lamp s) with recessed double contact bases, a nominal overall length of 96 inches, an input voltage at or between 120V and 277V, and that operate at ambient temperat ures of 20 °F or less and are used in outdoor signs.

DOE is considering exempting the following ballasts:

(1) ballasts designed for dimming to 50 percen t or less of the maximum output of the

ballasts.

c The 2009 Lamps Rule adopted a new definition for rated wattage that can be found in 10 CFR 430.2.

3-3

### 3.1.5 Replacement Ballast

Replacement ballast means a ballast that

(1) is designed for use to replace an existing fluorescent lamp ballast in a previously installed luminaire; (2) is marked “FOR REPLACEMENT USE ONLY”; (3) is shipped by the manufacturer in packages containing not more than 10 fluorescent lamp ballasts; and (4) has output leads that when fully extended are a total length that is less than the length of the lamp with which the ballast is intende d to be operated.

3.2 MARKET ASSESSMENT

The following market assessment identifies the manufacturer trade association and

domestic manufacturers of fluores cent lamp ballasts; discusse s manufacturer market share, regulatory programs, and non-regulatory initiatives ; defines product classes; provides historical shipment data, shipment projections, and equipment lifetime estimates; and summarizes market performance data.

3.2.1 Trade Associations

The National Electrical Manufacturers Association (NEMA) is the trade association for fluorescent lamp ballasts. NEMA’s Lighting Syst ems Division is one of eight product divisions. The division’s 47 member companies comprise 85-95 percent of the U.S. commercial and industrial market, as well as large portions of the institutional a nd educational markets. 1 

### In addition to ballasts, NEMA’s Lighting System s Division also oversees products such as fluorescent lamps, emergency lighting, lighting controls, luminaires, solid state lighting, and other emerging lighting technologies. NEMA provides an organization through which manufacturers of lighting equipment can work together on projects that affect their industry and business. NEMA’s activities relating to energy efficiency include 2



### • “[a]dvising the DOE and executive agencies on lighting research and market transformation needs;

• engaging in legislative work on energy and lighting issues;

• monitoring energy-efficiency rulemakings a nd standards affecting lighting products by federal and state agencies;

• promoting the national voluntary luminaire rating and information program under the National Lighting Collaborative;

• supporting adoption of 1999 ASHRAE/IESNA 90.1 lighting provisions;

• working with market transfor mation and environmental groups to advance market use of energy-efficient lighting technologies;

3-4

### • advising DOE and the U.S. Environmenta l Protection Agency (EPA) on ENERGY STAR Buildings and ENERGY STAR voluntar y product labeling programs; and

• advocating market-based approaches to e nhance the use and penetration of energyefficient technologies.”

3.2.2 Manufacturers and Market Share

The following list contains the names of manuf acturers that produce fluorescent lamp ballasts:

•

•

• Acuity Brands Lighting

Advance Transformer

American Ballast •

• General Electric

Consumer &

Industrial

Hatch Transformer •

•

•

• PQL

Prescolite Progress Lighting

Radionic

•

•

•

•

•

•

•

•

•

• Antron Compact

Electronics Axis Technologies

Ballast Wise

Bodine

CEW Cooper Lighting

EBW Electronics Espen Technology,

Inc.

Etlin-Daniels

Fulham •

•

•

•

•

•

•

•

•

• Holophane

Howard Industries Iota Engineering Keystone Technologies Lamar Lighting

SOLA Ballasts Lighting Components Lightolier

Lutron Electronics Company, Inc.

MaxLite •

•

•

•

•

•

•

•

• Robertson Worldwide Sage Lighting Ltd. SLI Lighting Sunpark Electronics Corp. Superior Lamps, Inc.

TCP Ultrasave Lighting

Ltd. Universal Lighting Technologies

Ventex

• France •

• OSRAM Sylvania Pacific Lighting and

Electric •

• Venture Lighting

International

Wide-Lite

Four manufacturers hold the majority of the domes tic market share of fluorescent lamp ballasts

• GE Consumer and Industrial of Genera l Electric, Inc. (hereafter, “GE”)

• OSRAM Sylvania of Siemens AG (hereafter “Osram Sylvania”)

• Advance Transformer of Philips Lighting (hereafter “Advance”)

• Universal Lighting Technologies (hereafter “Universal”).

The lighting divisions of some of these co mpanies also manufacture other products, such as fluorescent lamps, high intensity discharge lamps, light emitting diodes (LEDs), and compact fluorescent lamps (CFLs).

3.2.2.1 Small Businesses

Small businesses may be particularly affect ed by the promulgation of minimum energy conservation standards for fluorescent lamp ba llasts. The Small Business Administration (SBA)

lists small business size standards that are matc hed to industries as they are described in the North American Industry Classification System (NAI CS). A size standard is the largest that a

3-5

### for-profit concern can be and still qualify as a small business for Federal Government programs. These size standards are generally the average annual receipts or the average employment of a firm. For fluorescent lamp ballasts, the si ze standard is matc hed to NAICS code 335311, Power, Distribution, & Specialty Transformer Manufacturing , which has a size standard of 750 employees or fewer. 3



### DOE will study the potential impacts on these small businesses in detail during the manufacturer impact analysis, which it will conduct as part of the notice of proposed rulemaking.

3.2.3 Regulatory Programs

Several Federal and international regulatory programs affect the markets for fluorescent lamp ballasts. The following section summarize s U.S., Canadian, and European regulatory initiatives relevant to the ballasts covered by this rulemaking. While the following discussion is not exhaustive in describing all regulatory acti on related to fluorescent la mp ballasts, it provides

detail on some notable initiatives that characterize recent developments in the lighting market.

3.2.3.1 Federal Energy Conservation Standards

EPCA (42 U.S.C. 6291–6309) established an energy conservation program for major household appliances. Additional amendments to EP CA gave DOE the authority to regulate the energy efficiency of several products, including certain fluorescent lamp ballasts. Amendments to EPCA in the National Appliance Energy Conservation Amendments of 1988 (NAECA 1988), Pub. L.100357, established energy conservation standards for fluorescent lamp ballasts. d 

### (42

U.S.C. 6295(g)(5)) The standards promulgated by NAECA 1988 can be found in Table 3.2.1. These amendments also required that DOE (1) conduct two rulemaking cycles to determine whether these standards should be amended; a nd (2) for each rulemaking cycle, determine

whether the standards in effect for fluorescent lamp ballasts s hould be amended so that they would be applicable to additional fluorescent lamp ballasts. (42 U.S.C. 6295(g)(7)(A)(B))

Table 3.2.1 EPCA Standards for Fluorescent Lamp Ballasts

d Although fluorescent lamp ballasts are typically understood to be used in the commercial and industrial sectors, it is the “consumer products” section of the statute that gran ts 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,” two parts cluster the group of products DOE regulates. “Part A – Energy Conservation Program for Consumer Products Other than Automobiles” 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 consum er 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 A1– 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.

3-2Application for Operation of Ballast Input Voltage

V Total Nominal Lamp Watts

W Ballast Efficacy

Factor

One F40T12 Lamp 120 40 1.805

277 40 1.805

Two F40T12 Lamps 120 80 1.060

277 80 1.050

Two F96T12 Lamps 120 150 0.570

277 150 0.570 Two F96 T12 High Output 120 220 0.390 (HO) Lamps 277 220 0.390



### On September 19, 2000, DOE published a final rule in the Federal Register that 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 a dvocacy organizations. The standard levels DOE adopted replaced the ballast efficacy factors promulgated in NAECA 1988 for certain fluorescent lamp ballasts. The standard levels were intended to eliminate certain magnetic ballasts, which operate lamps at a line frequency of 60 Hertz (Hz), and are less e fficient than electronic ballasts, which operate lamps at high frequency for ballasts that operate F40T12 and F96T12 lamps. e 

### Table 3.2.2 shows the standards codified by DOE. 10 CFR 430.32(m)(3)

Table 3.2.2 2000 Ballast Rule Standards for Fluorescent Lamp Ballasts

Application for Operation of Ballast Input Voltage

V Total Nominal Lamp Watts

W Ballast Efficacy

Factor

One F40T12 Lamp 120 40 2.29

277 40 2.29

Two F40T12 Lamps 120 80 1.17

277 80 1.17

Two F96T12 Lamps 120 150 0.63

277 150 0.63

Two F96 T12 HO Lamps 120 220 0.39

277 220 0.39



### Due to the language in the consensus standard that DOE adopted in the 2000 Ballast Rule, it was still be possible for manufacturers to produce and sell magnetic ballasts for certain types of fluorescent lamps. In response, Co ngress promulgated new energy conservation standards for certain fluorescent lamp ballast s under the Energy Policy Act of 2005 (EPACT 2005), Pub. L. 10958. (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 ba llast efficacy requirements for “energy

e The standard level was intended to eliminate magnetic ballasts that operate one and two nominally 40W medium bipin lamps (F40T12) and two nominally 75W 8-foot T12 single pin slimline lamps (F96T12).

3-3

### saver” versions of full-wattage ballasts, such as the F34T12 ballast. Table 3.2.3 shows the standards prescribed by EPACT 2005. 10 CFR 430.32(m)(5)

Table 3.2.3 EPACT 2005 Standards for Fluorescent Lamp Ballasts

Application for Operation of Ballast Input Voltage

V Total Nominal Lamp Watts

W Ballast Efficacy

Factor

One F34T12 Lamp 120 34 2.61

277 34 2.61

Two F34T12 Lamps 120 68 1.35

277 68 1.35

Two F96T12/ES Lamps 120 120 0.77

277 120 0.77

Two F96 T12 HO/ES Lamps 120 190 0.42

277 190 0.42



### In summary, fluorescent lamp ballasts that are currently regulated under EPCA, as amended, include ballasts that are designed to operate one and two nominally 40W and 34W 4­ foot T12 medium bipin lamps (F40T12 and F34T 12), 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 RDC high output lamps (F96T12 and F96T12/ES) at nominal input voltages of 120 or 277 volts with an input current frequency of 60 Hz and a power factor of 0.90 or greater. 10 CFR 430.32(m). Ballasts that are excluded from regula tion include (1) ballasts designed for dimming to 50 percent or less of its maximum output, (2) ballasts designed for use with two F96T12 high output (HO) lamps at ambient temperatures of 20 °F or less and for use in an outdoor sign or ballasts designed for use with two F96T12 HO/ES lamps at ambient temperatures of 20 °F or less and for use in an outdoor sign, f 

### (3) ballasts with a power factor of less than 0.90 and designed and labeled for use only in residen tial building applications, and (4) replacement

ballasts as defined in paragraph (m)(4)(ii). g 

### 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. 110140), 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 amend its test procedure for fluorescent lamp ball asts to incorporate a measure of standby mode and off mode energy consumption by March 31, 2009. (42 U.S.C. 6295(gg)(2)(B)(ii)) In addition, pursuant to 42 U.S.C. 6295(o), DOE is di rected to incorporate standby mode and off

f 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°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°F

or less.

g The exclusion provided for replacement ballasts requires that they meet certain cr iteria 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 of this TSD for the exact language of the exclusion for replacement ballasts.

3-4

### mode energy use in any amended or new sta ndard 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.

DOE published a final rule test procedure to comply with the standby mode and off mode energy use provisions from EISA 2007 that apply to fluorescent lamp ballasts that are (or could be) covered by this rulemaking. DOE stated in that final rule that standby mode energy use, as defined in EISA 2007, h 

### is nonexistent for typical ballasts that operate on a switch or a motion sensor. DOE also stated that standby mode ener gy use is only applicable to ballasts with a lighting control system. One example of these new ballast designs is a DALI i 

### -enabled ballast. DALI-enabled ballasts exhibit standby power, as they have internal circuitry that is integral to the design of the ballast that remains on and ac tive, even when the ballast is not driving any lamps. DOE noted that fluorescent lamp ballast s never meet the definition of “off mode.”

Pursuant to EPCA section 325(gg)(2)(A), 42 U.S.C. 6295(gg)(2)(A), DOE is evaluating whether to incorporate standby mode into a single amended or new metric. DOE is also evaluating whether to include standby mode standa rds in this rulemaking. For more information, see chapter 2 of the preliminary TSD.

3.2.3.2 California Energy Commission

The California Energy Commission (CEC) specifies appliance standards that are “applicable as state law to the sale and offe ring for sale of appliances in California.” 4 

### The current standards took effect on December 29, 2007. The CEC is currently undergoing a rulemaking to revise the existing standards.

3.2.3.3 Canadian Energy Efficiency Standards

The Natural Resources Canada (NRCan) Office of Energy Efficiency regulates the energy efficiency of fluorescent lamp ballasts in Canada. In 1992, Parlia ment passed the Energy Efficiency Act (S.C. 1992, c. 36), which concerns minimum performance levels for energy-using products, effective in February 1995. Fluorescent la mp ballasts were include d in the first set of energy efficiency regulations, published in November 1994. 5 

### An amendment published in April 2003 updated Canada’s regulations to the minimum le vels put forth in the 2000 Ballast Rule. It

h In amending 42 U.S.C. 6295(gg)(1)(a)(i), (ii), and (iii) , section 310 of EISA 2007 defines “active mode,” “off mode,” and “standby mode” as follows: “The term ‘active mode’ means the condition in which an energy-using product—(I) is connected to a main power source; (II) has been activated; and (III) provides 1 or more main

functions.” “The term ‘off mode’ means the condition in which an energy-using product— (I) is connected to a main power source; and (II) is not providing any standby or active mode function.” “The term ‘standby mode’ means the condition in which an energy-using product (I) is connected to a main power source; and (II) offers 1 or more of the following user-oriented or protective functions: (aa) To facilitate the activation or deactivation of other functions (including active mode) by remote switch (including remote control), internal sensor, or timer. (bb) Continuous functions including information or status displays (including clocks) or sensor-based functions.”

i DALI stands for Digital Addressable Lighting Interface, which is a system that enables communication between a central lighting controls system and the individual components, including the ballasts.

3-5

### also proposed two effective dates: April 1, 2005 for new installations and April 1, 2010 for existing installations (replacement ballasts). 6 

### Amendment 9, published in the Canadian Gazette Part II on November 15, 2006, introduced standards for ballasts that operate energy-saving lamps and F32T8 lamps, modified the criteria for exempted ballasts, and repealed the effective date for fluorescent lamp ballasts. 7 

### Table 3.2.4 8 

### shows the current Canadian standards for fluorescent lamp ballasts.

Table 3.2.4 Canadian Standards for Fluorescent Lamp Ballasts

Application for Operation of Ballast Input Voltage

V Total Nominal Lamp Wattage |

W Minimum Ballast Efficacy Factor

Level 1 j Level 2 k

One F40T12 Lamp 

### * 120 40 1.805 2.29

277 40 1.805 2.29

347 40 1.750 2.22

One F34T12 Lamp 120 34 1.805 2.61

277 34 1.805 2.61

347 34 1.750 2.53

Two F40T12 Lamps 120 80 1.060 1.17

277 80 1.050 1.17

347 80 1.020 1.12

Two F34T12 Lamps 120 68 1.060 1.35

277 68 1.050 1.35

347 68 1.020 1.29

Two F96T12(IS) Lamps 

### ** 120 150 0.570 0.63

277 150 0.570 0.63

347 150 0.530 0.62

Two F96T12(ES) Lamps 120 120 0.570 0.77

277 120 0.570 0.77

347 120 0.530 0.76

Two 110W F96T12 HO Lamps 120 220 0.390 0.390

277 220 0.390 0.390

347 220 0.380 0.380

Two F96T12 HO(ES) Lamps 120 190 0.390 0.42

277 190 0.390 0.42

347 190 0.380 0.41

Two F32T8 Lamps 120 64 1.250 1.250

277 64 1.230 1.230

347 64 1.200 1.200 *Also for use on 40W/48T10/RS lamps **Also for use on 60W/96T12/IS lamps



### The Canadian standards listed above apply to residential as well as commercial ballasts.

Canadian standards consider an input voltage of 347V in a ddition to 120V and 277V, which is

consistent with the Canadian el ectrical distribution network. Cana dian standards also require a

j The Level 1 effective date is April 1, 2005 for replacement ballasts.

k The Level 2 effective date for new installation ballasts is February 3, 1995; the Level 2 effective date for replacement ballasts is April 1, 2010.

3-6

### minimum power factor of 0.9 (consistent with U.S. standards) fo r all ballasts except residential

ballasts.

3.2.3.4 European Energy Efficiency Standards

Directive 2005/32/EC of the European Parliame nt and the Council of the European Union

amended Council Directive 92/42/EEC and Directives 96/57/EC and 2000/55/EC to establish a framework for setting energy efficiency requirements for energy-using products. Energy efficiency standards for fluorescent lamp ballasts have yet to be published.

3.2.4 Non-Regulatory Initiatives

DOE reviewed several national, regional, a nd local voluntary programs that promote the use of energy efficient lighting in the United States. These include the Federal Energy Management Program’s (FEMP’s) program for energy efficient lighting, the Consortium for Energy Efficiency’s (CEE’s) High Performance Commercial Lighting Initiative, the ENERGY STAR Program, and the Northeast Energy Effici ency Partnership (NEEP). The following section summarizes some of these programs for the ballasts covered by this rulemaking. While it is not an exhaustive list, the discussion provides detail on some notable initiatives that characterize recent developments in the lighting market.

3.2.4.1 Federal Energy Management Program

FEMP helps Federal buyers identify and purchase energy efficient products including

certain fluorescent ballasts. Section 161 of EP ACT 1992 encourages energy efficient Federal procurement. Section 104 of EPACT 2005 require s that each agency incorporate energy efficiency criteria consistent with ENERGY ST AR and FEMP-designate d products for “...all procurements involving energy consuming products and systems, including guides specifications, project specifica tions, and construction, renovation, and service contracts that include provision of energy consuming products and systems, and into the factors for the evaluation of offers received for the procurement.” Executive Order 13123 and Federal Acquisition Regulation (FAR) section 23.704 direct agencies to purchase products in the upper 25 percent of energy efficiency, including all models that qualify for the ENERGY STAR product labeling program. 64 FR 30851, 30854 (June 8, 1999). FEMP provides recommendations for how to buy energy efficien t fluorescent ballasts, including the products

shown in Table 3.2.5. 9 

### FEMP offers buyers support tools su ch as efficiency guidelines, costeffectiveness examples, and a cost calculator. FEMP also offers training, on-site audits, demonstrations, and design assistance.

3-7

### Table 3.2.5 Federal Energy Management Pr ogram Efficiency Recommendation

Lamp Type Number of Lamps Recommended BEF Best Available BEF

Four-Foot and U-Tube Lamps

T8, 32 Watts 1 2.54 or higher 3.00

2 1.44 or higher 1.54

3 0.93 or higher 1.06

4 0.73 or higher 0.79

T12, 34 Watts 1 2.64 or higher 3.05

2 1.41 or higher 1.53

3 0.93 or higher 0.95 Eight-Foot Lamps
T8, 59 Watts 2 0.80 or higher 0.81
T12, 60 Watts 2 0.80 or higher 0.80



### 3.2.4.2 Consortium for Energy Efficiency

CEE has both a Residential Lighting Initiative and a High-Performance Commercial Lighting Initiative. CEE launched its commercial lighting initiativ e in November 2004 to help identify and select energy efficient commercia l lighting products and practices. Initial efforts focused on designating high-performance T8 lighting products. In January 2007, the initiative was expanded to include redu ced-wattage T8 products. Ta ble 3.2.6 and Table 3.2.7 summarize CEE’s specifications for high-performance and reduced-wattage T8 ballasts.

Table 3.2.6 CEE High-Performance T8 Ballast Specifications 10

Instant Start Ballast

Lamps Low BF

BF ≤

0.85 Normal BF

0.85<BF<1.0 High BF

BF ≥ 1.01

1 ≥ 3.08 ≥ 3.11 n/a

2 ≥ 1.60 ≥ 1.58 ≥ 1.55

3 ≥ 1.04 ≥ 1.05 ≥ 1.04

4 ≥ 0.79 ≥ 0.80 ≥ 0.77 Programmed Rapid Start Ballast

1 ≥ 2.84 ≥ 2.84 n/a

2 ≥ 1.48 ≥ 1.47 ≥ 1.51

3 ≥ 0.97 ≥ 1.00 ≥ 1.00

4 ≥ 0.76 ≥ 0.75 ≥ 0.75 Ballast Frequency 20 to 33 kHz or ≥ 40 kHz, Power Factor ≥ 0.90, Total Harmonic Distortion ≤

20%

3-8

### Table 3.2.7 CEE Reduced Wattage T8 Ballast Specifications 11

Instant Start Ballast, 28W Systems Lamps All BF Ranges

1 ≥ 3.52

2 ≥ 1.76

3 ≥ 1.16

4 ≥ 0.88 Instant Start Ballast, 25W Systems

1 ≥ 3.95

2 ≥ 1.98

3 ≥ 1.32

4 ≥ 0.99 Ballast Frequency 20 to 33 kHz or ≥ 40 kHz, Power Factor ≥ 0.90, Total

Harmonic Distortion ≤ 20%



### CEE created separate standards for normal wattage T8 ballasts ba sed on ballast factor, which compares the ratio of light output of la mps operated by a specific ballast to the light output of the same lamps operate d by a standard reference balla st. However, CEE chose not to create standards by ballast factor for reduced-wa ttage ballasts. A dditionally, CEE did not specify performance based on input voltage. CEE’s specifications state that multi-voltage ballasts must meet or exceed the listed BEF when operating on at least one of the intended operating voltages.

3.2.4.3 NEMA Premium

NEMA maintains a labeling program for “NEMA Premium” ballasts based on CEE’s specifications for high-efficiency 4-foot T8 ballasts. The program is intended to promote energy efficiency and assist end-users in identifying the most efficient ballasts on the market. 12 

### As of March 2009, NEMA’s website indicates that ballast s manufactured by Acuity Brands Lighting, Advance, American Ballast, Espen Technologies, GE, Osram Sy lvania, Robertson Worldwide, Technical Consumer Products, and Universa l all qualify for the NEMA Premium label.

The NEMA Premium label for fluorescent lamp ballasts is similar to NEMA’s existing program for motors. In November 2004, NEMA releas ed state-level shipment data that showed an increase in NEMA Premium motor shipme nts of 30 percent between 2001 and 2002 and 14 percent between 2002 and 2003. 13



### 3.2.4.4 ENERGY STAR

ENERGY STAR is a joint program of DOE and the Environmental Protection Agency (EPA) designed to protect the environment by promoting energy efficient products and practices. 14 

### ENERGY STAR specifies criteria for resi dential lighting fixtures, which contain three parts: a lamp, a ballast, and the fixture th at holds the lamp and ba llast. Products that qualify for the ENERGY STAR label may not use magnet ic ballasts in indoor fixtures. The ENERGY STAR specifications also define criteria for lamp start time, power factor, lamp current crest factor, ballast operating temperature, electrom agnetic interference, frequency, transient protection, end of life prot ection, dimming, and safety. 15



### 3.2.4.5 Energy Efficient Commercial Building Deduction

3-9

### EPACT 2005 created the Energy Efficient Commercial Buildings Deduction (26 U.S.C 179D), which establishes a tax deduction for building owners who incur expenses for energy efficiency upgrades. Effective for property in service from January 1, 2006 through December 31, 2008, the deduction allows partia l deductions for improvements in interior lighting. Though the statute does not specify required lamp types or efficacies, it does call for an overall reduction in lighting power density, encouraging the use of higher-performance and reduced-wattage fluorescent lamps. The Emergency Economic Stabilization Act of 2008 (HR-1424), approved and signed on October 3, 2008, extends the benefits of EPACT 2005 through December 31,

2013.

3.2.4.6 Northeast Energy Efficiency Partnerships

NEEP is a regional nonprofit organization that promotes energy efficiency in the Northeast. NEEP runs a High Efficiency Commercial Lighting Initiative to “achieve costeffective energy and demand by overcoming market barriers to the availability and widespread market adoption of advanced T8 fluorescent lighting systems.” 16 

### NEEP coordinates with multiple local and state governments, utilities, a nd other initiatives, such as Efficiency Vermont l


### and the Long Island Power Authority, to promote efficient lighting products. 17, 18



### 3.2.5 Historical Shipments

Awareness of annual product sh ipment trends is an importa nt aspect of the market assessment and the development of the standards rulemaking. For this rulemaking, DOE used publicly available ballast shipments from the U.S. Census from 1990 to 2005. 19 

### DOE also obtained confidential shipments from NEMA for 2007.

DOE used this data for three main purposes. First, the shipment data and market trend information contributed to the shipments analysis and base-case forecast for ballasts (chapter 9 of the preliminary TSD). By using historical shipment data and expert opinion on market trends and calibrating forecast assumptions with recen t data, DOE believes it has based the shipments

model and base-case forecasts on a sound dataset. Second, DOE used the data to select the representative product classes and representative units for analysis. Generally, DOE selected product classes and units to reflect the highest volume, most common ballast types used in the United States today (chapter 5 of the preliminary TSD). Third, DOE used the data to develop the installed stock of ballasts for the national impact analysis (chapter 10 of the preliminary TSD). Based on its understanding of trends in the market, DOE estimated how the market would respond to various candida te standard levels.

The historical shipment data for ballast s is broken down into many subcategories beginning with magnetic versus electronic ty pe ballasts. Under each technology type, the shipments are categorized by a variety of characteristics. Commercial and residential ballasts are delineated by corrected versus uncorrected power factor (section 3.3.3.4). Ballasts are also

l Efficiency Vermont offers technical assistance and financial incentives to encourage energy efficiency in Vermont. This organization offers rebates ranging from $10 to $50 for the upgrade to or installation of High Performance T8

systems.

3-10

### defined by starting method (sec tion 3.3.3.1), maximum number of lamp s driven (one, two, three, or four), lamp wattage, lamp diameter, and a few additional specific characteristics. Based on

interviews with ballast manufacturers, DOE learned that the U. S. Census data represents about 90 percent of T8 and T5 shipments and about 70 percent of T12 electronic shipments. DOE also

learned that the U.S. Census does not include sh ipment data for major residential ballasts or dimming ballasts. The Census data also does not provide shipments for every permutation of ballast performance characteristics, but does provide data for establishing trends for the major categories. Ballasts that operate T8 lamps comprised the majority of shipments in 2005. These are followed (in order of 2005 unit sales) by T12 ba llasts, compact fluorescent lamp ballasts, T5 ballasts, and other small subsets.

Figure 3.2.1 depicts the ballast market based on shipments reported to the U.S. Census in

2005.

Figure 3.2.1 2005 Ballast Market Share

In 2005, corrected power-factor (commercial) magnetic ballasts were not broken out into smaller categories for shipments reporting. DOE used subcategory unit shipment proportions from the 2000 corrected power-factor magnetic balla st category to extrapolate the disaggregation of shipments for 2005. This estimation provided da ta points for 4- and 8-foot magnetic T12

ballasts as well as 8-foot HO ma gnetic T12 ballasts. The 2005 U.S. Census Data also did not report magnetic residential and linear dimming ballast shipments. To estimate magnetic residential ballast shipments, DOE extended the linear decline in magnetic residential ballasts from 2002-2004 to extrapolate a value for 2005. DOE used a similar approach to estimate linear dimming ballast shipments.

Electronic ballasts have slowly replaced magne tic ballasts, as seen in Figure 3.2.2. In 1990, magnetic ballasts repres ented about 96 percent of shipment s, while the 2005 ma gnetic ballast market share dropped to 27 percent. This trend was in part due to energy conservation standards

3-11

### for T12 ballasts. The most recent energy conservation standards for fluorescent lamp ballasts effectively eliminated the sale of 4-foot T12 medium bipin (MBP), 2-foot T12 U-shaped, and 8­ foot T12 slimline magnetic ballasts. The standard began to go into effect for certain 4-foot T12 MBP, 8-foot T12 slimline ballasts, and 8-foot HO ballasts in 2005. The final phase of the standard will be effective in 2010, when replacem ent 4-foot T12 MBP, 8-foot T12 single pin (SP) slimline, and 8-foot HO magn etic ballasts will no longer be sold. (10 CFR 430.32(m)(4)(ii) and 430.32(m)(5)-(6))

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%Market Share

Magnetic

Electronic



### 1989 1991 1993 1995 1997 1999 2001 2003 2005

Year



### Figure 3.2.2 Magnetic and Electronic Ballast Market Share

The vast majority of 4-foot T12 MBP and 2-foot T12 U-shaped ballasts are magnetic (about 77 percent of the T12 market in 2005), and th e vast majority of 4-foot T8 MBP and 2-foot T8 U-shaped ballasts are electronic (about 97 percent of T8 ballast shipments in 2005). Therefore, the decline in magnetic ballasts mirrors a decline in T12 ballast shipments. Similarly,

the increase in electronic ballasts mirrors an increa se in 4-foot T8 MBP and 2-foot T8 U-shaped ballast shipments. Figure 3.2.3 and Table 3.2.8 show these shipment trends. The trend in ballast shipments is followed by similar trends in 4-foot T8 MBP and 2-foot T8 U-shaped lamp shipments and 4-foot T12 MBP and 2-foot T12 U- shaped lamp shipments. DOE received general service fluorescent lamp historical shipments from NEMA from 2001 to 2005. 20 

### Based on conversations with manufacturers, DOE believes these trends continue beyond 2005.

3-12

### 0 5,000 10,000 15,000 20,000 25,000 30,000 35,000 40,000 45,000 50,000

1994 1996 1998 2000 2002 2004 2006Shipments



## Year T8s

T12s

Figure 3.2.3 Shipments of Ballasts that Operate Four-Foot MBP Lamps

Table 3.2.8 Shipments of Four-Foot T8 MBP and Two-Foot T8 U- Shaped Ballasts and Lamps and Four-Foot T12 MBP and Two-Foot U-Shaped Ballasts and Lamps

Unit Sales by Year

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005

Four-Foot

T12

Ballast (D) (D) 27,227 27,704 26,395 24,463 (D) (D) (D) (D) 11,218

Four-Foot

T8 Ballast 23,965 22,317 28,032 30,883 32,488 40,179 44,700 44,215 43,219 45,727 45,951

Four-Foot T8 Lamp (D) (D) (D) (D) (D) (D) 172,143 170,416 179,312 204,922 224,189

Four-Foot T12 Lamp (D) (D) (D) (D) (D) (D) 222,236 215,312 191,391 182,864 171,503

(D) indicates data not made public.



### Table 3.2.9 shows similar trends for 8-foot T12 and T8 SP slimline ballasts and lamps. In general, 8-foot SP slimline T12 ballasts and lamps are experiencing a decrease in shipments, whereas 8-foot SP slimline T8 ballasts and lamps are experiencing an increase in shipments. The increase in shipments for 8-foot SP slimline T8 lamps is smaller than for 4-foot T8 shipments. According to manufacturers and lighting experts, this is because a portion of the 8-foot T12 SP slimline ballast market is being transferred to the 4-foot T8 ballast market.

3-13

### Figure 3.2.4 Shipments of Eight-Foot Slimline T8 and Eight-Foot SP Slimline T12 Ballasts

Table 3.2.9 Shipments of Eight-Foot Slimline T8 and Eight-Foot SP Slimline T12 Ballasts and Lamps

Unit Sales by Year

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005
Eight-Foot

Slimline T12

Ballast 7,394 6,612 6,268 6,601 6,638 5,813 (D) (D) (D) (D) 2,599

Eight -Foot

Slimline T8

Ballast 932 847 961 959 1,020 1,160 1,547 1,560 1,218 1,214 1,224

Eight -Foot

Slimline T12 Lamp (D) (D) (D) (D) (D) (D) 43,2 65 41,443 37,170 36,263 33,636

Eight -Foot

Slimline T8 Lamp (D) (D) (D) (D) (D) (D) 4,405 5,300 5,183 5,727 5,176

(D) indicates data not made public.



### Table 3.2.10 shows that T12 high-output ballast shipments decreased from 1995 to 2005. Data for high output ballasts were not repor ted in 1997 or from 2001 to 2005. DOE estimated the 2005 market share using the method described earlie r. A portion of the ballasts listed in Table

3.2.10 are rated for cold-temperature outdoor sign age applications, which were excluded from previous energy conservation standards. The Census data for high output ballasts are not exclusive to ballasts that operate 8-foot RD C HO lamps, but information from manufacturers indicates these ballasts represent most of the high output market. Discussions with lighting experts and lamp manufacturers indicate that th ey expect any migration of the 8-foot RDC HO market to go toward T5 HO fluorescent systems and metal halide systems. High output ballast shipments likely follow a similar trend to the 8-foot HO lamp shipments. Both ballast and lamp

3-14Unit Sales by Year*

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 Eight-Foot

T12 RDC

HO Ballast 3,538 3,322 (D) 2,305 3,089 2,682 (D) (D) (D) (D) 1,199

Eight-Foot

T12 RDC HO Lamp 23,887 24,398 24,206 24,591 25,442

Eight-Foot

T8 RDC HO Lamp 691 647 467 674 420

(D) indicates data not made public. 

### shipments show the high output market share is much smaller than for 8-foot slimline T8 and T12 ballasts and lamps.

Table 3.2.10 T12 High-Output Ballast Market Share

* Data from 1995 and 1996 include electronic and magnetic ballast shipments. Data from 1997-2005 include only magnetic shipments. Lamps shipments are available for 2001-2005 only.



### Based on public data, Figure 3.2.5 shows magne tic residential balla st shipments have

decreased from 1995 to 2004. m 

### Shipments data for this category were unavailable for 2005. Because the major manufacturers in the residentia l sector are not members of NEMA, shipments in the residential sector are likely larger than t hose reported in the U.S. Census data. Residential ballasts have been excluded from energy conservation sta ndards to date.

14,000

12,000

10,000

8,000Shipments



### 6,000

4,000

2,000

0

1988 1990 1992 1994 1996 1998 2000 2002 2004 2006



### Year



### Figure 3.2.5 Shipments of Residential Ballasts

m

U.S. Census data does not report shipments of electronic residential (low-power-factor) ballasts.

3-15

### T5 ballasts have been growing steadily si nce reported shipments began in 2002 (Figure 3.2.6). T5 normal output ballast shipments were not reported in the U.S. Census data.

Conversations with balla st manufacturers indicated some gr owth in normal output T5 ballasts due to replacements of 4-foot electronic T8 ballasts. In add ition, manufacturers indicated that significant growth in T5 ballast shipments has been driven by 4-lamp T5 high output ballast systems replacing high-bay metal halide systems in the industrial sector. Based on information from ballast manufacturers, DOE believes these trends continued beyond 2005.

Figure 3.2.6 Shipments of T5 High-Output Ballasts

3.3 TECHNOLOGY ASSESSMENT

The purpose of the technology assessment is to develop a preliminary list of technologies that could be used to improve the efficiency of fluorescent lamp ballasts. The following assessment provides a description of the basic co nstruction and operation of the fluorescent lamp and fluorescent lamp ballast, followed by technology options to improve efficiency.

3.3.1 Basic Structure of Fluorescent Lamps

The fluorescent lamp is a low-pressure gas discharge source. The lamps are tubular in shape and available in a variety of lengths, diameters, and wattages.

Lamp types are designated by a series of le tters and numbers. The letter “F” is used to designate a fluorescent lamp. It is followed by a two-digit number that identifies either the nominal lamp wattage for nominally 4-foot lamps or the lamp length in inches for 8-foot lamps. These digits are followed by the letter “T,” for tubular, which is followed by the lamp diameter

3-16

### in eighths of an inch. Additional designations are sometimes used: for example, “HO” if the lamp is high output or “/ES” if the lamp is an energy saver or reduced-wattage lamp. Table 3.3.1

shows the nomenclature that defines the diamet er, lamp length, and la mp wattage for some common fluorescent lamps.

Table 3.3.1 Common Linear Fluorescent Lamp Nomenclature

Lamp Nomenclature Nominal Lamp Length feet Nominal Lamp Wattage

W Lamp Diameter

inches

F32T8 4 32 1

F40T12 4 40 1 1⁄2

F54T5 HO 4 54 5/8

F96T12 8 75 1 1⁄2

F96T12 HO 8 110 1 1⁄2

F96T12 HO/ES 8 95 1 1⁄2



### The fluorescent lamp consists of a glass bulb or tube, filled with low pressure mercury vapor and inert gas, with electrodes sealed onto both ends of the tube. The fluorescent lamp has five major components: bulb, el ectrodes, base, gas fill, a nd phosphors. Two electrodes are hermetically sealed to both ends of the bulb. The electrodes are usually constructed from coiled tungsten wires coated with a mixture of alkalin e oxides. A base provides an electrical connection to these electrodes and also supports the lam p. Depending on the star t method and operational properties of the lamp ( e.g. , dimming, wattage, etc.), lamp designs may use different bases such as SP, MBP, and RDC. Once voltage is applied to the electrodes, the tungsten coil and coatings emit large quantities of electrons when the co ating is at the proper temperature (1,000–1,300 K). These electrons then collide with gaseous mercury atoms, exciting electrons within those atoms. As the electrons decay to their stable or gr ound state, they emit UV radiation primarily at 254 nanometers (nm). In addition to the mercury vapor, an inert gas or a combination of gases is added to the lamp primarily to moderate the collisions of mercury ions and minimize evaporation of the electrode coating. The UV radiation is then absorbed by the phosphors and reemitted as light.

3.3.2 Electrical Characteristics of a Fluorescent Discharge Lamp

Regardless of shape, size, or type, all fluorescent lamps require a ballast to initiate and maintain the arc discharge.

To achieve arc formation, the gas plasma ha s to be excited, ionized, and broken down (to become a virtual negative resistance, almost a sh ort circuit). This requires an initial high cathode emission and a high electric field ( i.e. , voltage). Once the arc is achieved, current limiting has to be involved to prevent run-away and almost immediate lamp burnout. These two phenomena,

i.e. , ignition and current limiting/control, are required in all fluorescent lamps, regardless of shape, size, or type. Both functions constitute the major function of a ballast. Figure 3.3.1 shows a graphical representation of this relationship from ignition (Townsend, glow, and abnormal glow) through arc discharge.

3-17Current(I)



## Voltage (V) Arc

Abnormal Glow

Glow

Townsend Target Region

Undesirable

RegionCurrent(I)



## Voltage (V) Arc

Abnormal Glow

Glow

Townsend Target Region

Undesirable

Region



### Figure 3.3.1 Electrical Characterist ic of a Gas Discharge Lamp
Source: Adapted from Murdoch, Illuminating Engineering: From Edison’s Lamp to the LED , 2nd Edition, 2003.



### A voltage pulse several times that of the lamp operating voltage may be required to initiate the arc discharge. During this process, the lamp’s operating point must pass through the Townsend, glow, and abnormal-glow as quickly as possible. Rapid star t (RS) and programmed start (PS) systems use tertiary cathode heating to catalyze this process, while instant start (IS) operation simply uses a higher starting voltage.

In general, tertiary cathode heating is believed to have a positive impact on lamp life. The reduction in filament heating caused by instant start operation increases the rate of loss of the low–work function coating due to reduced i on bombardment at the cathode (also known as sputtering). This causes the tungsten wire coating to deteriorate more rapidly over time, which contributes to higher failure rates. Therefore, lamps that operate on RS or PS ballasts can have longer lifetimes than lamps that operate on IS ballasts. Lamp life not only depends on the starting method of the ballast, but can also depend on the la mp current crest factor. For more information on starting method and lamp current crest factor, see section 3.3.3.

3.3.3 Fluorescent Lamp Ballast Overview

Fluorescent lamp ballasts are devices that by means of resistance, inductance, capacitance, or electronic elements, singly or in combination, control the current, voltage, and waveform to properly start and safely operate fluorescent lamps (ANSI C82.13-2002). The following sections discuss ba sic ballast operation and the tw o main ballast technologies: magnetic and electronic.

A ballast has four critical functions:

1. provide controlled cathode heating to aid in starting and maintaining the arc discharge,

2. deliver high voltage to st art and ignite the lamp,

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### 3. regulate (limit) electric current flowing through the lamp after ignition to avoid current run-away and self-destruction, and

4. regulate (compensate) for variations in line voltage. Good regulation ensures that small variations in line voltage result in even smaller variations in lamp lumen output.

Ballast types can be subdivided into two ma in groups: magnetic (low frequency) and electronic (high frequency). Magnetic ballasts were the first technology used to operate ballasts. Electronic ballasts were developed later in the 1980s because of their high efficiency. Section

3.3.4 provides additional discussion on these and other technology options that can be used to increase the efficiency of fluorescent lamp ballasts.

There are many performance parameters used to describe the operation of a fluorescent lamp ballast. These include starting method, ballast factor, ballast efficacy factor, power factor, total harmonic distortion (THD), electromagnetic interference (EMI), and fluorescent system safety requirements. These performance pa rameters are briefly discussed below.

3.3.3.1 Starting Method

Fluorescent ballasts can be categorized by th e manner in which they operate the lamp, or more specifically, how the lamp is started. The most common ballasts use three different methods to start a fluorescent lamp: rapid start, programmed start, and instant start. These methods are all defined in ANSI C82.11-2002. The starting method primarily affects the ballast’s switching cycle capability ( i.e. , the number of times one can switch the lamp on and off before it expires) and the power consumption of the ballast.

Rapid start ballasts heat the electrodes for a set amount of time before lamp ignition. The coil heating reduces the open circuit voltage required to start the lamp, but coil heat remains constant after starting and consumes additional power. 21 

### The major benefit of this starting technique is that it leads to a longer lamp life th an the starting technique of an IS ballast. For example, if the lamp is switched on and off ev ery 3 hours, the fluorescent lamp life would be approximately 25 percent lower for an IS ballast than for a RS ballast. However, when the lamp is frequently switched on and off ( e.g. , every 15 or 30 minutes), the lamp life on instant start and rapid start ballasts can be similar. 23 

### In general, RS ballasts provide between 15,000 and 17,000 switching cycles. 22, 23



### A more recent and advanced version of the RS ballast is the PS ballast. Like the RS ballast, the PS ballast heats the la mp filaments to a certain temp erature for a prescribed amount of time before applying a high-voltage pulse to ignite the lamp. Some programmed start ballasts remove all power to the electrodes after ign ition (also known as cathode cut-out), resulting in some energy savings over other PS systems. Ho wever, due to added in ternal circuitry, PS

ballasts cannot be as efficient as IS balla sts. PS ballasts can provide between 50,000 to 100,000 switching cycles depending on ballast design. 22, 24 

### A lamp operating on a PS ballast can last more than three times longer than it would on a RS or IS ballast. 22



### Instant start ballasts rely on higher voltage to initiate the discharge rather than applying a steady filament voltage. These ballasts apply a very high voltage pulse to the lamp to rapidly ionize the gas in the lamp and initiate the ar c instantly, without the need for heating the

3-19

### electrodes. Because IS electronic ballasts do not provide lamp electrode heating, these ballasts are inherently more efficient, saving approximate ly 2 watts of energy per lamp compared to RS ballasts. However, due to the high applied voltage necessary to st art the lamp, the electrodes of a lamp operated by an IS ballast deteriorate more quickly than the heated electrodes of a lamp operated by a RS or PS ballast, resulting in decreased lamp life. IS ballasts can provide between 10,000 and 15,000 switching cycles depe nding on the ballast design. 22, 23



### 3.3.3.2 Ballast Factor

The ballast factor is defined as the output of a ballast delivered to a reference lamp in terms of power or light divided by the output of the relevant reference ballast delivered to the same lamp (ANSI C82.13-2002). To calculate the light output of a lamp-and-ballast system, one would multiply the light output of the lamp by both the number of lamps operated by the ballast

and its ballast factor. Because ba llast factor affects the light out put of the system, manufacturers design ballasts with a range of ballast factors to allow consumer s to vary the light output (and thus power consumed) of a fluoresce nt system. In general, ballasts designed with a ballast factor

of around 0.88 are deemed normal ballast factor. Low ballast factor ballasts have a ballast factor of 0.78 or less; high ballast fact or ballasts typically have a ballast factor of 1.10 or higher.

3.3.3.3 Ballast Efficacy Factor

Ballast efficacy factor (BEF) is a measure of ballast system performance or efficacy. According to Appendix Q to Subpart B of Part 430 in the CFR, this factor is defined as:

Relative Light Output BEF = Equation 3.1 Input Power

Where:

B

EF = 

### ballast efficacy factor; Relative Light Output = 

### the light output delivered through the use of a ballast divided by the
light output delivered through the use of a re ference ballast, expressed as a percent; and InputPower = 

### the power consumption in watts of a ba llast and fluorescent lamp or lamps.

3.3.3.4 Power Factor

The power factor (PF) is calculated by determining the ratio of the active power to the apparent power. PF depends on the current’s wa ve shape as well as the phase relationship between the current and the voltage. The power input is measured with a wattmeter capable of indicating the average power in watts. The ballast input voltage multiplied by the ballast input current is the ballast’s apparent power (ANSI C82.13-2002).

Power Input Power Factor = Equation 3.2 Ballast Input Voltage ∗ Ballast Input Current

Where:

PowerFactor = 

### power factor,

3-20

### PowerInput = 

### input power in watts to ballast,
BallastInputVoltage = 

### input voltage in volts to ballast, and
BallastInputCurrent = 

### input current in amps to ballast.

Power factors range between 0 and 1. A power fa ctor of 1 indicates that the voltage and current wave forms are in phase and not distorte d. Fluorescent ballasts can be characterized by two classes of power factor: high power factor (HPF) of 0.9 or greater, and normal power factor (NPF) of 0.6 or greater. HPF ballasts use about on e-half the current of NPF ballasts. The primary cause of low power factor in ma gnetic ballasts is the inductance of the ballast transformers. It can be corrected with the addition of the proper capacitor. In electronic ballasts, the primary cause of low power factor is due to total harmonic distortion (defined below) caused by a nonlinear load. According to ANSI C82.77-2002, comme rcial ballasts must have a HPF while residential fluorescent ballasts (with an input pow er below 120W) must have a power factor of

0.5 or greater.

3.3.3.5 Total Harmonic Distortion

Another important performance parameter is harmonic distortion. Line current harmonics are the components of the line current that osc illate at integer multiple s of the fundamental frequency of the power supply, e.g. , 60 Hz, 120 Hz, 180 Hz, etc. Harmonics of a fundamental frequency are an undesirable byproduct of any no n-linear system operation, generating noise and wasted power. Total harmonic distor tion refers to the ratio of the root mean square (rms) values

of the harmonic content to that of the fundamental current, expressed as a percentage. It may also

be called harmonic factor:

2 2 2 

### I + I + I +

...

2 3 4 

### THD ( fund ) = I 1 2 

### Equation 3.3



### Where:

THD = 

### total harmonic distortion; and

I

n 

### = the rms current of harmonic n , where n=1 is the fundamental harmonic.

High THD figures are not acceptable and are detrimental to many kinds of electronic devices connected to the power line. They are also considered a “pollutant” to the environment because of radio frequency noise. Therefore, ANSI C82.11-2002 requires that the THD of electronic ballasts not exceed 32 percent. Electronic ballasts today are typically rated at less than 20 percent THD. Magnetic ballasts are typically rated in the 20 to 28 percent range.

3.3.3.6 Electromagnetic Interference



### Many devices found in office environments, such as computers, photocopiers, facsimile machines, and fluorescent lighting systems, can generate electromagnetic waves. The effects of these waves vary based on their strength and the susceptibility of nearby equipment. Alternating

current in electronic devi ces produces a magnetic field, which in turn induces an AC voltage in a

3-21

### nearby electronic device. Electromagnetic interference (EMI) takes two forms: conducted or

radiated. Conducted EMI occurs when electronic devi ces induce currents in the local power network that in turn negatively affect other devi ces on that network. Radiated EMI is associated with the electric and magnetic fi eld inherent in electronic devi ces. EMI can be minimized with proper grounding and wiring techniques. 25 

### EMI limits for both consumer and non-consumer lighting products sold in the United States are listed in 47 CFR 18 subpart C. These regulations require that consumer/residential (Class B) ballasts have lower maximum EMI requirements than non-consumer (Class A) products. The International Committee on Radio Interference has more stringent regulations concerning EMI. However, fluorescent lamp ballasts sold in the United States currently do not have to meet these regulations.

3.3.3.7 Safety



### A ballast will continue to drive or reignite a lamp when the lamp reaches the end of its life. Usually, the failure of th e lamp will have no adve rse consequences. Occasionally, the ballast will continue to try to drive a failed lamp repeatedly until the temperature in the region of the electrode increases rapidly and causes overheati ng of the lamp electrodes. This can be avoided through additional circuitry that provides end-of-life (EOL) prot ection. Some ballasts in the United States are required to have EOL protection ( e.g. , ballasts that operate T5 lamps). However, the most popular T8 ballasts are not. International standards (IEC 600797-1 Ed. 4) require all fluorescent lamp ba llasts regardless of lamp diamet er to have EOL protection.

Another safety issue arises when a lamp is not inserted properly into the lamp holder, which can cause arcing. This problem can either be addressed through better design of the lamp holders, or by adding circuitry to the ballast that detects arcing and reduces the output voltage so

that the arc cannot be sustained.

3.3.4 Fluorescent Lamp Ballast Technology Options



### The following section discusses the two ma jor technologies used in fluorescent lamp ballast design—magnetic ballasts and electronic ballasts— and additional technology options (lamp diameter, improved components, and improved circuit design) that can incrementally improve the efficiencies of a magnetic or electronic ballast.

3.3.4.1 Magnetic Ballasts



### The main components of a magn etic ballast are a magnetic choke to limit the current, a step-up transformer to obtain a high starting voltage, and a capacitor that corrects for the ballast’s low power factor. Multi-lamp magnetic ballasts also have one or more additional capacitors to sequence the starting of the lamps. Magnetic ballasts opera te at an input frequency of 60 Hz and operate the lamp(s) at the same frequency.

The main core-and-coil assembly consists of a capacitor and laminated transformer steel wound with copper or aluminum magnet wire. The assembly is infused with a potting material ( e.g. , hot asphalt) containing fiber su ch as silica and housed in a steel case. Figure 3.3.2 presents a labeled graphic of the interior of a standard magnetic ballast.

3-22

### Figure 3.3.2 Cutaway View of a Typi cal Magnetic Fluorescent Ballast



### The core and coil assembly functions as a voltage transformer and a current limiter (choke). A capacitor enables the ballast to use energy from the alternating current power line more efficiently, which is then referred to as a HPF or PF corrected ballast. The purpose of the insulating material is to conduct heat away fro m the transformer coils and ensure tightness of

transformer coils to eliminate vibrational noise.

Because of their low frequency operation, magnetic ballasts are less energy efficient than electronic ballasts (Figure 3.3.3). Magnetic ba llasts fail to optimize lumen output for a given wattage. These ballasts also release the energy not used to operate the lamp as heat in the transformer windings. This heat is dissipated to the environment by the ballast potting material and its metal or pl astic enclosures.

3.3.4.2 Electronic Ballasts



### For equivalent light output, electronic ballasts consume about 10 to 30 percent less energy than magnetic ballasts. An electronic ballast starts and operates fluorescent lamps at frequencies greater than 20 kHz using electronic components rather than the traditional core and coil assembly. The electronic ballast takes the input 60 Hz power, r ectifies it, and converts it into a high frequency using an oscillator circuit.

Higher operating frequency generates great er lumen output. Figure 3.3.3 shows the increase in lumen output relative to 60 Hz operation as a function of frequency. The gain in light output by increasing operating frequency begins to plateau around 20 kHz. Therefore, electronic ballasts typically operate at frequencies above 20 kHz.

3-23

### Figure 3.3.3 Fluorescent Lamp Efficacy vs. Operating Frequency of Lamp
Source: Adapted from IESNA, 2002.



### Not only is the lamp more efficient at higher frequencies but the ballasting action (current-limiting) at high frequency requires smaller components. This reduces ballast losses and makes the ballast more efficient. In addition, the ballast noise becomes inaudible at higher frequencies and there is no 60-cycle flicker like that associated with fluorescent lamps that operate with magnetic ballasts.

Whereas typical magnetic ballasts generally have three components ( i.e. , core, coil, and capacitor), electronic ballasts ha ve additional blocks of elect ronic components. Figure 3.3.4

shows the interior of an electronic ballast.

Figure 3.3.4 Cutaway View of an Electronic Fluorescent Ballast

3-24

### Figure 3.3.5 presents an example of a func tional block diagram of a fixed-light output electronic ballast. Auxiliary functions performed by a typical electronic ballast include electromagnetic interference filtering to block ballast-generated noise, input rectification, PF

correction for sinusoidal i nput current, a direct-current (DC) filte r, a direct-current to alternatingcurrent (DC-AC) inverter, a feedback/controller fo r high-frequency operation, and a final output stage to power the lamp.

Figure 3.3.5 Fixed-Light Output Electroni c Fluorescent Ballast Block Diagram
Source: T. Ribarich, A Systems Approach to Ballast IC Design, El Segundo, CA, 1999, and Philips Semiconductor, Power Semiconductor Applications , 1994.



### Table 3.3.2 provides a description of each component in a typical electronic ballast, the efficiency impact of these components, and the wa veform at each stage of the fluorescent lamp

ballast circuit.

Table 3.3.2 Basic Building Blocks of a Fixed-Light Output Fluorescent Lamp Ballast and

Associated Characteristics

Circuit Stage Function Efficiency Impact Waveform (not to scale)

EMI Filter Impedes EMI by providing a high impedance path to EMI and a low impedance path to the desired input. The circuit also protects against high voltage pikes. Very Low

t V

Begins to convert incoming AC to DC using diodes. A full-bridge rectifier, one type of input rectifier, is composed of four diodes, which “rectify” the full AC waveform as shown in the waveform on the right. The current is not in phase with the voltage. Low



### t V, I

3-25Input Rectifier

Power Factor

Correction Corrects the current so it is in phase with the voltage. Power factor correction can be achieved through a buck or boost-converter circuit topology. Low-Medium

t V, I

DC Filter Reduces “ripple” of the DC current waveform using capacitors. The most common type of capacitor used is the electrolytic capacitor. Low

t V

DC-AC Inverter Converts incoming DC to high-frequency AC. The resonant half-bridge self-oscillating circuit is one type of circuit topology that can be used to accomplish this task. MediumHigh

t V

Output Stage When the lamp is not started, the circuit operates in resonance to increase output voltage to start the lamp. Once the lamp is started, the circuit operates at a frequency off of resonance to continue operating the lamp. A resonant filter topology is one type of circuit topology used in the output stage. High Starting:

t V

Operation:

t V

Feedback/Controller An integrated circuit (IC) that controls the frequency output of the DC-AC inverter. It can also protect against under voltage lockout Low N/A

3-26and lamp faults.



### 3.3.4.3 Lamp Diameter



### Lamp diameter is another design parameter of a fluorescent lamp ballast that can affect the ballast efficacy factor. As discussed in section 3.4, product classes are not explicitly segregated by the lamp diameter operated by the ballast. When DOE determines that changes in lamp diameter offer a distinct utility, DOE may establish separate product classes. In general, however, DOE considers lamp diamet er to be a technology option.

The diameter of a lamp affects both the lamp efficacy and the ballast’s BEF. For lamps, an optimum design diameter exists for a specific fluorescent lamp type resulting from two opposing effects. First, in small diameter lamps, an increase in diameter decreases the number of electrons and mercury ions that recombine at the bulb wall and produce no light. This lessening

of non-radiative recombination results in an incr ease of optical power output and subsequently a rise in lamp efficacy. However, when the lamp diameter is sufficiently large as to result in minimal non-radiative recombination, a second oppos ing effect begins to influence the efficacydiameter relation. With these larger diameter lamps, a further enlargement in diameter causes a greater imprisonment of radiation within the lamp. As the total light output is reduced, the lamp efficacy declines as well. In general, T12 lamps are less efficient than T8 lamps.

For ballasts, lamp diameter affects the BEF of a ballast in the following manner. Because T12 lamps are less efficient than T8 lamps, lamp manufacturers can achieve similar light output using lower-wattage T8 lamps. Ballasts that operate lower-wattage T8 lamps use less power to operate the lamp at a similar ballast factor than higher-wattage T12 lamps. Therefore, the BEF of the ballast operating a T8 lamp is generally higher than that of a ballast operating a T12 lamp. Because the BEF and lamp efficacy of a T8 fluorescent system are higher than that of a T12 fluorescent system, T8 systems are more efficacious than T12 systems.

DOE only considered lamp diameter as a technology option for T12 and T8 lamps. DOE’s research indicates that ballasts that operate T8 lamps are common replacements for ballasts that operate T 12 lamps. Although the lumen packages for ballasts that operate T8 lamps are sometimes lower than that of ballasts that operate T12 lamps, in this situation, it does not seem to be significant enough to affect consum er utility. Conversely, DOE’s research indicates that ballasts that operate T5 lamps are not commonly used as substitutes for their T8 or T12 counterparts. T5 lamps require different lamp holde rs due to differences in lamp length and base type. In addition, because T5 lamps have sim ilar total lumen output as T8 and T12 lamps over a significantly smaller surface area, T5 lamp-and-ballast systems are often marketed as too bright for use in direct lighting fixtures. As such, balla sts that operate T5 lamps are not considered a technology option for improving the ballast efficacy factor of T8 and T12 ballasts.

3.3.4.4 Improved Components

3-27

### A common way to increase the efficiency of both magnetic and electronic ballasts is to improve the quality of their components. Transfor mers, diodes, capacitors, and transistors are the main components that affect efficiency.

Transformers : In electronic ballasts, transformers influence the efficiency of the EMI, power factor correction (PFC), a nd output stage of the ballast. In magnetic ballasts, transformers influence the efficiency of the output stage and current-limiting portion of the ballast.

There are two loss mechanisms associated with transformers: core losses and winding

losses. Core losses involve the ma gnetic properties of the core material, which exhibits power losses in the form of hysteresis and eddy currents within the core itself. Winding losses come from the resistance in the winding, typically copper. There are several technology options that can improve the efficiency of a transformer’s core losses. These include improved silicon steel, amorphous steel, or increased amounts of amorphous steel. Litz wire can be used as a technology option to improve a transformer’s winding losses.

One way to reduce transformer power loss at light loads is to select a transformer with higher quality core materials. There are two types of core materials that ballasts can use: silicon steel (thinly laminated steel alloyed with silicon) and amorphous steel. Core performance of silicon steel can be enhanced by magnetically orienting the grain structure in the metal. Even larger gains in efficiency can be achieved us ing amorphous materials. To further increase the efficiency of the ballast using amorphous material s, one can create the core of the inductor from laminated sheets of amorphous steel, insulated from each other. However, this method can increase the size and weight of the ballast.

Another way to reduce the transformer’s power loss is to select materials with lower winding losses. High-frequency operation (typical of electronic ballasts) can increase winding losses as two additional loss mechanisms, skin effect and proximity effect, become more prominent. One way to reduce both the skin effect and proximity effect is to use litz wire, which

consists of a number of individua lly insulated magnet wires twisted or braided into a uniform pattern. Skin effect refers to th e tendency of AC current to flow through a conductor’s surface or

“skin” rather than a conductor’s core. Because litz wire increases the amount of surface area current can flow through, overall winding losses can be reduced as the effective wire resistance is decreased. When conductors are close together, the magnetic field of one conductor will reduce the area that the current flows through in another conductor, increasing its winding losses. This effect, called the proximity effect, can be also be improved by using litz wire.

Diodes: In electronic ballasts, the input rectifier in verts the negative half of the AC sine wave and makes it positive. Several technology options can be used to improve the efficiency of this portion of the circuit. The power consumed by a diode is the product of the current flowing through the diode multiplied by the voltage drop across it. Conventional diodes have a voltage

3-28

### drop of about 0.6 V. Using Schottky diodes n 

### reduces the voltage drop across the diodes by about

0.3 V to 0.4 V.

Capacitors: In both magnetic and electronic ballast s, capacitors are used in the PFC and output stage of the circuit design. In electronic ballasts, capacitors are also used in the DC Filter stage of the electronic circuit. One way to improve the efficiency of each portion of the circuit is to use capacitors with low effective series resistance (ESR). Capacitors with a low ESR are also more reliable because they are cooler than capacitors with a higher ESR.

Transistors: In electronic ballasts, transistors are used in both the power factor correction and the DC-AC inverter portion of the circuit. The transistor dissipa tes energy due to its drain-tosource resistance (R DS_ON 

### ) when the current flows through the transistor to the transformer. Using transistors with low R DS_ON 

### can reduce this loss. For example, the efficiency of electronic ballast’s bipolar transistors can be improved by using metal-ox ide-semiconductor field-effect transistors (MOSFETs), a transistor w ith a lower drain-to-source resistance.

3.3.4.5 Improved Circuit Design



### Another method of increasing the efficiency of both magnetic and el ectronic ballasts is to improve the ballast’s circuit design. Examples of improved circuit design include cathode cutout technology, integrated circuits, improved star ting method, and synchr onous rectification.

Cathode Cutout : Both rapid start and programmed st art ballasts provide heat to the filament while starting a lamp. As discussed in section 3.3.3.1, providing filament power while starting the lamp can increase its lifetime. Removing the power provided to the filament after the lamp has been started using an electronic circuit will increase the efficiency of both programmed start and rapid start ballasts. Rem oving this power can reduce the power the ballast consumes by as much as 2 watts per lamp.

Integrated Circuits : In certain cases, a ballast’s efficiency can be improved by substituting integrated circuits for discrete components. For example, some ballasts use bipolar transistors in a resonant half-bridge self-oscillating circuit to convert incoming DC to AC. The efficiency of this circuit can be improved by s ubstituting the components in that circuit with an integrated circuit. 26



### Starting Method : RS and PS ballasts are inherently less efficient than IS ballasts, which use extra power to provide filame nt power to the ballast to increase its lifetime. Although these ballasts can cut out the filament power during lamp operation (using the cathode cutout technology option discussed above), the extra circuit to remove this power uses some amount of

power.

DOE only considered starting method as a t echnology option in case of the migration from RS to IS ballasts. DOE’s research indicates that IS ballasts are common replacements for

n A Schottky diode is a metal semiconductor diode with a smaller voltage drop than a conventional diode. Schottky diodes therefore consume less power.

3-29

### RS ballasts, and though the lamp lifetime is sometimes lower in IS ballasts than RS ballasts, it does not seem to be significant enough to affect consumer utility. As discussed in section 3.3.3.1, lamp lifetime in IS ballasts is approximately 25 percent less compared to RS ballasts when operated on a 3-hour start. Howeve r, lamps operated on RS ballast s have the same lifetime as lamps operated on IS ballasts when operated on short start cycles. This is typical when ballasts are used with occupancy sensors to save energy. Conversely, the lifetime of a lamp that operates on a PS ballast with occupa ncy sensors can be as much as three times longer than the lifetime of a lamp that operates on an IS or RS ballasts. Because IS ballasts have more limited utility as replacements for PS ballasts, IS ballasts are not considered a technology option for improving the efficiency of PS ballasts.

3.4 PRODUCT CLASSES



### When evaluating and establishing energy conservation standards, DOE divides covered products into classes by the type of energy used , capacity, or other performance-related features that affect efficiency, and factors such as the utility of the product to users. (See 42 U.S.C. 6295(q)) DOE then conducts its analysis and cons iders establishing or amending standards to provide separate standard levels for each product class. DOE applied the criteria of 42 U.S.C. 6295(q) to fluorescent lamp ballast s to develop product classes for this preliminary TSD. This section describes the pro duct classes DOE considers for this rulemaking.

In amending EPCA, NAECA 1988 established ei ght product classes for fluorescent lamp ballasts (Table 3.4.1).

Table 3.4.1 EPCA Product Classes Established by NAECA 1988 for Fluorescent Lamp

Ballasts

Application for Operation of Ballast Input Voltage Total Nominal Lamp Watts

One F40T12 Lamp 120 40

277 40

Two F40T12 Lamps 120 80

277 80

Two F96T12 Lamps 120 150

277 150

Two F96T12 HO Lamps 120 220

277 220



### In further amendments to EPCA, EPACT 2005 established an additional eight product classes for fluorescent lamp ballasts (Table 3.4.2).

Table 3.4.2 EPCA Product Classes Established by EPACT 2005 for Fluorescent Lamp

Ballasts

Application for Operation of Ballast Input Voltage Total Nominal Lamp Watts

One F34T12 Lamp 120 34

277 34

Two F34T12 Lamps 120 68

277 68 Two F96T12/ES Lamps 120 120

3-30277 120

Two F96T12 HO/ES Lamps 120 190

277 190



### In addition to the lamps and lamp ballasts id entified in Table 3.4.1 and Table 3.4.2, the fluorescent lamp ballast market today includes ballasts that operate smaller diameter lamps such as T8 and T5 lamps (section 3.3.1). These fluor escent lamp-and-ballast systems are gaining in market share, whereas T12 systems are becomi ng less popular and losing market share. This market shift is expected to accelerate in 2010, when the exclusion from the standard levels established by the 2000 Ballast Rule and EPAC T 2005 for replacement ballasts will expire. The standard levels established by the 2000 Balla st Rule and EPACT 2005 for fluorescent lamp ballasts are difficult to meet using magnetic ballast technology. Becau se magnetic ballasts comprise the large majority of T12 ballast sales, DOE believes that when the standards take effect, there will be an increase in shipments of electronic ballasts that operate T8 and T5 lamps.

Because of these market changes and because DOE is anticipating expanding its scope of covered product for fluorescent lamp ballasts, DOE is considering amending the product classes for these ballasts. The following sections summarize all of the factors that DOE considered as potential determinants of product class. In general, when consid ering the characteristics below, DOE considered three main factors as affecting consumer utility: (1) the lumen package of the lamp-and-ballast system; (2) the physical constrai nts of the lamp-and-ballast system; and (3) the use of the ballast in an application for which othe r ballasts are either not suitable. When referring to efficiency, DOE is referring to BEF.

3.4.1 Lamp Length



### The fluorescent ballasts considered for coverage are designed to operate lamps with lengths of four or eight feet. Because BEF is a function of ballast input power, and input power is highly dependent on the length of the lamp operated by the ballast, all else being equal, a ballast operating a shorter lamp generally has a higher BEF than the same ballast operating a longer lamp. Furthermore, because consumers are often physically constrained by their building ceiling layout, systems operating 8-foot and 4-foot lamp s are not always substitutable for each other. Therefore, DOE believes that lamp length affects consumer utility. Given the impact on BEF and utility, DOE is establishing separate product classes for ballasts that operate different lamp lengths.

3.4.2 Lamp Diameter



### T8 lamp-and-ballast systems are generally more efficien t than T12 lamp-and-ballast systems and T8 ballasts generall y have higher BEFs than T 12 ballasts. DOE does not, however,

believe that this alone justifies creating separate product classes for ballast s that operate T8 and T12 lamps. Consistent with its approach in past rulemakings (74 FR 16920, 16937 (April 13, 2009)), DOE maintains that T8 lamp-and-ballast systems are commonly used as substitutes for T12 lamp-and-ballast systems, suggesting that there is no unique utility associated with T12 systems. Manufacturer marketing literature and general guidance on lighting design and installation often promote T8 lamp-and-ballast systems as energy saving substitutes for T12 systems. Such substitute systems often have the same lengths and bases, offer comparable lumen

3-31

### output, and can fit within the same fixtures. DOE recognizes that lamp diameter may affect ballast BEF, but the utility provided to the end-user is comparable and/or equivalent. Therefore,

DOE has decided to include ballast s that operate T8 and T12 lamp s in the same product class.

However, DOE has decided to establish a separate product class for ballasts that operate T5 lamps. All else bei ng equal, 4-foot T5 balla sts generally have lower input power (due to the lower wattage of the test lamp), and therefore higher BEF than T8 or T12 ballasts. These systems, though often used to replace T8 and T12 systems, are not viable substitutes in all applications. Because T5 lamps have similar total lumen output as T8 and T12 lamps over a significantly smaller surface area, T5 lamp-and-ballast systems are often marketed as too bright for use in direct lighting fixtures. To prevent eliminating lamps appropriate for direct lighting applications, DOE has tentatively decided to establish separate product clas ses for ballasts that operate T5 lamps.

3.4.3 Ballast Factor



### The ballasts considered for coverage in this rulemaking are available with a range of ballast factors. In applying DOE’s proposed am ended active mode test procedure (as presented in the active mode test procedure NOPR), DOE found that ballasts with high or low ballast

factors have lower BEFs than ballasts with a normal ballast factor. o 

### Furthermore, ballast factor is typically used to adjust the lumen package of a lamp-and-ballast system. Lumen package refers to the quantity of light that a lamp-and-ballast system provides to a consumer. DOE has observed that consumers tend to use systems with different lumen packages for different applications. For example, low BF ballasts (with smaller lumen packages) are commonly used in applications where less light is desired. In consideration of the effect that ballast factor has on both BEF and consumer utility, DOE has decided to establish separate product classes for low, normal, and high ballast factor ballasts.

3.4.4 Lumen Package



### Lumen package refers to the quantity of light that a lamp-and-ballast system provides to a consumer. To obtain a high lumen package, certain lamps are designed to operate with ballasts that run the lamps at high currents. For exampl e, 8-foot RDC HO lamps and 4-foot miniature bipin (MiniBP) HO lamps tend to operate at higher currents than 8-foot SP slimline lamps and 4­ foot MiniBP standard output (SO) lamps, respec tively. This difference in operating design increases the quantity of light per unit of lamp length.

High output lamps generally operate at high er wattages than comparable (same length, diameter) standard output lamps. For example, for 4-foot miniature bipin lamps, the most common high output lamp has a wattage of 54 W whereas the most common standard output lamp has a wattage of 28 W. This difference in lamp wattage means that ballasts that operate high output lamps generally have lower BEFs than ballasts that operate comparable standard output lamps.

o DOE classifies a low BF as less than or equal to 0.78, a normal BF as greater than 0.78 but less than 1.1, and a high BF as greater than or equal to 1.1.

3-32

### In addition, consumers tend to use systems w ith different lumen packages for different applications. For example, high-lumen-output syst ems may be installed in certain high-ceiling or outdoor applications where large quantities of lightare needed. Alternatively, standard-lumenoutput systems might be installed in lower-ceiling applications such as offices or hospitals, where, for example, distance between the light source and the illuminated surface is not as large. Notable differences in the appli cation of ballasts designed to op erate SO lamps versus HO lamps indicate a difference in utility.

Therefore, given the observed utility distinctions and notable efficacy differences, DOE is establishing separate produc t classes for ballasts that opera te SO lamps a nd ballasts that operate HO lamps.

3.4.5 Maximum Number of Lamps Operated



### Ballasts are designed to operate a certain maximum number of lamps. For example, ballasts designed to operate 4-foot MBP lamps ca n operate as few as one or as many as six lamps. DOE found that BEF decreased with each additional lamp operated by a ballast. This is because additional lamps increase the ballast’s input power, which appears in the denominator of Equation 3.1. DOE believes that the ability to operate different maximum number of lamps offers the consumer a distinct utility because this capacity affects the sp ace required by fixtures (a four-lamp fixture requires more physical spa ce than one-lamp fixture). Given this impact on both BEF and consumer utility, DOE has decided to establish separate product classes based on

the maximum number of la mps a ballast operates.

3.4.6 Starting Method



### As discussed in section 3.3.3.1, the starting me thod of a ballast affects its efficiency. RS and PS ballasts are inherently less efficient than IS ballasts as these ballasts use extra power to provide filament power to the lamp to increase the lamp’s lifetime. Although these ballasts can cut out the filament power durin g lamp operation (using the ca thode cutout technology option discussed above), the extra circuit to remove this power uses some amount of power.

Whereas RS and IS ballasts are commonly used as substitutes for each other, programmed start ballasts are not. PS ballasts are commonly used in conjunction with occupancy sensors because of their ability to maintain the lifetime of the fluorescent lamp. DOE’s research indicates that use of instant start ballasts with occupancy sensors can result in an 80 percent reduction in lamp lifetime. Because of the application in which they are used, programmed start ballasts offer the user a distinct utility. In consideration of its affect on both BEF and utility, DOE has tentatively decided to establish separate product classes for programmed start ballasts

3.4.7 Input Voltage



### Fluorescent lamp ballasts are available at a variety of input voltages, but the two most common input voltages are 120V and 277V. In examining test data between ballasts that operate only at 120V and ballasts that ope rate only at 277V, DOE found that there was not a significant

3-33

### difference in BEF. In addition, in its research, DOE found that the ballasts with the highest BEFs allowed operation at both 120V and 277V. For this reason, DOE does not consider input voltage

to be a factor in de termining product class.

3.4.8 Universal Voltage



### Universal voltage ballasts can operate at multiple input voltages ( e.g., 120V and 277V). To accommodate multiple voltage s, these ballasts contain more components than dedicated voltage ballasts (ballasts that operate only one input voltage). Universal ballasts are growing in popularity because they can be used in multiple applications and serv e as replacements for multiple ballasts. This allows distributors to stock fewer types of ballasts and allows contractors to keep fewer on hand for maintenance. Consolid ation of products create s economies of scale for manufacturers, which can lead to reduced produc tion costs. DOE compared test data between ballasts that operate only at one voltage and universal voltage ballasts operating at that voltage and found that there was not a significant differe nce in BEF between the two. Therefore, DOE does not consider operating at multiple voltages to be a factor in determining product class.

3.4.9 Residential Ballasts



### Separate minimum power factor and electromagnetic interference requirements exist for residential as compared to commercial ballasts. Residential ballasts have more stringent (or lower maximum allowable) electromagnetic interference requirements than commercial ballasts; they also have less stringent (or lower mi nimum allowable) power factor requirements p 

### . These differing requirements between co mmercial and residentia l products result in differing BEFs. In addition to their effect on BEF, these two requirements offer the consumer a unique utility in that they serve distinct market sectors and applica tions. Therefore, DOE has tentatively decided to establish a separate product cl asses for ballasts that operate in the resi dential sector and

commercial sector.

3.4.10 Sign Ballasts



### Ballasts that are designed for use in cold te mperature outdoor signs have slightly different characteristics than those ballasts that operate in the commercial or residential sectors. First, sign ballasts are designed to operate in cold temperature environm ents – as low as -20 °F. Second, sign ballasts are classified by the total length (in feet) of lamps they can operate as well as the total number of lamps. To operate in cold temper ature environments and to be able to handle numerous lamp combinations, sign ballasts c ontain more robust components compared to ballasts in the commercial sector that operate 8-foot HO lamps and therefore sign ballasts are inherently less efficient. Regular 8-foot HO ballasts cannot be used as substitutes due to their inability to operate in cold temperature environments. For this reason, DOE believes cold temperature sign ballasts offer the consumer a distinct utility. Therefore, DOE has established a separate product class for cold temperature sign ballasts.

p ANSI C82.77-2002 requires residential ballasts to have a minimum power factor of 0.5 and commercial ballasts to have a minimum power factor of 0.9.

3-34

### 3.4.11 Product Classes



### For all the reasons discussed above, DOE is considering the ballast product classes listed in Table 3.4.3. Although ballasts are designed to operate multiple wattages of lamps, energy conservation standards will only be specified for the most common lamp wattage in each product class. In addition, energy conservation standards will only be specified while a ballast is operating the maximum number of lamps it is designed to operate. Chapter 5 of this preliminary TSD provides detail on the selection of candidate st andard levels.

Table 3.4.3 Preliminary Product Classes for Fluorescent Lamp Ballasts

Number of Lamps Ballast and Lamp Type Starting

Method Ballast

Factor One Two Three Four Five Six

High 1 2 3 4 5 6

Normal 7 8 9 10 11 12 IS and RS

Low 13 14 15 16 17 18

High 19 20 21 22 23 24

Normal 25 26 27 28 29 30 Four-Foot MBP,

and Two-Foot UShaped

PS

Low 31 32 33 34 35 36

High 37 38 N/A N/A N/A N/A

Normal 39 40 N/A N/A N/A N/A Four-Foot T5

MiniBP SO All

Low 41 42 N/A N/A N/A N/A

Four-Foot T5

MiniBP HO All All 43 44 45 46 N/A N/A

High 47 48 N/A N/A N/A N/A

Normal 49 50 N/A N/A N/A N/A Eight-Foot SP

Slimline All

Low 51 52 N/A N/A N/A N/A

IS and RS All 53 54 N/A N/A N/A N/A Eight-Foot RDC

HO PS All 55 56 N/A N/A N/A N/A

IS and RS All 57 58 59 60 N/A N/A Residential Ballast,

Four-Foot MBP,

and Two-Foot UShaped PS All 61 62 63 64 N/A N/A

Sign Ballast All All 65 66 67 68 69 70

3-35

### REFERENCES

1 

### Ron Runkles. NEMA Premium Effici ency Electronic Ballast Program. NEMA Lighting Systems

Division . 2007. (Last accessed June 29, 2009). < http://www.cee1.org/cee/mtg/09

­ 07ppt/Wednesday/9%20NEMA_CEE%20Presentation.ppt >.

2 

### National Electrical Manufacturers Association. Lighting Systems Division . 2002. (Last accessed June 29, 2009). < http://www.nema.org/prod/lighting/upload/LightingSystemsDivision.pdf >.

3 

### U.S. Small Business Administration. Table of Small Business Size Standards Matched to North American Industry Classification System Codes. 2008. (Last accessed June 29, 2009.)

< http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf >.

4 

### California Energy Commission. 2007 Appliance Efficiency Regulations . 2007. (Last accessed June 29, 2009). < http://www.energy.ca.gov/2007publications/CEC-400-2007-016/CEC-400

­ 2007-016-REV1.PDF >.

5 

### Natural Resources Canada, Office of Energy Efficiency. Proposed Regulations for Fluorescent Lamp Ballasts . 2001. (Last accessed June 29, 2009). <http://oee.nrcan.gc.ca/regulations/Fluorescent.cfm?attr=0>.

6 

### Natural Resources Canada, Office of Energy Efficiency. Recent Amendments . 2009. (Last accessed June 29, 2009). <http://oee.nrcan.gc.ca/regulations/amendment6_part2.cfm?attr=0>.

7 

### Natural Resources Canada, Office of Energy Efficiency. Regulations Amending the Canada 's Energy Efficiency Regulations. 2009. (Last accessed June 29, 2009). <http://oee.nrcan.gc.ca/regulations/amendment9_part1.cfm?attr=0 >.

8 

### Natural Resources Canada, Office of Energy Efficiency. Canadian Energy Efficiency Regulations for Fluorescent Lamp Balla sts. 2009. (Last accessed June 29, 2009). <http://oee.nrcan.gc.ca/regulations/product/fluorescent_lamp_ballasts.cfm?attr=0>.

9 

### U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Federal Energy Management Program. How to Buy Energy-Efficient Fluorescent Ballasts . 2000. (Last accessed June 29, 2009). < http://www1.eere. energy.gov/femp/pdfs/ballast.pdf >

10 

### Consortium for Energy Efficiency. CEE High Performance T8 Specification . 2008. (Last accessed June 29, 2009). < http://www.cee1.org/com/com-lt/com-lt-specs.pdf >.

11 

### Consortium for Energy Efficiency. CEE Reduced-Wattage T8 Specification . 2007. (Last accessed June 29, 2009). < http://www.cee1.org/com/com-lt/lw-spec.pdf >.

12 

### National Electrical Manufacturers Association. NEMA Premium Electronic Ballast Program

. (Last accessed June 29, 2009).

3-36

### < http://www.nema.org/gov/energy/efficiency/upload/nema_premium_electronic_ballast_progra m.pdf >.

13 

### National Electrical Manufacturers Association. NEMA Premium Motor Results Show Increase

in Sales. 2004. (Last accessed June 29, 2009.) < http://www.nema.org/media/pr/20041104a.cfm >.

14 

### U.S. Environmental Protection Agency and U.S. Department of Energy. About ENERGY STAR. (Last accessed June 29, 2009).

< http://www.energystar.gov/index.cfm?c=about.ab_index >.

15 

### U.S. Environmental Protection Agency and U. S. Department of Ener gy. Residential Light Fixtures Key Product Criteria. (Last accessed June 29, 2009).

< http://www.energystar.gov/index.cfm?c=fixtures.pr_crit_light_fixtures >.

16 

### Northeast Energy Efficiency Partnership. Commercial Buildings and Technologies Initiative

. 2009 (Last accessed June 29, 2009) <http:// www.neep.org/initiatives/buildings.html>

17 

### Efficiency Vermont. High Performance T8 Eligible Products & Fact Sheet . (Last accessed June 29, 2009.) < http://www.efficiencyvermont.com/stella/filelib/2008_HPT8FactSheet_FINAL1207.pdf >.

18 

### Efficiency Vermont. 2009 Rebate Applica tion. 2009. (Last accessed June 29, 2009).

< http://www.efficiencyvermont.com/stella/filelib/2009_LightingForm_FINAL.pdf >.

19 

### U.S. Census Bureau. Manufacturing, Mining, and Construction Statistics . Current Industrial Reports, Fluorescent Lamp Ballasts, MQ335C . 2008. (Last accessed June 29, 2009).

< http://www.census.gov/mcd />

20 

### National Electrical Manufacturers Association. 2006. No. 12 at p. 7. This written comment, document number 12, is available in Dock et # EE–2006–STD–0131. For more information, contact Brenda Edwards-Jones at (202) 586-2945.

21 

### Illuminating Engineering Society of North America. 2000. The IESNA Lighting Handbook: Reference and Application. 9th Edition. M.S. Rea. New York. 2000.

22 

### Philips. Smart T Bay . (Last accessed June 29, 2009).

< http://www.smartlightingtechnology.com/pdf/SmarTBay_608.pdf

.

23 

### Osram Sylvania. Ballast-Lamp Technology Update . 2000. (Last accessed June 29, 2009).

< http://www.lighthouseconsultingllc.com/Osram_S ylvania/Sylvania%20Ballast%20update.pdf >.

24 

### Osram Sylvania. Ballast Technology Applications and Specifications Guide . 2009. (Last accessed June 29, 2009.) < http://content.sylvania.com/app/display.aspx?docid=003699308 >.

3-3725 

### National Lighting Product Information Program. Lighting Answers: Electromagnetic Interference Involving Fl uorescent Lighting Systems . 1995. (Last accessed June 29, 2009).

< http://www.lrc.rpi.edu/programs/NLPIP/lightinganswers/pdf/view/LAEMI.pdf >.

26 

### International Rectifier. International Rectifier Introduces Robust Self-Oscillating Electronic Ballast Lighting Control IC . 2009. (Last accessed June 29, 2009.) < http://www.irf.com/whats

new/nr051122.html >.

3-38

### CHAPTER 4. SCREENING ANALYSIS

TABLE OF CONTENTS

4.1 INTRODUCTION

......................................................................................................... 4-1

4.2 SCREENED-OUT TECHNOLOGIES

.......................................................................... 4-2

4.3 REMAINING TECHNOLOGIES

................................................................................. 4-2

LIST OF TABLES

Table 4.3.1 Fluorescent Lamp Ballast Design Options

................................................... 4-3

4-i

### CHAPTER 4. SCREENING ANALYSIS

4.1 INTRODUCTION

This chapter discusses the U.S. Department of Energy’s (DOE’s) screening analysis of the technology options identified for fluorescent lamp ballasts. As discussed in chapter 3 of the preliminary technical support document (TSD), DOE consults with industry, technical experts, and other intere sted parties to develop a list of technology options for consideration. The purpose of the screening analysis is to determine which options to consider further and which to screen out.

Section 325(o)(2) of the Energy Policy and Conservation Act (EPCA) provides that any new or revised standard must be designed to achieve the maximum improvement in energy efficiency that is determined to be technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)) In view of the EPCA requirements appendix A to subpart C of title 10, Code of Federal Regulations (CFR), part 430 (10 CFR part 430), Procedures, Interpretations, and Policies for Consideration of New or Revised Energy Conservation Standards for Consumer Products (the Process Rule) sets forth procedures to guide DOE in its consideration and pr omulgation of new or revised efficiency standards. These procedures elaborate on th e statutory criteria provided in 42 U.S.C. 6295(o) and, in part, eliminat e problematic technologies early in the process of prescribing or amending an energy efficiency standard. In particular , sections 4(b)(4) and 5(b) of the Process Rule pr ovide guidance to DOE for dete rmining which design options

are unsuitable for furt her consideration:

1. Technological feasibility. DOE will consider technologies incorporated in commercial products or in working protot ypes to be technologically feasible.

2. Practicability to manufacture, install, and service. If mass production and

reliable installation and se rvicing of a technology in commercial products could be achieved on the scale necessary to serve the relevant market at the time the standard comes into effect, then DOE will consider that technology practicable to manufacture, install, and service.

3. Adverse impacts on product utility or prod uct availability. If DOE determines a technology would have significant adve rse impact on the utility of the product to significant subgroups of consumers, or would result in the unavailability of any covered product type with performance ch aracteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as products generally available in the United States at the time, it will not consider this technology further.

4. Adverse impacts on health or safety. If DOE determines that a technology will have significant adverse impacts on health or safety, it will not consider this technology further.

4-1

### Section 4.2 discusses the technology op tions DOE screened out from further

consideration. Section 4.3 lists the remaining design options DOE considered in its analyses.

4.2 SCREENED-OUT TECHNOLOGIES

This section addresses the technologies that DOE screened out, having considered the following four factors: (1) technological feasibility; (2) practicability to manufacture, install, and service; (3) adverse impacts on product utility to consumers; and (4) adverse impacts on health or safety.

DOE examined all of the technology options presented in the technology assessment. Of those options, DOE screened out one: laminated sheets of amorphous steel. The following discussion details DOE’s co nsideration of this option in the context of the four screening criteria.

A ballast’s efficiency can be improved by using higher-quality inductors. The transformer affects the efficiency of magnetic and electronic ballasts. For electronic ballasts, transformers influence the efficiency of the electromagnetic interference, power factor correction, and output stage of the balla st. For magnetic balla sts, the transformer influences the efficiency of the output stage and current-limiting portion of the ballast. One method of decreasing transformer losses is to create the core of the inductor from laminated sheets of amorphous st eel, insulated from each other.

DOE screened out this technology because this method increases the size and weight of the ballast and therefore is not “practicable to manufacture, install, and service.” Larger inductors may cause probl ems in installing a nd servicing ballasts because the ballast could be too large to fit in a fixture. DOE also believes this technology option could have adverse imp acts on consumer utility. Specifically, increasing the size and weight of the ballast may limit the places a consumer could use the ballast in a building. DOE is unaware of whether this technology option is technologically feasible or whether it has adverse impacts on health or safety.

4.3 REMAINING TECHNOLOGIES

After screening out laminated sheets of amorphous steel in accordance with the policies set forth in 10 CFR Pa rt 430, Subpart C, Appendix A, (4)(a)(4) and 5(b), DOE is considering the design options in the follo wing table as viable means for improving ballast efficacy. Chapter 3 provides a detailed description of these design options, which DOE will consider in the engineering analysis (chapter 5).

4-2

### Table 4.3.1 Fluorescent Lamp Ballast Design Options

Technology Option Description

Magnetic Ballast Use a magnetic ballast design.

Electronic Ballast Use an electronic ballast design.

Lamp Diameter Vary the lamp diameter to improve system performance.

Improved Components Transformers Use grain-oriented silicon steel or amorphous steel to reduce core

losses.

Use litz wire to reduce winding losses.

Diodes Use diodes with lower losses.

Capacitors Use capacitors with a lower effective series resistance.

Transistors Use transistors with low drain-to-source resistance.

Improved Circuit Design Cathode Cutout Remove filament heating after lamp has started.

Integrated Circuits Substitute discrete components with an integrated circuit.

Starting Method Use instant start instead of rapid start as a starting method for lamp operation.

4-35-i 

### CHAPTER 5 ENGINEERING ANALYSIS

TABLE OF CONTENTS

5.1 INTRODUCTION

........................................................................................................... 5-1

5.2 METHODOLOGY OVERVIEW

.................................................................................... 5-1

5.3 PRICING ANALYSIS OVERVIEW

.............................................................................. 5-3

5.3.1 Manufacturer Production Costs ........................................................................... 5-4

5.3.1.1 Selection of Units ..................................................................................... 5-5

5.3.2 Manufacturer Markup

.......................................................................................... 5-5 5.3.2.1 Manufacturer Selling Price ...................................................................... 5-6

5.3.2.2 Manufacturer Financial Information Sources .......................................... 5-6

5.3.3 MSP Scaling

......................................................................................................... 5-8

5.4 REPRESENTATIVE PRODUCT CLASSES

................................................................. 5-8

5.5 BALLASTS THAT OPERA TE TWO FOUR

- FOOT MBP AND TWO

- FOOT U

SHAPED LAMPS

.......................................................................................................... 5-10

5.5.1 Baseline Models

................................................................................................. 5-11

5.5.2 Candidate Standard Levels

................................................................................ 5-13

5.5.3 Lamp and Ballast Prices

..................................................................................... 5-17

5.5.4 Results

................................................................................................................ 5-18

5.6 BALLASTS THAT OPERATE FOUR FOUR

- FOOT MBP AND TWO

- FOOT U

SHAPED LAMPS

.......................................................................................................... 5-22

5.6.1 Baseline Models

................................................................................................. 5-22

5.6.2 Candidate Standard Levels

................................................................................ 5-24

5.6.3 Lamp and Ballast Prices

..................................................................................... 5-26

5.6.4 Results

................................................................................................................ 5-27

5.7 BALLASTS THAT OPERATE TWO EIGHT

- FOOT SP SLIMLINE LAMPS

.......... 5-29

5.7.1 Baseline Models

................................................................................................. 5-29

5.7.2 Candidate Standard Levels

................................................................................ 5-31

5.7.3 Lamp and Ballast Prices

..................................................................................... 5-33

5.7.4 Results

................................................................................................................ 5-33

5.8 BALLASTS THAT OPERATE TWO EIGHT

- FOOT RDC HO LAMPS

................... 5-37

5.8.1 Baseline Models

................................................................................................. 5-37

5.8.2 Candidate Standard Levels

................................................................................ 5-39

5.8.3 Lamp and Ballast Prices

..................................................................................... 5-41

5.8.4 Results

................................................................................................................ 5-41

5.9 BALLASTS THAT OPERATE TWO FOUR

- FOOT MINIBP T5 SO LA MPS

.......... 5-44

5.9.1 Baseline Models

................................................................................................. 5-44

5.9.2 Candidate Standard Levels

................................................................................ 5-45

5.9.3 Lamp and Ballast Prices

..................................................................................... 5-47

5.9.4 Results

................................................................................................................ 5-47

5.10 BALLASTS THAT OPERATE TWO FOUR

- FOOT MINIBP T5 HO LA MPS

.......... 5-49

5.10.1 Baseline Models

................................................................................................. 5-49

5.10.2 Candidate Standard Levels

................................................................................ 5-50

5.10.3 Lamp and Ballast Prices

..................................................................................... 5-525- ii 

### 5.10.4 Results 5-52

5.11 BALLASTS THAT OPERATE TWO FOUR

- FOOT MBP AND TWO

- FOOT U

SHAPED LAMPS IN THE RESIDENTIAL SECTOR

................................................ 5-54

5.11.1 Baseline Models

................................................................................................. 5-54

5.11.2 Candidate Standard Levels

................................................................................ 5-56

5.11.3 Lamp and Ballast Prices

..................................................................................... 5-58

5.11.4 Results 5-58

5.12 BALLASTS THAT OPERATE FOUR EIGHT

- FOOT HO LAMPS IN COLD

TEMPERATURE APPLICAT IONS OR OUTDOOR SIGN S ..................................... 5-61

5.12.1 Baseline Models

................................................................................................. 5-61

5.12.2 Candidate Standard Levels

................................................................................ 5-62

5.12.3 Lamp and Ballast Prices

..................................................................................... 5-64

5.12.4 Results 5-64

5.13 SCALING TO PRODUCT CLASSES NOT ANALYZED

.......................................... 5-66

5.13.1 Number of Lamps .............................................................................................. 5-66

5.13.2 Starting Method ................................................................................................. 5-67

5.13.3 Ballast Factor

..................................................................................................... 5-67

5.13.4 Scaling 5-68

5.13.5 All CSLs

............................................................................................................. 5-69

REFERENCES

.......................................................................................................................... 5-72

LIST OF TABLES

Table 5.3.1 Ballast Types for Teardowns .................................................................................... 5-5 Table 5.3.2 Gross Profit Margin for Four Fluorescent Lamp Ballast Manufacturers* ................ 5-7 Table 5.3.3 Calculated Manufacturer Markups for Fluorescent Lamp Ballasts .......................... 5-7 Table 5.4.1 DOE Product Classes for Fluorescent Lamp Ballasts ............................................ 5-10 Table 5.5.1 Representative Product Classes for Ballasts that Operate Two Four -Foot MBP and

Two -Foot U-Shaped Lamps ....................................................................................................... 5-11 Table 5.5.2 Baseline Ballasts for the IS and RS Representative Product Class ........................ 5-12

Table 5.5 .3 Baseline Units for the PS Representative Product Class ........................................ 5-13 Table 5.5.4 Lamps for Use with F32T8 and F34T12 Ballasts ................................................... 5-13

Tab le 5.5.5 Summary of the CSLs for Two

- Lamp Four

- Foot MBP RS and IS Normal BF

Ballasts ....................................................................................................................................... 5-15 Table 5.5.6 Ballast Designs for the IS and RS Representative Product Class ........................... 5-17 Table 5.5.7 Ballast Designs for the PS Representative Product Class ....................................... 5-17 Table 5.5.8 Summary of the Manufacturing Selling Prices for the IS and RS R epresentative

Product Class ............................................................................................................................. 5-18 Table 5.5.9 Summary of the Manufacturing Selling Prices for the PS Representative Product

Class ........................................................................................................................................... 5-18

Table 5.5.10 Retail Prices for Four -Foot Medium Bipin Fluorescent Lamps .......................... 5-18 Table 5.5.11 IS and RS Representative Product Class with F32T8 Baseline ............................ 5-20 Table 5.5.12 IS and RS Representative Product Class with F34T12 Baseline .......................... 5-20

Table 5.5.13 Four- Foot MBP PS Product Class ........................................................................ 5-21 Table 5.6.1 Representative Product Classes for Ballasts that Operate Four Four -Foot MBP and

Two -Foot U-Shaped Lamps ....................................................................................................... 5-225- iii 

### Table 5.6.2 Baseline Ballasts for the I S and RS Representative Product Class ........................ 5-23 Table 5.6.3 Baseline Ballasts for the PS Representative Product Class .................................... 5-23 Table 5.6.4 Lamp for Use with F32T8 Ballasts ......................................................................... 5-23 Table 5.6.5 Ballast Designs for the IS and RS Representative Product Class ........................... 5-26

Table 5. 6.6 Ballast Designs for the PS Representative Product Class ....................................... 5-26 Table 5.6.7 Summary of the Manufacturing Selling Price for the IS and RS Representative

Product Class ............................................................................................................................. 5-26 Table 5.6.8 Summary of the Manufacturing Selling Price for the PS Representative Product

Class ........................................................................................................................................... 5-27

Table 5.6.9 Retail Prices for Four -Foot Medium Bipin Fluorescent Lamps ............................ 5-27

Table 5.6.10 Four- Lamp Four -Foot MBP RS and IS Product Class with F32T8 Baseline ....... 5-28

Table 5.6.11 Four- Lamp Four -Foot MBP PS Product Class with F32T8 Baseline ................. 5-28 Table 5.7.1 Representative Product Classes for Ballasts that Operate Two Eight

- Foot SP Slimline Lamps ......................................................................................................................................... 5-29 Table 5.7.2 Baseline Ballasts for the Eight

- Foot SP Slimline Representative Product Class ... 5-30 Table 5.7.3 Lamps for Use with F96T8 and F96T12/E S Ballasts ............................................. 5-30 Table 5.7.4 Ballast Designs for the Eight- Foot SP Slimline Representative Product Class ...... 5-32

Table 5.7.5 Manufa cturing Selling Prices for the Eight-Foot SP Slimline Representative Product

Class ........................................................................................................................................... 5-33

Table 5.7.6 Retail Prices for Eight -Foot SP Slimline Fluorescent Lamps ................................ 5-33 Table 5.7.7 Eight -Foot SP Slimline Representative Product Class with F96T12/ES Baseline . 5-35 Table 5.7.8 Eight

- Foot SP Slimline Representative Product Clas s with F96T8 Baseline ......... 5-35 Table 5.8.1 Representative Product Classes for Ballasts that Operate Two Eight

- Foot RDC HO Lamps ......................................................................................................................................... 5-37 Table 5.8.2 Baseline Ballasts for the Eight

- Foot RDC HO Representative Product Class ....... 5-38 Table 5.8.3 Lamps for Use with F96T8HO and F96T12HO/ES Ballasts ................................. 5-38 Table 5.8.4 Ballast Designs for the Eight- Foot RDC HO Representative Product Class .......... 5-40 Table 5.8.5 Manufacturing Selling Prices for the Eight-Foot RDC HO Repr esentative Product

Class ........................................................................................................................................... 5-41

Table 5.8.6 Retail Prices for Eight -Foot RDC HO Fluorescent Lamps .................................... 5-41 Table 5.8.7 Eight

- Foot RDC HO Representative Product Class with F96T12HO/ES Baseline 5-42 Table 5.8.8 Eight -Foot RDC HO Representative Product Class with F96T8HO Baseline ....... 5-43 Table 5.9.1 Representative Product Classes for Ballasts that Operate Two Four

- Foot MiniBP T5 SO Lamps

................................................................................................ ................................... 5-44 Table 5.9.2 Baseline Ballast for Four-Foot T5 MiniBP SO Represe ntative Product Class ....... 5-44 Table 5.9.3 Lamps for Use with F28T5 Ballasts ....................................................................... 5-45 Table 5.9.4 Ballast Designs for the Four- Foot T5 M iniBP SO Representative Product Class .. 5-46 Table 5.9.5 Manufacturing Selling Prices for the Four-Foot T5 MiniBP SO Representative

Product Class ............................................................................................................................. 5-47

Table 5.9.6 Retail Prices for Four -Foot MiniBP SO Fluorescent Lamps ................................. 5-47

Table 5.9.7 Four -Foot T5 MiniBP SO Representative Product Class with F28T5 Baseline ..... 5-48 Table 5.10.1 Representative Product Classes for Ballasts that Operate Two Four

- Foot MiniBP T5 HO Lamps .................................................................................................................................. 5-49 Table 5.10.2 Baseline Ballast for the Four-Foot T5 MiniBP HO Representative Product Class .. 5-

49 Table 5.10.3 Lamps for Use with F54T5HO Ballasts ............................................................... 5-505- iv 

### Table 5.10.4 Ballast Designs for the Four-Foot T5 MiniBP HO Representative Product Class 5-51

Table 5.10.5 Manufacturing Selling Prices for the Four- Foot T5 MiniBP HO Representative

Product Class ............................................................................................................................. 5-52

Table 5.10.6 Retail Prices for Four -Foot MiniBP HO Fluorescent Lamps .............................. 5-52 Table 5.10.7 Four-Foot T5 MiniBP HO Representativ e Product Class with F54T5HO Baseline 5-

53 Table 5.11.1 Representative Product Classes for Ballasts that Operate Two Four

- Foot MBP and

Two -Foot U-Shaped Lamps in the Residential Sector .............................................................. 5-54 Table 5.11.2 Baseline Ballasts for the Residential Representative Product Class ..................... 5-55 Table 5.11.3 Lamps for Use with F32T8 and F34 T12 Ballasts ................................................. 5-55 Table 5.11.4 Ballast Designs for the Residential Representative Product Class ....................... 5-57

Table 5.11.5 Manufacturing Selling Prices for the Residential Representative Product Class 5-58

Table 5.11.6 Retail Prices for Four -Foot MBP Fluorescent Lamps ......................................... 5-58 Table 5.11.7 Residential Representative Product Class with F34T12 Baseline ........................ 5-60 Table 5.11.8 Residential Representative Product Class with F32T8 Baseline .......................... 5-60 Table 5.12.1 Representative Product Classes for Ballasts that Operate Four Eight

- Foot HO Lamps in Cold Temperature Applications or Outdoor Signs .................................................... 5-61 Table 5.12.2 Baseline Ballasts for the Sign Ballast Representative Product Class ................... 5-61 Table 5.12.3 Lamps for Use with Cold Temperature F96T12HO Ballasts ............................... 5-62 Table 5.12.4 Ballast Designs for the Sign Ballast Representative Product Class ...................... 5-63

Table 5.12.5 Manufacturing Selling Prices for the Sign Ballast Representative Product Class ... 5-

64

Table 5.12.6 Retail Prices for Eight -Foot HO Cold Temperature Fluorescent Lamps ............. 5-64 Table 5.12.7 Sign Ball ast Representative Product Class with F96T12HO Baseline ................. 5-65 Table 5.13.1 Test Data Obtained for Ballasts that Operate Four -Foot Medium Bipin Lamps .. 5-66 Table 5.13.2 Example of Scaling Based on Number of Lamps ................................................. 5-68 Table 5.13.3 Example of Scaling Based on Starting Method .................................................... 5-69 Table 5.13.4 Example of Scaling Based on Ballast Factor ........................................................ 5-69 Table 5.13.5 CSLs for All Ballasts That Operate Four-Foot MBP and Two-Foot U-Shaped Lamps ......................................................................................................................................... 5-70 Table 5.13.6 CSLs for All Ballasts That Operate Eight- Foot SP Slimline Lamps .................... 5-70 Table 5.13.7 CSLs for All Ballasts That Operate Eight- Foot RD C HO Lamps ........................ 5-70 Table 5.13.8 CSLs for All Ballasts That Operate Four-Foot T5 MiniBP SO Lamps ................ 5-71

Table 5.13.9 CSLs for All Ball asts That Operate Four -Foot T5 MiniBP HO Lamps ............... 5-71 Table 5.13.10 CSLs for All Residential Ballasts That Operate Four -Foot MBP and Two-Foot UShaped Ballasts .......................................................................................................................... 5-71 Table 5.13.11 CSLs for All Cold Temperature or Outdoor Sign Ballasts ................................. 5-71

LIST OF FIGURES

Figure 5.3.1 Manufacturer Selling Price ...................................................................................... 5-3 Figure 5.5.1 Candidate Standard Levels for the IS and RS Representative Product Class ....... 5-15 Figure 5.5.2 Candidate Standard Levels for the PS Representative Product Class ................... 5-16 Figure 5.6.1 Candidate Standard Levels for the IS and RS Representative Product Class ....... 5-24 Figure 5.6.2 Candidate Standard Levels for the PS Representative Product Class ................... 5-255-v 

### Figure 5.7.1 Candidate Standard Levels for the Eight-Foot SP Slimline Representative Product

Class ........................................................................................................................................... 5-32 Figure 5.8.1 Candidate Standard Levels for the Eight-Foot RDC HO Representative Product

Class ........................................................................................................................................... 5-40 Figure 5.9.1 Candi date Standard Levels for the Four-Foot T5 MiniBP SO Representative Product

Class ........................................................................................................................................... 5-46 Figure 5.10.1 Candidate Standard Levels for the Four-Foot T5 MiniBP HO Representative

Product Class ............................................................................................................................. 5-51 Figure 5.11.1 Candidate Standard Levels for the Residential Representative Product Class .... 5-57 Figure 5.12.1 Candidate Standard Le vels for the Sign Ballast Representative Product Class .. 5-635-1 

### CHAPTER 5 ENGINEERING ANALYSIS

5.1 INTRODUCTION

The U.S. Department of Energy (DOE) performed an engineering analysis to establish the relationship between the manufacturer production cost (MPC) and the energy efficiency of fluorescent lamp ballasts (hereafter “ballasts”). The relationship between the MPC and energy efficiency, or the cost

- efficiency relationship, serves as the basis for cost

- benefit calculations for individual customers, manufacturers, and the Nation. This section provides an overview of the engineering analysis, discusses the representative product classes, establishes baseline unit specifications for those product classes, discusses incremental efficiency levels, discusses the analysis and results for the representative product classes, and establishes a scaling methodology to those product classes not analyzed.

The primary inputs of the engineering analysis are the design options from the screening analysis (preliminary technical support document (TSD) chapter 4). Additional inputs include cost and efficiency data derived from the teardown analysis and test data. The primary output of the engineering analysis is a set of cost

- efficiency curves. In a subsequent life

- cycle cost (LCC) analysis (preliminary TSD chapter 8), DOE used the industry cost- efficiency curves to determine customer prices for each product analyzed in the engineering analysis by applying the appropriate distribution channel markup s.

5.2 METHODOLOGY OVERVIEW

DOE typically structures its engineering analysis around one of three methodologies: (1) the design-option approach, which calculates the incremental cost of adding specific design options to the baseline model; (2) the efficiency

- level approach, which calculates the relative costs of achieving increases in energy efficiency levels, without regard to the particular design options used to achieve such increases; and/or (3) the reverse engineering cost

- assessment approach, which involves a “bottom- up” manufacturing cost assessment based on a detailed bill of materials (BOM) derived from teardowns of products being analyzed. Deciding which methodology to use for the engineering analysis depends on the product, the technologies under

stu dy, and any historical data DOE can draw upon. To establish the industry cost- efficiency curves for ballasts, DOE used both the efficiency -level approach to identify incremental improvements in efficiency for each product and the cost- assessment approach t o develop a cost for each efficiency level.

DOE generally follows five steps in the engineering analysis:

Determine Representative Product Classes: DOE first reviews covered ballasts and the associated product classes. When multiple product classes exist

, DOE selects certain classes as “representative” and concentrates its analytical effort on these. DOE selects representative product classes primarily because of their high market volumes. For those product classes it does not analyze, DOE extrapolates the candidate standard levels (CSLs) from representative product classes to other product classes.5-2 

### Select Baseline Ballasts: For each representative product class, DOE establishes baseline ballasts. Generally, a baseline ballast is a commercially available ba llast that just meets existing Federal energy conservation standards and provides basic consumer utility. The baseline serves as a reference point for each product class, against which DOE measures changes from potential amended energy conservation standards. To determine energy savings and changes in price, DOE compares each higher energy

- efficiency level with the baseline unit.

If no standard exists for that specific ballast, the baseline ballast represents the typical ballast sold within a product class with the lowest ballast efficacy factor (BEF). To determine the BEF, DOE tests a range of ballasts from multiple manufacturers. Appendix 5 C presents the test results. DOE selects specific characteristics such as starting method, ballast factor (BF), and

i nput voltage to characterize the most common ballast. DOE also selects multiple ballasts in certain product classes to ensure consideration of different ballast types and their associated

consumer economics.

Select Candidate Lamp-and- Ballast Designs: DOE selects commercially available ballasts with a higher BEF as replacement s for each baseline ballast in the representative product classes by considering the design options identified in the technology assessment and screening analysis (preliminary TSD chap ter 4). DOE can identify many of the distinguishing design options associated with each ballast. However, at some levels, these design options cannot be identified by the product number or catalog description, and therefore are assumed to be used in

the ba llast to achieve a higher BEF. In identifying more efficacious substitutes, DOE uses a database of commercially available ballasts. DOE then tests these ballasts to establish their appropriate BEF. Appendix 5C presents the se test results. All BEF and BE va lues were calculated according to the active mode test procedure unless otherwise specified.

Because fluorescent lamp ballasts are designed to operate fluorescent lamps, DOE considers properties of the entire lamp and ballast system in the engineering anal ysis. Though ballasts are capable of operating several different lamp wattages, DOE chooses the most common fluorescent lamp used with each ballast for analysis. DOE develops the engineering analysis based on two substitution cases. In the first case, the consumer is not allowed to change the spacing of the fixture and therefore replaces one baseline ballast with a more efficacious ballast. In this case, light output is maintained to within 10 percent of the baseline system lumen

output. a



### Determine Candidate Standard Lev els

. DOE develops CSLs based on three factors: (1) the design options associated with the specific ballasts studied; (2) the ability of ballasts operating lamps across different lamp wattages to comply with the CSL of a given product class; and (3) the max imum technologically feasible efficacy level. In the second case , the consumer is allowed to change the spacing of the fixture. Therefore, the consumer either purchases more or fewer ballasts to maintain light output and DOE normalizes the light output relative to the baseline ballast

.

Conduct Price Analysis

. DOE generates a bill of materials by disassembling multiple manufacturers’ ballasts that span a range of efficiency levels for each of the representative

a In some instances ( e.g. , when switching from T12 to T8 ballasts), light output slightly exceeds these limits. These instances are discussed in more depth in the appropriate sections below.5-3 

### product classes. The BOMs descr ibe the product in detail, including all manufacturing steps required to make and/or assemble each part. DOE then develops a cost model that converts the BOMs and efficiency levels into MPCs. By applying derived manufacturer markups to the MPCs, DOE calculates the manufacturer selling prices (MSPs) b



### DOE was not able to generate a BOM for all ballasts in this engineering analysis. In these cases, DOE evaluated retail prices for those ballasts and estimated an MSP for each one. For fluorescent lamps, DOE referenced the retail price for those lamps in the rulemaking for general service fluorescent and incandescent reflector lamps (hereafter “the 2009 Lamps Rule”).and constructs industry costefficiency curves.

c



### The sections that follow discuss how DOE applies this methodology to each product class to create the engineering analysis and the methodology DOE used to develop ballast prices.

5.3 PRICING ANALYSIS OVERVIEW

Developing the MSP for different fluorescent lamp ballasts involved two main inputs: a teardown analysis to develop the MPC and a markup analysis to arrive at the MSP. Figure 5.3.1 shows the general breakdown of costs and profit associated with manufacturing and selling a product. The full cost of production is broken down into two main costs: the full production cost

or manufacturer production cost, and the non-production cost. The non-production cost plus profits is equal to the manufacturer markup. DOE totaled the cost of materials, labor, and direct

overhead used to manufact ure a product in order to calculate the MPC. d 

### 5.3.1 Section describes

how DOE arrived at the MPC. Section 5.3.2 describes how DOE established a markup that

estimates non -production costs and profit.

Figure 5.3.1 Manufacturer Selling Price

b The MSP is the price at which the manufacturer can recover a ll production and non

- production costs and earn a profit. Non

- production costs include selling, general, and administration (SG&A) costs, the cost of research and development, and interest.

c The final rule for general service fluorescent and incandescent reflector lamps was published in the Federal Register on July 14, 2009. It is available at http://edocket.access.gpo.gov/2009/pdf/E9

- 15710.pdf.

d When viewed from the company

- wide perspective, the sum of all material, labor, and overhead costs equals the

c ompany’s sales cost, also referred to as the cost of goods sold (COGS).5-4 

### 5.3.1 Manufacturer Production Costs

The MPC is composed of direct labor, direct material, and overhead costs. Direct material costs represent the direct purchase price of components (resistors, connecting wires, etc.). DOE

conduct ed customized teardown analyses for select commercially available fluorescent lamp ballasts. DOE also conducted a teardown analysis on some ballasts removed from a manufacturing facility before adding potting, a type of black pitch. For these ballasts, DOE needed to estimate the cost of potting material to calculate the full material and labor costs. Based on information provided by members of the potting industry, DOE estimated the material and labor costs for potting to be about 60 cents for the standard ballast enclosure, which is 1 x 1.5 x 8 inches. Therefore, DOE added 60 cents to the teardown estimates for “pre

- potting”

ballasts to estimate the full material and labor costs.

Manufacturers co mmented that the materials involved in ballast manufacturing are highly correlated to commodity pricing. Due to recent economic trends in the commodities market, the estimated MPCs could exhibit significant variation depending on the timeframe for componen t materials price quotes. The teardown estimates reflect component pricing for January 2009. DOE investigated how January 2009 estimates would change if a 5- year average of materials prices

w as used instead of a January 2009 spot price. As described in appendix 5A, DOE found the price variation to be insignificant and did not incorporate these material price changes into its analysis.

The direct labor costs include fabrication and assembly labor. The teardown results also

included estimates for direct labo r costs associated with the assembly of the product. Separate labor rates were used for components that required manual (hand) insertion versus those that

we re automated. Based on conversations with manufacturers, DOE assumed the ballasts were

manufactured in Mexico and China and applied the corresponding labor rates.

The teardown results did not include overhead estimates . Overhead includes indirect material and labor costs, maintenance, depreciation, taxes, and insurance related to assets. DOE

used finan cial data to estimate the overhead cost by calculating it as a percentage of the MPC.

DOE estimated the depreciation cost from a representative electronics fabrication company’s U.S. Securities and Exchange Commission (SEC) 10-k, finding it to be about 2.6 percent of the cost of goods sold or the MPC. To determine the material and labor percentage, DOE marked down aggregated confidential MSPs to an MPC using the manufacturer markup (section 5.3.2 ). Then, DOE computed the ratio of aggregated teardown -sourced material and

labor costs to the manufacturer markdown sourced MPC. DOE found the material and labor costs to be about 93.8 percent of the MPC. DOE then subtracted the materials and labor and depreciation percentages from 100 percent to back out the remainder of overhead as a percentage of MPC. Overhead was estimated to be 3.6 percent of the MPC, which is reasonable as electronics manufacturing generally has low overhead costs. DOE found overhead and depreciation to be about 6.2 percent of the MPC or 6.6 percent of the material and labor costs. The 6.6 percent factor was then used to mark up the material and labor costs contained in the teardown results to the full production cost or MPC.5-5 

### 5.3.1.1 Selection of Units

DOE carefully selected units for the teardown analysis to create useful data to estimate manufacturer production costs. DOE mapped out a matrix of product specifications and then compared ballasts that differ by only one attribute. Ballasts are described by a long list of specifications, so DOE concentrated on the specifications it expected to have the greatest effect on efficiency. This list included high versus regular advertised efficiency, maximum number of lamps driven, starting method, and universal versus single input voltage. In addition to strategically selecting ballast specification characteristics, DOE also selected common ballast models from major manufacturers. This choice helped DOE capture the most accurate incremental price difference by tearing down high volume, mainstream products.

Unfortunately, DOE was only able to select unpotted ballasts for the teardown analysis. Some ballast manufacturers add potting to the ballast enclosure to improve durability. The potting reduces vibration damage and acts as a hea t sink for the circuit board. Because the sticky potting inhibits visual observation of the components, DOE was unable to reverse engineer many ballasts through a teardown analysis. As a result, DOE only conducted teardowns for unpotted

ballasts and ballas ts removed from a manufacturing facility before the potting procedure. Section

5.3.3 discusses how DOE estimated prices for those ballasts it could not or chose not to tear

down.

DOE selected thirteen fluorescent lamp ballasts to teardown for the engineering analysis.

Table 5.3.1 lists the ballast types submitted for teardowns.

Table 5.3.1 Ballast Types for Teardowns

Ballast Starting

Method For Operation

of Input Voltage Regular vs. High Efficiency

1 PS 2 F32T8 Universal HE

2 PS 2 F32T8 Single REG

3 and 4 IS 2 F32T8 Universal HE

5 IS 2 F32T8 Universal REG

6 IS 2 F32T8 Single REG

7 IS 4 F32T8 Single REG

8 IS 4 F32T8 Universal REG

9 IS 4 F32T8 Univers al HE

10 and 11 IS 2 F59T8 Universal HE

12 IS 2 F59T8 Single REG

1 3 IS 2 F59T8 Universal REG



### 5.3.2 Manufacturer Markup

More efficient products typically have higher manufacturing costs than baseline products. To meet new or amended energy conservation standards, manufacturers often must introduce design changes to their existing products or discontinue less efficient products, resulting in

standards -compliant products that have higher MPCs than baseline products. Depending on the competitive environment for these particular products, some or all of the increased production costs can be “passed through” from manufacturers to customers in the form of higher purchase prices. As production costs increase, manufacturers also typically incur additional overhead at5-6 

### the factory and corporate levels. The MSP must cover both of these additional contributions to overhead if a company is to maintain its current level of profitability.

As discussed previously, overhead costs within the DOE model are a function of

investmen ts, material costs, labor costs, or total costs, depending on the overhead category. Together, materials, labor, and factory overhead comprise the manufacturer production cost. DOE applies another multiplier to the manufacturer production cost to account for corporate non-production costs and profit. This latter multiplier, the manufacturer markup, is the focus of

this section.

The manufacturer markup is an integral part of the overall markup from production costs to installation costs. However, the manufac turer markup is different than the other markups in the distribution chain (which includes wholesalers, distributors, retailers, contractors, etc.) that convert MSP to customer price. The customer prices and installation costs are key inputs to the

LCC ana lysis, payback period (PBP) analysis, and national impact analysis ( NIA ). Through the use of the manufacturer and distribution chain markups and installation costs, DOE can calculate the first costs that customers would face under the various efficiency levels. DOE evaluates the tradeoff between the increase in first cost and the resulting energy cost savings at each efficiency level in the LCC and PBP analyses (preliminary TSD chapter 8) and NIA analysis (preliminary TSD chapter 10). In this section, DOE presents its methodology for converting the MPCs to manufacturer selling prices using the manufacturer markup.

5.3.2.1 Manufacturer Selling Price

DOE calculated the MSP for fluorescent lamp ballasts by multiplying the MPC by the calculated manufacturer markup, which is explained below. In general, the manufacturer markup should ensure that the MSP of the product is high enough to recover the full cost of the product ( i.e. , full production and non-production costs), and yield a satisfactory profit.

5.3.2.2 Manufacturer Financial Information Sources

Publicly owned companies are required by law to disclose financial information on a regular basis by filing different forms with the U.S. Securities and Exchange Commission. The

SEC form 10 -K, filed by companies on an annual basis, provides a comprehensive overview of the company’s business and financial conditions. Relevant information in the 10- K reports includes the company’s revenues and direct and indirect costs. For the manufacturer markup,

DOE used 10 -K reports from publicly owned ballast manufacturing companies. The financial figures necessary for calculating the manufacturer markup are net sales, costs of sales, and gross profit. The income statement section of the 10- K reports often reports these figures.

DOE calculated th e manufacturer markup by using financial figures from manufacturers’

SEC 10

- K reports, such as the net sales (revenues) and cost of sales to calculate gross profit and gross profit margins. DOE used averages of the financial figures spanning 2002 to 2008 to calculate the markup.

DOE used the following equations to calculate the gross profit and gross profit margins:5-7 

### Equation 5.3-1

Gross Profit ($) = Net Sales

– Cost of Sales

Equation 5.3-2

Table 5.3.2 contains the calculated gross profit margins for four sample manufacturers.

Table 5.3.2 Gross Profit Margin for Four Fluorescent Lamp Ballast Manufacturers*

Parameter Industry

Weighted Average Manufacturer

A B C D

Net Sales Million $ 66,614 90,705 46,952 38,118 63,862

Cost of Sales Million $ 44,203 58,350 29,567 27,562 44,804

Gross Profit Million $ 22,411 32,355 17,385 10,556 19,057

Gross Profit Margin % 33.6 35.7 37.0 27.7 29.8
* Data taken from 2002, 2003, 2004, 2005, 2006, 2007, and 2008 SEC 10

- K reports.



### To calculate the time

- average gross profit margin for each firm, DOE first summed the gross profit for all the years and then divided the result by the sum of the net sales for those years. Each manufacturer’s markup was calculated as:

Equation 5.3-3

Table 5.3.3 shows the manufacturer markups using this method.

Table 5.3.3 Calculated Manufacturer Markups for Fluorescent Lamp Ballasts

Manufacturer Manufacturer Markup

Manufacturer A 1.55

Manufacturer B 1.59

Manufacturer C 1.38

Manufacturer D 1.43
Average 1.50



### DOE calculated the average manufacturer markup to be 1.50 based on the estimated market share of each manufacturer. In other words, fluorescent lamp ballast manufacturers, on average, sell their products to the next party in the distribution channel at 50 percent above the manufacturing production cost.

Although publicly owned companies file SEC 10-K reports, the financial information summarized is not always exclusive to t he fluorescent lamp ballast portion of their business. It can include financial information from other product sectors, whose margins could be quite different from those of the fluorescent lamp ballast industry. Therefore, during interviews, DOE5-8 

### asked manu facturers to provide both the manufacturer markup and the manufacturer selling price of fluorescent lamp ballasts sold through two main distribution chains: from the manufacturer to an original equipment manufacturer (OEM), and from the manufacturer to a d istributor.

DOE supplemented the information provided in Table 5.3.3 by estimating a weighted

average manufacturer markup . DOE used information from DOE’s 2000 Ballast Rule, which

estimates that ballasts sold to a distributor represent 37 percent of the market, while ballasts sold to an OEM fixture manufacturer represent 63 percent of the market. 1



### DOE used these multipliers in the engineering analysis to determine the MSPs for each representative product class. DOE used a constant markup to reflect the MSPs of the baseline products as well as more e fficient products. DOE took this approach because amended standards may make high-efficiency products, which currently are considered premium products, the

baseline and commodity products in the future. DOE then applied these weights to the manufacturer markups provided directly by manufacturers. DOE also applied these weights to a manufacturer markup calculated by comparing the manufacturer selling prices and the estimated MPC. After considering these two additional sources of information, DOE determined that a manufacturer markup of approximately 1.50 on an aggregate basis for the

f luorescent lamp ballast industry was appropriate.

5.3.3 MSP Scaling

To estimate M SP s for additional ballasts types, DOE used online ballast supplier pricing to develop ratios relating online prices to teardown

- sourced MSPs. Using these ratios, DOE estimated MSPs for additional ballasts based on their online price.

To do this, DOE compiled an online price databa se for ballasts. Ballasts produced by the same manufacturer were assigned prices from one online supplier. In this way, DOE eliminated pricing variability among different online suppliers. Next, DOE created a manufacturer- specific ratio of online price to MSP for certain two -lamp 32- watt (W) electronic ballasts (ballasts 1 through 6 in Table 5.3.1 ). DOE believed these ratios to be representative of other product classes as well as those that operate two 32 W 4 -foot medium bipin lamps.

DOE then estimated MSPs for additional ballasts. For a given efficiency level, DOE identified comparable ballast examples across multiple manufacturers and obtained online prices for each ballast. DOE continued to use the same online suppliers for each manufacturer to be consistent with the development of the MSP ratios. DOE divided the online price by the MSP ratio to estimate the MSP for each ballast. Finally, the MSP for a particular CSL was estimated as an average of the MSPs of the various balla sts that just meet that CSL.

5.4 REPRESENTATIVE PRODUCT CLASSES

As discussed in the market and technology assessment (preliminary TSD chapter 3),

DOE is considering revising the Energy Policy and Conservation Act (EPCA) table of standards

for ballasts to co ntain 70 product classes (5-9 

### Table 5.4.1 ) . DOE chose to analyze at least one representative product class for each lamp type analyzed. For the most prevalent ballast type (ballasts that operate 4 -foot medium bipin (M BP ) and 2-foot U-shaped lamps), DOE chose to analyze multiple representative product classes. U.S. Census data indicate that approximately 50 percent of ballasts that operate F32T8 lamps (the most common 4-foot MBP lamp) are one and two- lamp ballasts while the remaining 50 percent are three - and four- lamp ballasts. 2 

### Based on its discussions with manufacturers and industry experts, DOE estimates that approximately 40 percent of ballasts that operate F32T8 lamps are two -lamp ballasts, 30 percent are four- lamp ballasts, 20 percent are three

- lamp ballasts, and the remaining 10 percent are one- lamp ballasts. U.S. Census data also indicates that the vast majority of ballasts that operate 4 -foot MBP T12 lamps are two- lamp ballasts. Therefore, DOE chose to concentrate on analyzing four-lamp and two- lamp ballasts that operate 4-foot MBP lamps and all starting methods for these ballasts. Although instant start (IS) and rapid start (RS) ballasts are the most common ballasts that operate 4

- foot MBP lamps, programmed star t (PS) ballasts are growing in market share. DOE limited its study to only

include those ballasts that exhibit a normal ballast factor (BF) , as this BF is the most common e



### .

DOE estimates the majority of ballasts that operate 4 -foot T5 miniature bipin (Min iBP)

standard -output (SO) lamps, 8-foot single pin (SP) lamps, 8-foot high output (HO), and

residential 4

- foot MBP lamps are two

- lamp ballasts. Therefore, DOE analyzed the two

- lamp ballast representative product class for these lamp types. DOE also decided to study only the

two

- lamp representative product class for ballasts that operate 4 -foot T5 MiniBP HO. Based on discussions with manufacturers and industry experts, DOE estimates that approximately 60 percent of ballasts that operate 4 -foot T5 MiniBP HO l amps are two

- lamp ballasts, 30 percent are

three

- lamp ballasts, and the remainder are one

- lamp or four- lamp ballasts. DOE chose to analyze

four- lamp sign ballasts because industry experts report these are the most common sign ballasts.

For all commercial ballast types, DOE limited its study to those ballasts that exhibit a normal ballast factor as this BF is the most common. DOE also chose to study only the IS and RS product class for ballasts that operate 8 -foot HO and residential 4- foot MBP lamps as these are the most common starting methods for these ballasts.

Although DOE did not create a separate engineering analysis for many product classes, DOE established standards for these product classes based on the representative product classes directly analyz ed. For instance, DOE extended its proposal for ballasts that operate two 4-foot T5 MiniBP HO lamps by testing ballasts that operate one, three, and four lamps and determining an appropriate scaling factor. Section 5.13 provides more information on extending standards to the product classes DOE did not analyze.

e DOE defines low ballast factor as being less than or equal to 0.78, normal ballast factor as being greater than 0.78 but less than 1.10, and high ballast factor as being greater than or equal to 1.10.5- 10 

### Table 5.4.1 DOE Product Classes for Fluorescent Lamp Ballasts

Ballast and Lamp Type Starting

Method Ballast

Factor Number of Lamps

One Two Three Four Five Six

Four

- Foot MBP and Two

- Foot

U- Shaped IS and RS High 1 2 3 4 5 6

Normal 7 8 9 10 11 12

Low 13 14 15 16 17 18

PS High 19 20 21 22 23 24

Normal 25 26 27 28 29 30

Low 31 32 33 34 35 36

Four

- Foot T5 Mini BP SO All High 37 38 N/A N/A N/A N/A

Normal 39 40 N/A N/A N/A N/A

Low 41 42 N/A N/A N/A N/A

Four

- Foot T5 MiniBP HO All All 43 44 45 46 N/A N/A

Eight

- Foot SP Slimline All High 47 48 N/A N/A N/A N/A

Normal 49 50 N/A N/A N/A N/A

Low 51 52 N/A N /A N/A N/A

Eight

- Foot RDC HO IS and RS All 53 54 N/A N/A N/A N/A

PS All 55 56 N/A N/A N/A N/A

Residential Ballast, Four

- Foot

MBP and Two

- Foot U

- Shaped IS and RS All 57 58 59 60 N/A N/A

PS All 61 62 63 64 N/A N/A

Sign Ballast, All Lamp Types All All 65 66 67 68 69 70

Shading indicates a representative product class.



### 5.5 BALLASTS THAT OPERATE TWO FOUR

- FOOT MBP AND TWO

- FOOT U

SHAPED LAMPS

DOE analyzed multiple efficiency levels and estimated the MPC and MSP for each of the representative product classes presented in section 5.4

. In this section, DOE analyzes the representative product classes designated by numbers 8 and 26 in the table below. All BEF and

BE values presented in this section were calculated according to the ac tive mode test procedure unless otherwise specified.5- 11 

### Table 5.5.1 Representative Product Classes for Ballasts that Operate Two Four

- Foot MBP

and Two -Foot U- Shaped Lamps

Ballast and Lamp Type Starting

Method Ba llast

Factor Number of Lamps

One Two Three Four Five Six

Four

- Foot MBP and Two

- Foot

U- Shaped IS and RS High 1 2 3 4 5 6

Normal 7 8 9 10 11 12

Low 13 14 15 16 17 18

PS High 19 20 21 22 23 24

Normal 25 26 27 28 29 30

Low 31 32 33 34 35 36

Shading indicates a representative product class.



### 5.5.1 Baseline Models

DOE selected baseline models as reference points for each product class, against which DOE measured changes resulting from potential amended energy conservation standards. As

discussed in section 5.2 , a baseline ballast just meets current Federal energy conservation standards and provides basic consumer utility. To determine energy savings and changes in price, DOE compared each higher energy efficiency level with the baseline unit.

DOE chose to analyze two baseline ballasts f or the two

- lamp 4 -foot and 2-foot U- shaped MBP IS and RS normal BF product class (designated by product class 8 in Table 5.5.1 ; hereafter

referred to as the IS and RS representative product class) . Census data indicate that 2001 shipments of 4-foot and 2-foot U- shaped MBP T12 ballasts represented 14 percent of all 4-foot

and 2-foot U- shaped MBP ballast shipments, while 4 -foot and 2-foot U- shaped MBP T8 ballasts

r epresented 86 percent of all 4-foot and 2-foot U- shaped MBP ballast shipments. f



### Table 5.5.4 Therefore, DOE analyzed both T12 and T8 ballasts as a baseline ballast. Because the 2009 Lamps Rule eliminated all currently commercially available T12 lamps by 2012, DOE created an F34T12 lamp that complied with the 2009 Lamps Rule to pair with T12 ballasts (see ). DOE chose to analyze only those T12 ballasts that operate F34T12 lamps b ecause only the most efficient T12 lamps will be available when this ballast rulemaking takes effect . For the T8 baseline, DOE chose to analyze only those ballasts that operate the F32T8 lamp because it is the most common 4-foot MBP T8 lamp.

DOE considered the ballast’s characteristics i n choosing the most appropriate F32T8 and F34T12 ballasts for the IS and RS product class. These characteristics include d the ballast’s starting method ( e.g. , RS, or IS), input voltage (277 volts (V) vs. 120V), power factor (PF), total harmonic distortion (THD), ballast factor, input power, BEF, and type (electronic vs. magnetic),

and whether the ballast can operate at multiple voltages g

f More recent census data for ballasts are available. However, shipments of T12 ballasts have not been publicly released for all product classes after 2001. DOE used 2001 Census data for all analysis in this chapter. 

### (universal voltage) or only one (single voltage). Finally, DOE considered whether the ballast just meets existing Federal minimum

g Universal voltage ballasts can operate at 120V or 277V.5- 12 

### energy conserv ation standards. In considering each of these characteristics, DOE chose a

baseline ballast that exhibits the characteristics of the least efficient and most common ballast.

The Federal minimum energy conservation standard for ballasts that operate two F34T12 lamps became effective for ballasts manufactured on or after July 1, 2009. (10 CFR Part 430.32 (m)(5)). This energy conservation standard effectively allowed only electronic F34T12 ballasts. Therefore, DOE chose an electronic ballast as the F34T12 bas eline ballast. To determine the BEF of the baseline ballast, DOE tested multiple ballasts operating a reference F34T12 lamp. The BEF, BF and input power of the most common T12 ballast that just meets the minimum energy conservation standard of 1.35 is shown in Table 5.5.2 below. The majority of F34 T12 electronic ballasts in product catalogs are RS, single voltage, have a high PF (~0.98) and a THD <20 percent. The ballast that just meets the energy conservation standard also exhibits these characteristics. DOE also chose a ballast that has an input voltage of 277V ballast because the majority of ballasts operate in commercial buildings at 277V.

Currently there is no federal minimum energy conservation standard for ballasts that operate F32T8 lamps. Therefore, in choosing the baseline ballast for this lamp type, DOE chose the most common, least efficient ballast on the market. DOE tested a range of F32T8 ballasts from multiple ballast manufacturers and found that the least efficient b ut most common ballast

exhibited the characteristics shown in Table 5.5.2 below. The vast majority of T8 ballasts are IS, electronic, and have a high PF (>0.98). Furthermore, the least efficient T8 ballasts are single voltage and have a THD <20 percent. Finally, like the F34T12 baseline ballast, DOE chose a ballast that has an input voltage of 277V as the majority of ballasts operate in commercial buildings at 277V.

Table 5.5.2 Baseline Ballasts for the IS and RS Representative Product Class

For operation

of Starting Method, Input Voltage, Ballast Type, PF, THD BF Input

Power

W Ballast Efficiency BEF Federal Energy

Conservation

Standard

2, F34T12

lamps RS, 277V, Electronic, Single Vo ltage >0.98 PF,

<20% THD 0.86 63.5 80.1%* 1.359 1.35

2, F32T8

lamps IS, 277V, Electronic, Single Voltage, >0.98
PF, <20% THD 0.88 60.4 85.4%* 1.450 N/A

* DOE was unable to test the efficiency of these particular ballast s . DOE estimates are based on the

re lationship between BEF and ballast efficiency determined by the active mode test procedure

. For the IS and RS representative product class, t he BEF of a ballast is related to ballast efficiency in the following

manner: BEF= 1.697 *BE

.



### For the 2- lamp 4 -foot MBP and 2- foot U -shaped PS normal BF product class (designated by product class 26 in Table 5.5.1 ; hereafter referred to as the PS representative product class)

, DOE found that only F32T8 ballasts operate in this product class. DOE tested a range of F32T8 PS ballasts from multiple ballast manufacturers and found that the least efficient of these ballasts

exhibited the characteristics shown in Table 5.5.3 below. This ballast does not use cathode cutout technology to reduce power, and thus exhibits a higher input power and lower BEF than

ballasts that have cathode cut -out technology. This ballast also, like the majority of PS ballasts on the market is electronic, has a high PF (~0.98), has a low THD (<10 percent), and is universal voltage.5- 13 

### Table 5.5.3 Baseline Units for the PS Representative Product Class

For operation of Starting Method, Input Voltage, Ballast Type, PF, THD BF Input

Power Ballast Efficiency BEF Federal Energy

Conservation Standards (EF)

2, F32T8

lamps PS, 277V, Electronic,
>0.99, <10% THD, Universal Voltage 0.90 63.5 84.3% 1.418 N/A



### DOE paired both commercial and industrial 4-foot and 2- foot U

- shaped MBP ballasts with an appropriate F34T12 and F32T8 lamp. DOE chose 4-foot lamps that just meet the energy conservation standard (ECS) issued in the 2009 Lamps Rule, which becomes effective in 2012, as these will be the most common lamps available after the ballast rule takes effect. The 2009 Lamps Rule proposed a standard that eliminated T12 lamps that are currently commercially available. However, the 2009 Lamps Rule did not prohibit manufacturers from developing a more efficient T12 lamp that can meet the standard by the time the rulemaking takes effect in

2012. Because the ballast rulemaking takes effect in 2014, the efficacy of T12 lamps can potentially be improved by the use of rare earth phosphor to a point at which it complies with the 2009 Lamps Rule. Therefore, DOE paired T12 ballasts with a T12 lamp it invented that just meets the energy conservation standard adopted by the 2009 Lamps Rule. The characteristics of the T12 and T8 lamps paired with 4- foot MBP ballasts in this rulemaking are listed in the table

below.

Table 5.5.4 Lamps for Use with F32T8 and F34T12 Ballasts

Lamp Type CCT Rated Efficacy* Initial Light Output Mean Light Output Life CRI

K lm/W lm lm hr

F34T12 4,100 92.3 3,138 2,825 24,000 N/A

F32T8 4,100 92.3 3,000 2,850 24,000 8 5

* Rated efficacy is based on the rated wattage of the lamps, which is 34W for the F34T12 lamp

, and

32.5W for the F32T8 lamp

.



### These combinations of lamps and ballasts represent the most common configurations for these ballasts in existing and new insta llations. Together, these lamp and ballast combinations create a system lumen package of approximately 4,872 mean lumens (and 5,412 initial lumens) for the baseline F34T12 ballast, approximately 4,988 mean lumens (and 5,250 initial lumens) for the

baselin e F32T8 IS ballast, and approximately 5,110 mean lumens (and 5,379 initial lumens) for

the baseline F32T8 PS ballast.

5.5.2 Candidate Standard Levels

For the 2- lamp 4 -foot and 2-foot U- shaped MBP product classes, DOE conducted a survey of the fluorescent lamp b allast market to determine what types of products are available to consumers. For each representative product class , DOE surveyed and tested many of the manufacturers’ product offerings for BEF and ballast efficiency to identify the efficiency levels

corre sponding to the highest number of models. DOE identified the most prevalent BEF values in the range of available products and established CSLs based on those products. Because the5- 14 

### baseline ballasts have different BEF values and represent various design opt ions, in some product classes CSLs affect only one of the two baseline lamps. For example, CSL1 may require a more efficient T12 ballast than the baseline T12 ballast, but not require a ballast more efficient than the T8 baseline. However, the full range o f CSLs ultimately specifies requirements that are above the BEF values of all the baseline ballasts sold, and therefore affect all baseline ballasts. Finally, DOE determined the maximum improvement in BEF that is technologically feasible (“max

- tech”) for f luorescent lamp ballasts, as required by section 325(o) of EPCA. (42 U.S.C. 6295(o)). To determine this level, DOE conducted a survey of the fluorescent lamp ballast market and the research fields that support the market. DOE believes that within a given p roduct class, no working prototypes exist that have a distinguishably higher BEF than currently available ballasts. Therefore the highest CSL presented, which represents the most efficient tier of commercially available ballasts, is the max

- tech level that DOE determined for this preliminary rulemaking. However, DOE presents additional research in appendix 5D of the preliminary TSD to explore whether technologies used in products similar to ballasts can be used to improve the efficiency of ballasts currentl y on the market. See appendix 5D for a detailed discussion of these technologies.

The following section identifies the steps and technologies associated with each CSL

DOE considered for the IS and RS representative product class. As discussed in the scree ning analysis (preliminary TSD chapter 4), DOE used design options that achieve a higher BEF than the baseline ballast. Because the baseline ballast is an electronic ballast, improvements required the use of the following design options: lamp diameter, improved components, and improved circuit design.

CSL1 . BEF: 1.450; Efficiency: 85.4 percent

This level affects the F34T12 baseline ballast but not the F32T8 baseline ballast. It requires the use of improved lamp diameters (T8 instead of T12). Therefore, no T12 ballasts meet this level. In addition, ballasts must use improved circuit designs (a starting method that is IS rather than RS).

CSL2 . BEF: 1.535; Efficiency: 90.5 percent

This level affects the both baseline ballasts. However, no T12 ballast that is commercially available can meet this level. Ballasts at this level use better components and more efficient circuit designs than those ballasts that just meet CSL1.

CSL3 . BEF: 1.561 ; Efficiency: 9 2.0 percent

This level again affects the both baseline ballasts and represents the maximum technologically feasible level. This level represents a modest improvement in efficiency over CSL2. Ballasts at this level use slightly better components and circuit designs than those ballasts that just meet

CSL2.5- 15 

### Table 5.5.5 Summary of the CSLs for Two

- Lamp Four

- Foot MBP RS and IS Normal BF

Ballasts

Candidate Standard Level BEF Requirement

CSL1 1.450

CSL2 1.5 35

CSL3 1.5 61



### Figure 5.5.1 illustrates the three CSLs on a plot of fluorescent lamp ballasts DOE selected to analyze. A line at 1.350 denotes the existing energy conservation standard. Square boxes and labels identify the two baseline ballasts. The plot shows replacement ballasts DOE considered for each baseline ballast at higher efficacies.

1.30 1.35 1.40 1.45 1.50 1.55 1.60

31 32 33 34 35Ballast Efficacy Factor (BEF)



### Nominal Lamp Wattage (W) CSL3

CSL2

CSL1

EPCA F34T12 F32T8

F32T8 Baseline

F34T12 Baseline



### Figure 5.5.1 Candidate Standard Levels for the IS and RS Representative Product Class

The following discussion identifies the steps and technologies associated with each CSL

DOE considered for the PS representative product class. As discussed in the screening analysis (preliminary TSD chapter 4), DOE considered design options that achieve a higher BEF than the baseline ballast. Because the baseline ballast is a T8 electronic ballast, improvements required the use of the following design options: improved components, and improved circuit design. For PS ballasts, DOE identified only one CSL. This CSL represents the maximum technologically

feasible level.5- 16 

### CSL1

. BEF: 1.51 8; Efficiency: 90.2 percent

This level requires the use of improved circuit designs for the PS ballast. Specifically, ballasts at

this level must use cut

- out cathode heating of the filament after the lamp starts.

Figure 5.5.2 illustrates the CSL on a plot with the baseline and standards -compliant ballast. The square box and label identifies the baseline ballast. The plot also shows the replacement ballast DOE is considering at CSL1.

1.41 1.43 1.45 1.47 1.49 1.51

31 32 33Ballast Efficacy Factor (BEF)



### Nominal Lamp Wattage (W) CSL1

F32T8 PS Baseline



### Figure 5.5.2 Candidate Standard Levels for the PS Representative Product Class

Table 5.5.6 and Table 5.5 .7 provide detailed information on the 4- foot MBP ballast designs used in the engineeri ng analysis and subsequent analyses. In general, for the IS and RS representative product class, ballasts at higher efficiencies can operate at multiple voltages, have a lower THD, and similar BF and PF as the baseline ballast designs. For the PS represent ative product class, the ballast characteristics are very similar.5- 17 

### Table 5.5.6 Ballast Designs for the IS and RS Representative Product ClassCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast Efficiency

V W

Baseline 2 F34T12 Lamps Electronic RS 277 Single >0.98 <20% 0.86 63.5 1.359 80.1%*

Baseline

/CSL1 2 F32T8 Lamps Electronic IS 277 Single >0.98 <20% 0.88 60.4 1.450 85.4%*

CSL2 2 F32T8 Lamps Electronic IS 277 Universal >0.98 <10% 0.86 56.0 1.535 90.5%

CSL3 2 F32T8 Lamps Electronic IS 277 Universal >0.97 <10% 0.87 56.4 1.561 92.0%

* DOE was unable to test the efficiency of these particular ballast s . DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the IS and RS representative product class, t he BEF of a ballast is related to ballast efficiency in the f ollowing manner: BEF= 1.697 *BE

.



### Table 5.5.7 Ballast Designs for the PS Representative Product ClassCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast Efficiency

V W

Baseline 2 F32T8 Lamps Electronic PS 277 Universal >0.99 <10% 0.90 63.5 1.418 84.3%

CSL1 2 F32T8 Lamps Electronic PS 277 Universal >0.98 <10% 0.86 56.9 1.518 90.2%



### 5.5.3 Lamp and Ballast Prices

DOE analyzed each CSL forthe IS and RS representative product class to develop appropriate MSPs. For the F34T12 baseline ballast, DOE used the online price scaling technique

described in section 5.3.3 . For all F32T8 ballasts, DOE generated an MSP from teardowns. As

shown in Table 5.5.8 , DOE found the MSP for the F34T12 ballast was higher than any of the

F32T8 ballasts. The F34T12 electronic ballast is sold at lower volumes than the electronic F32T8 ballasts represented by CSL1, CSL2, and CSL3. DOE attributes the smaller shipments volume to its high cost relative to its efficiency. In addition, physical teardown information suggests that

the efficient F32T8 ballast at CSL3 is le ss costly than the less efficient CSL2 ballast, but both CSL2 and CSL3 are more costly than CSL1.5- 18 

### Table 5.5.8 Summary of the Manufacturing Selling Prices for the IS and RS Representative Product Class

Can didate Standard Level Lamp Type Starting Method MSP $

Baseline F34T12 RS 10. 26

Baseline/CSL1 F32T8 IS 7. 43

CSL2 F32T8 IS 10.01

CSL3 F32T8 IS 8. 93



### DOE analyzed each CSL for the PS representative product class to develop appropriate

MSPs . DOE derived the baseline MSP from a teardown and the CSL1 MSP from the online price scaling technique. DOE found that the MSP increased with increased efficiency for this product class as depicted in Table 5.5.9

.

Table 5.5.9 Summary of the Manufacturing Selling Prices for the PS Representative

Product Class

Candidate Standard Level Lamp Type Starting Method MSP $

Baseline F32T8 PS 8. 98

CSL1 F32T8 PS 12.49



### The following table depicts the appr opriate lamp prices for the baseline lamps as used in the 2009 Lamps Rule. Although DOE calculated the performance characteristics of a T12 lamp such that it would comply with the standard adopted by the 2009 Lamps Rule, DOE assumed that the price of this T12 lamp would be the same as the representative T12 lamp that met trial standard level (TSL) 3 in the 2009 Lamps Rule. DOE believes that both TSL3 in the 2009 Lamps Rule and the market situation in 2014 are instances in which a very efficient T12 lamp com petes directly with cheaper T8 lamps. Therefore, DOE believes that price competition will prevent manufacturers from raising the price of T12 lamps any higher than the price at which the most efficient T12 lamps are currently sold.

Table 5.5.10 Retail Prices for Four

- Foot Medium Bipin Fluorescent Lamps

Lamp Type Retail Price (2007$)

F34T12 $5.83

F32T8 $2.82



### 5.5.4 Results

As discussed above, DOE evaluated multiple baseline ballasts for the relevant product

clas ses to provide a comprehensive understanding of the consumer economics. DOE based its5- 19 

### engineering analysis on two substitution cases. In the first case, the consumer is not allowed to change the spacing of the fixtures and therefore replaces one baseline ballast with a more efficacious ballast. In this case, light output is maintained to within 10 percent of the baseline system lumen output. Percentage change in mean lumen output is shown in Table 5.5.11 through

Table 5.5.13 . In the second case, the consumer is allowed to change the spacing of the fixture. To show how energy savings would change due to this change in fixture spacing, DOE shows the normalized system input power. The following formula is used to normalize the system input power of the standards- case system to the mean lumen output of the baseline system:

Equation 5.5-1

dardsCase S

dardsCase S Baseline

dardsCase S 

### InputPower MLO MLO InputPower Normalized

tan

tan tan 

### ∗ **=**

dardsCase S 

### InputPower Normalized

tan 

### = Input power of the standards- case system that

matches the light output of the baseline system

Baseline 

### MLO = Mean lumen output of the baseline system

dardsCasee S 

### MLO

tan 

### = Mean lumen output of the standards- case system

dardsCasee S 

### InputPower

tan 

### = Input power of the standards- case system

Table 5.5.11 th rough Table 5.5.13 also present the retail price of the replacement lamps (e.g, if it is a 2

- lamp system the retail price is the price of two lamps). Table 5.5.11 presents the engineering characteristics of the ballast replacement options for the baseline F32T8 system in

the IS and RS representative product class. Because the BFs of the standards

- case systems are slightly lower than the baseline sy stem, the normalized input power is slightly higher than the measured input power. If a direct substitution is made, mean lumen output does not change by more than 2 percent relative to the mean lumen output of the baseline system.5- 20 

### Table 5.5.11 IS and RS Representative Product Class with F32T8 BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline

/CSL1 2 F32T8 Lamps Electronic IS 277 Single >0.98 <20% 0.88 60.4 1.450 85.4% * 5,250 4,988 N/A 7.43 5.65 60.4

CSL2 2 F32T8 Lamps Electronic IS 277 Universal >0.98 <10% 0.86 56.0 1.535 90.5% 5,161 4,903

- 1.7% 10.01 5.65 57.0

CSL3 2 F32T8 Lamps Electronic IS 277 Universal >0.97 <10% 0.87 56.4 1.561 92.0% 5,242 4,980

- 0.2% 8.93 5.65 56.5

* DOE was unable to test the efficiency of these particular ballast s . DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the IS and RS representative product class, the BEF of a ballast is related to ballast efficiency in the following manner:

BEF= 1.697 *BE

.



### Table 5.5.12 presents the engineering characteristics of the ballast replacement options for the baseline F34T12 system in the IS and RS representative product class. If a direct substitution is made, mean lumen output does not change by more than 3 percent relative to the mean lumen output of the baseline system.

Table 5.5.12 IS and RS Representative Product Class with F34T12 BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 2 F34T12 Lamps Electronic RS 277 Single >0. 98 <20% 0.86 63.5 1.359 80.1% * 5,412 4,872 N/A 10.26 11.65 63.55- 21 CSL1 2 F32T8 Lamps Electronic IS 277 Single >0.98 <20% 0.88 60.4 1.450 85.4% * 5,250 4,988 2.4% 7.43 5.65 59.0

CSL2 2 F32T8 Lamps Electronic IS 277 Universal >0.98 <10% 0.86 56.0 1.535 90.5% 5,161 4,903 0.6% 10.01 5.65 55.7

CSL3 2 F32T8 Lamps Electronic IS 277 Universal >0.97 <10% 0.87 56.4 1.561 92.0% 5,242 4,980 2.2% 8.93 5.65 55.2

* DOE was unable to test the efficiency of these particular ballast s . DOE estimates are based on the relations hip between BEF and ballast efficiency determined by the active mode test procedure

. For the IS and RS representative product class, the BEF of a ballast is related to ballast efficiency in the following manner: BEF= 1.697 *BE

.



### Tab le 5.5.13 presents the engineering characteristics of the ballast replacement options for the baseline F32T8 system in the PS representative product class. If a direct substitution is made, mean lumen output does not change by more than 4 percent relative to the mean lumen output of the baseline system.

Table 5.5.13 Four

- Foot MBP PS Product ClassCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 2 F32T8 Lamps Electronic PS 277 Universal >0.99 <10% 0.90 63.5 1. 418 84.3% 5, 379 5, 110 N/A 8.98 5.65 63.5

CSL1 2 F32T8 Lamps Electronic PS 277 Universal >0.98 <10% 0.86 56. 9 1.51 8 90.2% 5,1 76 4,9 17

- 3. 8 12.49 5.65 59. 15-22 

### 5.6 BALLASTS THAT OPERATE FOUR FOUR

- FOOT MBP AND TWO

- FOOT U

SHAPED LAMPS

In this section, DOE analyzes the representative product classes designated by numbers 10 and 28 in the table below. All BEF and BE values presented in this section were calculated according to the active mode test procedure unless otherwise specified.

Table 5.6.1 Representative Product Classes for Ballasts that Operate Four Four

- Foot MBP

and Two -Foot U- Shaped Lamps

Ballast and Lamp Type Starting

Method Ba llast

Factor Number of Lamps

One Two Three Four Five Six

Four

- Foot MBP and Two

- Foot

U- Shaped IS and RS High 1 2 3 4 5 6

Normal 7 8 9 10 11 12

Low 13 14 15 16 17 18

PS High 19 20 21 22 23 24

Normal 25 26 27 28 29 30

Low 31 32 33 34 35 36

Shading indicates a representative product class.



### 5.6.1 Baseline Models

Although census data indicates that both T12 and T8 ballasts that operate 4-foot and 2-

foot U- shaped MBP lamps exist in the market, DOE research found that only T8 ballasts operate

four lamps. Therefore, DOE analyzed only a T8 ballast as a baseline ballast for the 4

- lamp 4 -foot and 2-foot U-shaped MBP IS and RS normal BF product class (designated by product class 10 in

Table 5.6.1 ; hereafter referred to as the I S and RS representative product class) . Furthermore, DOE chose to analyze only those ballasts that operate the F32T8 lamp because this lamp is the most common 4-foot MBP T8 lamp.

In choosing the most appropriate F32T8 ballast for this product class, DOE considered the ballast’s characteristics. Because there is no Federal energy conservation standard, DOE

chose a baseline ballast that exhibits the characteristics of the least efficient and most common

ballast.

DOE tested a range of F32T8 ballasts from multiple ballast manufacturers and found that

the least efficient but most common ballast exhibited the characteristics shown in Table 5.6.2 below. The vast majority of T8 ballasts are IS, electronic, and have a high PF (>0.99).

Furth ermore, the majority of the least efficient T8 ballasts are single voltage and have a THD <10 percent. Finally, DOE chose a ballast that has an input voltage of 277V as the majority of ballasts operate in commercial buildings at 277V.5- 23 

### Table 5.6.2 Baseline Ballasts for the IS and RS Representative Product Class

For Operation

of Starting Method, Input Voltage, Ballast Type, PF, THD BF Input

Power

W Ballast Efficiency BEF Federal Energy

Conservation

Standard

4, F32T8

Lamps IS, 277V, Electronic, Single Voltage, >0.99
PF, <10% THD 0.84 111.5 90.5% 0.768 N/A



### For the 4- lamp 4 -foot MBP and 2- foot U -shaped PS normal BF product class (designated by product class 28 in Table 5.6.1 ; hereafter referred to as the PS representative product class)

, DOE also found that only F32T8 ballasts operate in this product class. DOE tested a range of F32T8 PS ballasts from multiple ballast manufacturers and found that the least efficient of these

ballasts exhibited the characteristics shown in Table 5.6.3 . This ballast does not use cathode cutout technology to reduce power, and thus exhibits a higher input power and lower BEF than

ballasts that have cathode cut -out technology. This b allast also, like the majority of PS ballasts on the market is electronic, has a high PF (~0.99) and has a low THD (<10 percent).

Table 5.6.3 Baseline Ballasts for the PS Representative Product Class

For Oper ation

of Starting Method, Input Voltage, Ballast Type, PF, THD BF Input

Power

W Ballast Efficiency BEF Federal Energy

Conservation

Standard

4, F32T8

Lamps PS, 277V, Electronic, Single Voltage, 0.99

PF, <10% THD 0.87 120.3 83.9% 0.708 N/A



### DOE paired bot h commercial and industrial 4 -foot and 2- foot U

- shaped MBP ballasts with an appropriate F32T8 lamp. As discussed above, DOE chose 4- foot lamps that just meet the ECS issued in the 2009 Lamps Rule (which becomes effective in 2012) as these will be the most common lamps available after the ballast rule takes effect. 74 FR 34080 (July 14, 2009). The characteristics of these lamps are listed in the table below.

Table 5.6.4 Lamp for Use with F32T8 Ballasts

Lamp Typ e CCT Rated Efficacy* Initial Light Output Mean Light Output Life CRI

K lm/W lm lm hr

F32T8 4,100 90.8 3,000 2,850 20,000 85

* Rated efficacy is based on the rated wattage of the lamps, which for the F32T8 lamp is 32.5W.



### This combination of lamp and ballast represents the most common configuration for these ballasts in existing and new installations. Together, this lamp and ballast combination creates a system lumen package of approximately 9,545 mean lumens (and 10,048 initial lumens) for the

basel ine F32T8 IS ballast and approximately 9,863 mean lumens (and 10,382 initial lumens) for

the baseline F32T8 PS ballast.5- 24 

### 5.6.2 Candidate Standard Levels

The following discussion identifies the steps and technologies associated with each CSL

DOE considered for th e IS and RS representative product class. As discussed in the screening analysis (preliminary TSD chapter 4), DOE used design options that achieve a higher BEF than the baseline ballast. Because the baseline ballast is an electronic T8 ballast, improvements required the use of the following design options: improved components and improved circuit design. For 4 -lamp ballasts, DOE identified only one CSL. This CSL represents the maximum technologically feasible level

CSL1 . BEF: 0.781; Efficiency: 92.0 percent

This level represents a modest improvement over the baseline efficiency. This level also represents the maximum technologically feasible level. Ballasts at this level use slightly better components and circuit designs than those ballasts that meet the bas eline level.

Figure 5.6.1 illustrates the baseline and CSL on a plot of fluorescent lamp ballasts DOE is selecting to analyze. The square box and label identifies the baseline ballast. The plot also shows the replacement ballast DOE is considering at CSL1.

0.760 0.762 0.764 0.766 0.768 0.770 0.772 0.774 0.776 0.778 0.780 0.782 0.784 0.786 0.788 0.790

31 32 33Ballast Efficacy Factor (BEF)



### Nominal Lamp Wattage (W) CSL1

F32T8 RS&IS Baseline



### Figure 5.6.1 Candidate Standard Levels for the IS and RS Representative Product Class5- 25 

### The following discussion identifies the steps and technologies associated with each CSL

DOE considered for the PS representative product class. As discussed in the screening analysis (preliminary TSD chapter 4), DOE considered design options that achieve a higher BEF than the

baseline ballast. Because the baseline ballast is a T8 electronic ball ast, improvements required the use of the following design options: improved components and improved circuit design. For PS ballasts, DOE identified only one CSL. This CSL represents the maximum technologically

feasible level.

CSL1 . BEF: 0.755 ; Efficiency: 89.4%

This level requires the use of improved circuit designs for the PS ballast. Specifically, ballasts at

this level must use cut

- out cathode heating of the filament after the lamp starts.

Figure 5.6.2 illustrates the baseline and CSL on a plot of fluorescent lamp ballasts DOE is selecting to analyze. The square box and label identifies the baseline ballast. The plot also shows the replacement ballast DOE is considering at CSL1.

0.700 0.705 0.710 0.715 0.720 0.725 0.730 0.735 0.740 0.745 0.750 0.755 0.760 0.765 0.770

31 32 33Ballast Efficacy Factor (BEF)



### Nominal Lamp Wattage (W) CSL1

F32T8 PS Baseline



### Figure 5.6.2 Candidate Standard Levels for the PS Representative Product Class

Table 5.6.7 and Table 5.6 .6 provide detailed information on the 4- foot MBP ballast designs used in the engineering analysi s and subsequent analyses. In general, for the IS and RS5- 26 

### representative product class, ballasts at higher efficiencies can operate at multiple voltages and have a similar BF and PF as the baseline ballast designs. For the PS representative product class,

t he ballast characteristics are also very similar.

Table 5.6.5 Ballast Designs for the IS and RS Representative Product ClassCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast Efficiency

V W

Baseline 4 F32T8 Lamps Electronic IS 277 Single >0.98 <1 0% 0.84 111 .5 0.768 90.5%

CSL1 4 F32T8 Lamps Electronic IS 277 Universal >0.98 <1 0% 0.87 114 .4 0.781 92.0%



### Table 5.6.6 Ballast Designs for the PS Representative Product ClassCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast Efficiency

V W

Baseline 4 F32T8 Lamps Electronic PS 277 Single >0.99 <10% 0.87 120.3 0.708 83.9 %

CSL1 4 F32T8 Lamps Electronic PS 277 Universal >0.98 <10% 0.88 116.1 0.755 89.4 %



### 5.6.3 Lamp and B allast Prices

DOE analyzed each CSL for the IS and RS representative product class to develop appropriate MSPs . T he baseline MSP was calculated using the online price scaling technique

described in section 5.3.3 whereas the CSL 1 MSP was derived from a teardown. DOE found that the MSP increased with increased efficiency for this product class as depicted in Table 5.6.7

.

Table 5.6.7 Summary of the Manufacturing Selling Price for the IS and RS Representative

Product Class

Candidate Standard Level Lamp Type Starting Method MSP

Baseline F32T8 IS $ 10.50

CSL1 F32T8 IS $11. 885- 27 

### DOE analyzed each CSL for the PS representative product class to develop appropriate

MSPs . T he baseline MSP was derived from a teardown whereas the CSL1 MSP was estimated using the online price scaling technique . DOE found that the MSP increased with increased efficiency for this product class as depicted in Table 5.6.8

.

Table 5.6.8 Summary of the Manufacturing Selling Price for the PS Representative

Product Class

Candidate Standard Level Lamp Type Starting Method MSP

Baseline F32T8 PS $10. 72

CSL1 F32T8 PS $ 14.20



### The following table depicts the appropriate lamp prices for the baseline lamps as used in the 2009 Lamps Rule (see section 5.5.3 ).

Table 5.6.9 Retail Prices for Four

- Foot Medium Bipin Fluorescent Lamps

Lamp Type Retail Price (2007$)

F32T8 $2.82



### 5.6.4 Results

Table 5.6.10 presents the engineering characteristics of the ballast replacement option for the baseline F32T8 system in the IS and RS representative p roduct class. Because the BF of the

standards -case system is slightly higher than the baseline system, the normalized input power is lower than the measured input power. If a direct substitution is made, mean lumen output does not change by more than 4 per cent relative to the mean lumen output of the baseline system.5- 28 

### Table 5.6.10 Four

- Lamp Four

- Foot MBP RS and IS Product Class with F32T8 BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 4 F32T8 Lamps Electronic IS 277 Single 0.98 <10% 0.84 111.5 0.7 68 90.5% 10,048 9,545 N/A 10.50 11.29 111.5

CSL1 4 F32T8 Lamps Electronic IS 277 Universal 0.98 <10% 0.87 114.4 0.7 81 92.0% 10 ,394 9,874 3.4% 11.88 11.29 110.6



### Table 5.6.11 presents the engineering characteristics of the ballast replacement option for the baseline F32T8 system in the PS representative product class. If a direct substitution is made, mean lumen output does not change by more than 2 percent relative to the mean lumen output of the baseline system.

Table 5.6.11 Four

- Lamp Four

- Foot MBP PS Product Class with F32T8 BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 4 F32T8 Lamps Electronic PS 277 Single 0.99 <10% 0.87 120.3 0.7 08 83.9% 10,382 9,863 N/A 10.72 11.29 120.3

CSL1 4 F32T8 Lamps Electronic PS 277 Uni versal 0.98 <10% 0.88 116.1 0.75 5 89.4% 10,555 10,028 1.7% 14.20 11.29 114.25- 29 

### 5.7 BALLASTS THAT OPERATE TWO EIGHT

- FOOT SP SLIMLINE LAM PS

In this section, DOE analyzes the representative product class designated by number 50

in the table below. All BEF and BE values presented in this section were calculated according to the active mode test procedure unless otherwise specified.

Table 5.7.1 Representative Product Classes for Ballasts that Operate Two Eight -Foot SP

Slimline Lamps

Ballast and Lamp Type Starting

Method Ballast

Factor Number of Lamps

One Two Three Four Five Six

Eight

- Foot SP Slimline All High 47 48 N/A N/A N/A N/A

Normal 49 50 N/A N/A N/A N/A

Low 51 52 N/A N/A N/A N/A

Shading indicates a representative product class.



### 5.7.1 Baseline Models

For the 2- lamp 8 -foot SP slimline normal BF product class (designated by product class

50 in Table 5.7.1 ; hereafter referred to as the 8

- foot SP slimline representative product cla ss)

, DOE chose to analyze two baseline ballasts. Census data indicates that 2001 shipments of 8 -foot SP slimline T12 ballasts represented approximately 50 percent of all shipments while 8

- foot SP slimline T8 ballasts represented the remaining approximately 50 percent. 8



### 5.5.1 Therefore, DOE analyzed both a T12 and T8 ballast as baseline ballasts. Because the 2009 Lamps Rule eliminated all currently commercially available T12 lamps by 2012, DOE created an F96T12/ES lamp that complied with the 2009 Lamps Rule to pai r with T12 ballasts (see section ). Because only the most efficient T12 lamps will be available when this ballast rulemaking takes effect, DOE chose to analyze only those T12 ballasts that operate F96T12/ES lamps for this rulemaking. For the T8 baseline, DOE chose to analyze only those ballasts that operate the F96T8 lamp because this lamp is the most common 8- foot SP slimline T8 lamp.

The Federal minimum energy conservation standards for ballasts that operate two F96T12/ES lamps became effective for ballasts manufactured on or after July 1, 2009. (10 CFR Part 430.32 (m)(5)). This energy conservation standard effectively allowed only electronic F96T12/ES ballasts. Therefore, DOE chose an electronic ballast as the F96T12/ES b aseline ballast. To determine the BEF of the baseline ballast, DOE tested multiple ballasts operating a reference F96T12/ES lamp. The BEF, BF and input power of the most common T12 ballast that just meets the minimum energy conservation standard of 0.77 is shown in Table 5.7.2 below. All T12 electronic ballasts in product catalogs are IS, single voltage, and have a high PF. The ballast that just meets the energy conservation standard also exhibits these characteristics. DOE also

8 More recent census data for ballasts is available. However, shipments of T12 ballasts have not been publicly released after 2001. T12 ballast shipments also include data for the 6

- foot SP slimline ballast which DOE estimates is negligible when compared to the 8

- foot shipments.5- 30 

### ch ose a ballast that has an input voltage of 277V because the majority of ballasts operate in commercial buildings at 277V. There are multiple THD values for electronic F96T12/ES. These range from <20 percent to <14 percent and <10 percent. DOE chose a ballast with a THD of <10 percent because it represented the least efficient T12 ballast.

Currently there is no federal minimum energy conservation standard for ballasts that operate F96T8 lamps. Therefore, in choosing the baseline ballast for this lamp type, D OE chose the most common, least efficient ballast on the market. DOE tested a range of F96T8 ballasts from multiple ballast manufacturers and found that the least efficient but most common ballast

exhibited the characteristics shown in the table below. The vast majority of F96T8 ballasts are IS, electronic, and have a high PF (>0.98). Furthermore, the majority of the least efficient T8 ballasts are universal voltage and have a THD <10 percent. Finally, like the F96T12/ES baseline ballast, DOE chose a ballas t that has an input voltage of 277V as the majority of ballasts operate in commercial buildings at 277V.

Table 5.7.2 Baseline Ballasts for the Eight

- Foot SP Slimline Representative Product Class

For Operation of Starting Method, Input Voltage, Ballast Type, PF, THD BF Input

Power

(W) Ballast Efficiency BEF Federal Energy

Conservation

Standard

2, F96T12/ES Lamps IS, 277V, Electronic, Single Voltage, ≥0.97,
PF, <10% THD 0.88 111.1 90.7%* 0.797 0.77

2, F96T8

Lamps IS, 277V, Electronic, Universal Voltage, >0.98
PF, <10% THD 0.87 109.7 90.0% 0.7 90 N/A

* DOE was unable to test the efficiency of this particular ballas t. DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the 8

- foot SP slimline representative product class, the BEF of a ballast is related to ballast efficiency in the following manner: BEF= 0.878 *BE

.



### DOE paired 8

- foot SP slimline ballasts with an appropriate F96T12/ES or F96T8 lamp.

DOE chose 8 -foot SP slimline lamps that just meet the ECS issued in the 2009 Lamps Rule which becomes effective in 2012 as these will be the most common lamps available after the ballast rule takes effect. The characteristics of these lamps are listed in the table below.

Table 5.7.3 Lamps for Use with F96T8 and F96T12/ES Ballasts

Lamp Type CCT Rated Effi cacy* Initial Light Output Mean Light Output Life CRI

K lm/W lm lm hr

F96T12/ES 4,100 98.2 5,939 5,516 15,000 N/A

F96T8 4,100 98.2 5,900 5,428 15,000 82

* Rated efficacy is based on the rated wattage of the lamps, which for the F96T12/ES lamp is

60. 5W and for the F96T8 lamp is 60.1W.



### This combination of lamp and ballast represents the most common configuration for these ballasts in existing and new installations. Together, this lamp -and- ballast combination creates a system lumen package of approximately 9,760 mean lumens (and 10,508 initial lumens) for the5- 31 

### baseline F96T12/ES ballast, approximately 9,396 mean lumens (and 10,213 initial lumens) for

the baseline F96T8 IS ballast.

5.7.2 Candidate Standard Levels

The following discussion identifies the steps and technologies associated with each CSL

DOE considered for the 8- foot SP slimline representative product class. As discussed in the screening analysis (preliminary TSD chapter 4), DOE used design options that achieve a higher BEF than the baseline ballast. Because the baseline ballasts are electronic ballasts, improvements required the use of the following design options: improved components and improved circuit design. For the 8- foot SP slimline representative product class, DOE identified only one CSL. This CSL represents the maximum technologically feasible level.

CSL1 . BEF: 0.807; Efficiency: 92.0 percent

This level represents a modest improvement over both the baseline T12 and T8 efficiency. Ballasts at this level use slightly better components and ci rcuit designs than those T12 and T8 ballasts that meet the baseline level. This level also represents the maximum technologically feasible level. DOE notes that unlike some CSLs in other product classes, both T12 and T8

ballasts can meet the maximum techno logically feasible level. DOE also notes that although T12 systems are typically less efficacious than T8 systems for other product classes. The T12 systems for this product class have equivalent or higher system efficacies than the T8 systems.

Figure 5.7.1 illustrates the baselines and CSL on a plot of fluorescent lamp ballasts DOE is selecting to analyze. The square box and label identifies the baseline ballasts. The plot also shows the replacement ballasts DOE is considering at CSL1.5- 32 0.765 0.770 0.775 0.780 0.785 0.790 0.795 0.800 0.805 0.810 0.815

58 59 60 61Ballast Efficacy Factor (BEF)



### Nominal Lamp Wattage (W) CSL1

EPCA F96T12/ES F96T8

F96T8 Baseline F96T12/ES Baseline



### Figure 5.7.1 Candidate Standard Levels for the Eight

- Foot SP Slimline Representative

Product Class

Table 5.7.4 provides detailed information on the 8

- foot SP slimline balla st designs used in the engineering analysis and subsequent analyses. For the F96T8 ballasts, the ballast characteristics remain the same as the baseline system. However, for the F96T12/ES ballasts, the THD and PF are slightly lower than the baseline ballas t.

Table 5.7.4 Ballast Designs for the Eight

- Foot SP Slimline Representative Product ClassCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast Efficiency

V W

Baseline 2 F96T12ES Lamps Electronic IS 277 Single ≥0.97 <10% 0.88 111.1 0.797 90.7% *

CSL1 2 F96T12ES Lamps Electronic IS 277 Single >0.95 <20% 0.88 109.5 0.807 92.0% *

Baseline 2 F96T8 Electronic IS 277 Universal >0.98 <10% 0.87 109.7 0.7 90 90.0%5- 33 Lamps

CSL1 2 F96T8 Lamps Electronic IS 277 Universal >0.9 8 <10% 0.87 108.0 0.8 09 92.2%

* DOE was unable to test the efficiency of these particular ballast s . DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the 8

- foot SP slimline repr esentative product class, t he BEF of a ballast is related to ballast efficiency in the following manner: BEF= 0.878 *BE

.



### 5.7.3 Lamp and Ballast Prices

DOE analyzed each CSL for the 8- foot SP slimline representative product class to develop appropriate MSPs. Bot h the baseline and CSL1 MSPs for ballasts that operate F96T12/ES lamps were estimated using the online price scaling technique described in section

5.3.3 . DOE based the MSP for the baseline ballast that operates F96T8 lamps on the online price scaling technique, whereas the CSL1 MSP was derived from a teardown . DOE found that the MSP increased with increased efficiency for both the F96T12/ES ballasts as depicted in the table below. For ballasts that operate F96T8 lamps, DOE foun d the baseline ballast to be more expensive than that at CSL1. Because of energy conservation standards effecting ballasts manufactured after July 1, 2009, DOE believes this market is currently in flux.

Table 5.7.5 Manufacturing Selling Prices for the Eight -Foot SP Slimline Representative

Product Class

Candidate Standard Level Lamp Type MSP $

Baseline F96T12/ES 1 9

. 34

CSL1 F96T12/ES 26.27

Baseline F96T8 15.55

CSL1 F96T8 9.27



### The following table depicts th e appropriate lamp prices for the baseline lamps as used in the 2009 Lamps Rule (see section 5.5.3 ).

Table 5.7.6 Retail Prices for Eight

- Foot SP Slimline Fluorescent Lamps

Lamp Ty pe Retail Price (2007$)

F96T12/ES $7.00

F96T8 $5.92



### 5.7.4 Results

Table 5.7.7 presents the engineering characteristics of the ballast replacement options for the baseline F96T12/ES system in the 8- foot SP slimline representative pr oduct class. Because

the BF of the standards- case system is almost exactly the same as the baseline system, the normalized input power is very close to the measured input power. If a direct substitution is5- 34 

### made, mean lumen output does not change by more than 0.1 percent relative to the mean lumen output of the baseline system.5- 35 

### Table 5.7.7 Eight

- Foot SP Slimline Representative Product Class with F96T12/ES BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 2 F96T12ES Lamps Electronic IS 277 Single ≥0.97 <10% 0.88 111.1 0.797 90.7%* 10,508 9,760 N/A 19.34 14.00 111.1

CSL1 2 F96T12ES Lamps Electronic IS 277 Single >0.95 <20% 0.88 109.5 0.807 92.0%* 10,499 9,751

- 0.1% 26.27 14.00 109.6

* DOE was unable to test the efficiency of these particular ballas t s . DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the 8

- foot SP slimline representative product class, the BEF of a ballast is related to ballast efficiency in the following manner:
BEF= 0.878 *BE

.



### Table 5.7.8 presents the engineering characteristics of the ballast replacement options for the baseline F96T8 system in the 8

- foot SP slimline representative product class. Because the BF of the standards

- case system is almost the same as the baseline system, the normalized input power is close to the measured input power. If a direct substitution is made, mean lumen output does not change by more than 1 percent relative to the mean lumen output of the bas eline system.

Table 5.7.8 Eight

- Foot SP Slimline Representative Product Class with F96T8 BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 2 F96T8 Lamps Electronic IS 277 Universal >0.98 <10% 0.87 109.7 0.7 90 90.0% 10,213 9,396 N/A 15.55 11.84 109.7

CSL1 2 F96T8 Lamps Electronic IS 277 Universal >0.98 <10% 0.87 108.0 0.8 09 92.2% 10,317 9,491 1.0% 9.27 11.84 106.95- 365- 37 

### 5.8 BALLASTS THAT OPERATE TWO EIGHT

- FOOT RDC HO LAMPS

In this section, DOE analyzes the representative product class designated by number 54 in the table below. All BEF and BE values presented in this section were calculated according to the active mode test proced ure unless otherwise specified.

Table 5.8.1 Representative Product Classes for Ballasts that Operate Two Eight -Foot RDC

HO Lamps

Ballast and Lamp Type Starting

Method Ballast

Factor Number of Lamps

One Tw o Three Four Five Six

Eight

- Foot RDC HO IS and RS All 53 54 N/A N/A N/A N/A

PS All 55 56 N/A N/A N/A N/A

Shading indicates a representative product class.



### 5.8.1 Baseline Models

For the 2- lamp 8

- foot RDC HO IS and RS product class (designated by product cl ass 54

in Table 5.8.1 ; hereafter referred to as the 8

- foot RDC HO representative product class) , DOE chose to analyze two baseline ballasts. DOE found the market share of 8-foot HO (T8 and T12) standard application ballasts (exclu ding cold temperature sign ballasts) to be about 0.5 percent.

DOE believes most of the 8 -foot HO ballasts currently shipped are T12. However, the 2009 Lamps Rule will reduce the number of T12 RDC HO lamps and increase the number of T8 RDC HO lamps shipped by promulgating more stringent lamp standards. Therefore, DOE analyzed

both T12 and T8 ballasts as baseline ballasts. Because the 2009 Lamps Rule eliminated all currently commercially available T12 lamps by 2012, DOE created an F96T12HO/ES lamp that complied with the 2009 Lamps Rule to pair with T12 ballasts (see section 5.5.1 ). Because only the most efficient T12 lamps will be available when this ballast rulemaking takes effect, DOE chose to analyze only those T12 ballasts that operate F96T12HO/ES lamps for this rulemaking. For the T8 baseline, DOE chose to analyze only those ballasts that operate the F96T8HO lamp because this lamp is the most common 8

- foot RDC HO T8 lamp.

The Federal minimum energy conservation standards for ba llasts that operate two F96T12HO/ES lamps became effective for ballasts manufactured on or after July 1, 2009. (10 CFR Part 430.32 (m)(5)). This energy conservation standard did not eliminate magnetic ballasts from the market. Therefore, DOE chose a magnet ic ballast as the F96T12HO/ES baseline ballast. To determine the BEF of the baseline ballast, DOE tested multiple ballasts operating a reference F96T12HO/ES lamp. The BEF, BF and input power of the most common T12 ballast that just meets the minimum energy conservation standard of 0.42 is shown in Table 5.8.2 below. All T12 magnetic ballasts in product catalogs are RS, single voltage, and have a high PF (>0.90). The ballast that just meets the energy conservation standard also exhibits these characteristics. DOE also chose a ballast that has an input voltage of 277V because the majority of ballasts operate in commercial buildings at 277V. THD values range from <25 percent to <18 percent. DOE chose a ballast with a THD of <18 percent because it represented the least efficient T12 ballast.5- 38 

### Currently there is no federal minimum energy conservation standard for ballasts that operate F96T8HO lamps. Therefore, in choosing the baseline ballast for this lamp type, DOE chose the most common, least efficient ballast on the market. DOE tested a range of F96T8HO ballasts from multiple ballast manufacturers and found that the least efficient but most common ballast exhibited the characteristics shown in the table below. The vast majority of F96T8H O ballasts are electronic and have a high PF (>0.95). Furthermore, the majority of the least efficient T8 ballasts have a THD <20 percent. Finally, like the F96T12HO/ES baseline ballast, DOE chose a ballast that has an input voltage of 277V as the majority of ballasts operate in commercial buildings at 277V.

Table 5.8.2 Baseline Ballasts for the Eight

- Foot RDC HO Representative Product Class

For Operation

of Starting Method, Input Voltage, Ballast Type, PF, TH D BF Input

Power

(W) Ballast Efficiency BEF Federal Energy

Conservation

Standard

2, F96T12HO/ES Lamps RS, 277V, Magnetic, Single Voltage, ≥0.90,
PF, <18% THD 0.92 208.4 71.6%* 0. 440 0.42

2, F96T8HO Lamps RS, 277V, Electronic, Single Voltage, >0.98
PF, < 20% THD 0.88 160.0 89.6%* 0.550 N/A

* DOE was unable to test the efficiency of these particular ballast s . DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the 8

- foot RDC HO rep resentative product class, t he BEF of a ballast is related to ballast efficiency in the following manner: BEF= 0.614 *BE

.



### DOE paired 8 -foot RDC HO ballasts with an appropriate F96T12HO/ES and F96T8HO lamp. DOE chose 8-foot RDC HO lamps that just meet the ECS issued in the 2009 Lamps Rule which becomes effective in 2012 as these will be the most common lamps available after the ballast rule takes effect. The characteristics of these lamps are listed in the table below.

Table 5.8.3 Lamps for Use with F96T8HO and F96T12HO/ES Ballasts

Lamp Type CCT Rated Efficacy* Initial Light Output Mean Light Output Life CRI

K lm/W lm lm hr

F96T12HO/ES 4,100 91.9 8,910 8,019 12,000 N/A

F96T8HO 4,100 91.9 7,900 7,100 24,00 0 78

* Rated efficacy is based on the rated wattage of the lamps, which for the F96T12HO/ES lamp is 97W and for the F96T8HO lamp is 86W.



### This combination of lamp and ballast represents the most common configuration for these ballasts in existing and new installations. Together, this lamp -and- ballast combination creates a system lumen package of approximately 14,705 mean lumens (and 16,3 39 initial lumens) for the baseline F96T12HO/ES ballast, approximately 12,496 mean lumens (and 13,904 initial lumens)

fo r the baseline F96T8HO ballast.5- 39 

### 5.8.2 Candidate Standard Levels

The following discussion identifies the steps and technologies associated with each CSL

DOE considered for the 8- foot RDC HO representative product class. As discussed in the screening analysis (pr eliminary TSD chapter 4), DOE used design options that achieve d a higher BEF than the baseline ballast. Because the baseline ballast is a magnetic ballast, improvements required the use of the following design options: electronic ballasts, improved components, and improved circuit design. For the 8- foot RDC HO representative product class, DOE identified two CSLs. CSL2 represents the maximum technologically feasible level.

CSL1 . BEF: 0.500; Efficiency: 81.4 percent

This level only affects the T12 baseline and represents a modest improvement over the baseline T12 efficiency. Ballasts at this level are electronic instead of magnetic. Both T12 and T8 ballasts

can meet this level.

CSL2 . BEF: 0.549 ; Efficiency: 89.4 percent

This level represents the maximum tech nologically feasible level. This level affects both T12 and T8 baselines. Only T8 ballasts can meet this level. Ballasts at this level use slightly better components and circuit designs than those T8 ballasts that meet CSL1.

Figure 5.8.1 illustrates the baselines and two CSLs on a plot of fluorescent lamp ballasts DOE is selecting to analyze. The square box and label identifies the baseline ballasts. The plot also shows the replacement ballasts DOE is considering at each CSL.5- 40 0.40 0.42 0.44 0.46 0.48 0.50 0.52 0.54 0.56 0.58 0.60

84 86 88 90 92 94 96Ballast Efficacy Factor (BEF)



### Nominal Lamp Wattage (W) CSL2

CSL1 F96T12HO/ES F96T8HO

F96T8HO Baseline

F96T12HO/ES Baseline



### Fi gure 5.8.1 Candidate Standard Levels for the Eight

- Foot RDC HO Representative

Product Class

Table 5.8.4 provides detailed information on the 8 -foot RDC HO ballast designs used in

th e engineering analysis and subsequent analyses. For the more efficient F96T12HO/ES and F96T8HO ballasts, the ballast factor is lower than that of the baseline ballast.

Table 5.8.4 Ballast Designs for the Eigh t- Foot RDC HO Representative Product ClassCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast Efficiency

V W

Baseline 2 F96T12 HO/ES Lamps Magnetic RS 277 Single ≥0.90 <18% 0.92 20 8. 4 0.4 40 71.6%*

CSL1 2 F96T12HO/ES Lamps Electronic RS 277 Single >0.98 <20% 0.85 170.0 0.500 81.4%*

Baseline

/CSL1 2 F96T8HO Lamps Electronic RS 277 Single >0.98 <20% 0.88 160.0 0.550 89.6%*5- 41 CSL2 2 F96T8HO Lamps Electronic IS 277 Single >0.98 <10% 0.68 14 2.8 0.5 49 89.4%

* DOE was unable to test the efficiency of these particular ballast s . DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the 8

- foot RDC HO re presentative product class, t he BEF of a ballast is related to ballast efficiency in the following manner: BEF= 0.614 *BE

.



### 5.8.3 Lamp and Ballast Prices

DOE analyzed each CSL for the 8- foot RDC HO representative product class to develop appropriate MSPs . The base line, CSL1, baseline/CSL1 and CSL2 were each estimated using the online price scaling technique described in section 5.3.3 . DOE found that the MSP increased for each CSL relative to its respective baseline as depicted in the ta ble below.

Table 5.8.5 Manufacturing Selling Prices for the Eight -Foot RDC HO Representative

Product Class

Candidate Standard Level Lamp Type MSP $

Baseline F96T12HO/ES 22.80

CSL1 F96T12HO/ES 23.14

Baselin e/CSL1 F96T8HO 18.45

CSL2 F96T8HO 24.38



### The following table depicts the appropriate lamp prices for the baseline lamps as used in the 2009 Lamps Rule (see section 5.5.3 ).

Table 5.8.6 Retail Prices for Eight

- Foot RDC HO Fluorescent Lamps

Lamp Type Retail Price (2007$)

F96T12HO/ES $12.35

F96T8HO $6.57



### 5.8.4 Results

Table 5.8.7 presents the engineering characteristics of the ballast replacement options for the baseline F96T12HO/ES system in the 8- foot RDC HO representative product class. Because

the BF of the standards- case system decreases at higher CSLs, the normalized input power is higher than the measured input power. If a direct substitution is made, mean lumen output decreases relative to the baseline system.5- 42 

### Table 5.8.7 Eight

- Foot RDC HO Representative Product Class with F96T12HO/ES BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 2 F96T12HO/ES Lamps Magnetic RS 277 Single 0.90 <18% 0.92 20 8. 4 0.4 40 71.6%* 16,339 14,7 05 N/A 22.80 24.70 20 8. 4

CSL1 2 F96T12HO/ES Lamps Electronic RS 277 Single 0.98 <20% 0.85 170.0 0.500 81.4%* 15,147 13,632

- 7. 3% 23.14 24.70 18 3.4

Baseline

/CSL1 2 F96T8HO Lamps Electronic RS 277 Single 0.98 <20% 0.88 160.0 0.550 89.6%* 13,904 12,496

- 15. 0% 18.45 13.13 188. 3

CSL2 2 F96T8HO Lamps Electronic IS 277 Single 0.98 <10% 0.68 14 2.8 0.5 49 89.4% 1 0,682 9,600

- 34 .7% 24.38 13.13 218.8

* DOE was unable to test the efficiency of these particular ballast s . DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the 8

- foot RDC HO re presentative product class, t he BEF of a ballast is related to ballast efficiency in the following manner: BEF= 0.614 *BE

.



### Table 5.8.8 presents the engineering characteristics of the ballast replacement options for the baseline F9 6T8HO system in the

8- foot RDC HO representative product class. Because the BF of the standards

- case system is lower than the baseline system, the normalized input power is higher than the measured input power. If a direct substitution is made, mean lumen output decreases relative to the baseline system.5- 43 

### Table 5.8.8 Eight

- Foot RDC HO Representative Product Class with F96T8HO BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInputVoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalizedInputPower

V W lm lm % $ $ W

Baseline/

CSL1 2 F96T8HO Lamps Electronic RS 277 Single 0.98 <20% 0.88 160.0 0.550 89.6%* 13,904 12,496 N/A 18.45 13.1 3 160.

0

CSL2 2 F96T8HO Lamps Electronic IS 277 Single 0.98 <10% 0.68 14 2.8 0. 549 89.4% 10,682 9 ,600

- 23.2 % 24.38 13.1 3 185.

9

* DOE was unable to test the efficiency of this particular ballast. DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the 8

- foot RDC HO representat ive product class, t he BEF of a ballast is related to ballast efficiency in the following manner: BEF= 0.614 *BE

.5- 44 

### 5.9 BALLASTS THAT OPERATE TWO FOUR

- FOOT MINIBP T5 SO LA MPS

In this section, DOE analyzes the representative product class designated by numbers 40 in the table below. All BEF and BE values presented in this section were calculated according to the active mode test procedure unless otherwise specified.

Table 5.9.1 Representative Product Classes for Ballasts that Operate Two Four-Foot

MiniBP T5 SO Lamps

Ballast and Lamp Type Starting

Method Ballast

Factor Number of Lamps

One Two Three Four Five Six

Four

- Foot T5 MiniBP SO All High 37 38 N/A N/A N/A N/A

Normal 39 40 N/A N/A N/A N/A

Low 41 42 N/A N/A N/A N/A

Shading indicates a representative product class.



### 5.9.1 Baseline Models

For the 2- lamp 4 -foot MiniBP T5 SO normal BF product class (designated by product

class 40 in Table 5.9.1 ; hereafter referred to as the 4 -foot T5 MiniBP SO representative product class), DOE chose to analyze one baseline ballast. DOE believes that F28T5 lamps encompass the vast majority of 4 -foot MiniBP T5 SO lamp sales. 9



### Curre ntly there is no federal minimum energy conservation standard for ballasts that operate F28T5 lamps. In addition, only electronic 4-foot T5 MiniBP SO ballasts are sold on the U.S. market. DOE recognizes, however, that magnetic 4- foot T5 MiniBP SO ballasts may be introduced to the U.S. market and purchased widely by consumers if a BEF standard for 4-foot

T5 MiniBP SO ballasts is not established. Because 4 -foot T5 MiniBP SO magnetic ballasts do not exist currently, DOE developed a baseline model 4-foot T5 Min iBP SO magnetic ballast by determining the difference in BEF between magnetic and electronic ballasts. More information on how DOE developed this baseline model is outlined in appendix 5B. The baseline 4 -foot T5

MiniBP SO ballast has the characteristics sh own in the table below. Although this ballast is not commercially available today, it is the lowest efficiency ballast that may be commercially

available when standards take effect. Therefore, DOE has chosen to only analyze the F28T5 baseline ballast.

Table 5.9.2 Baseline Ballas t for Four -Foot T5 MiniBP SO Representative Product Class

For Operation

of BF Ballast Type Input

Power

(W) Ballast Efficiency BEF Federal Energy

Conservation

Standard

F28T5 1.02 Magnetic 77.8 7 9.1 % * 1.309 N/A

* DOE was unable to test the efficiency of thi s particular ballast. DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the 4

- foot T5 MiniBP SO representative product class, the BEF of a ballast is related to

9 Currently only one manufacturer sells a 4

- foot MiniBP T5 lamp that is not a F28T5. This lamp is a reduced wattage (F26T5).5- 45 ballast efficien cy in the following manner: BEF= 1.655 *BE

.



### DOE paired the 2- lamp 4 -foot MiniBP SO ballast with an appropriate F28T5 lamp. DOE

chose a 4

- foot MiniBP SO lamp that just meets the ECS issued in the 2009 Lamps Rule which

becomes effective in 2012 as this will be the most common lamp available after the ballast rule takes effect. The characteristics of this lamp are listed in the table below.

Table 5.9.3 Lamps for Use with F28T5 Ballasts

Lamp Type CCT Rated Effica cy* Initial Light Output Mean Light Output Life CRI

K lm/W lm lm hr

F28T5 4,100 104.3 2,900 2,660 20,000 85

* Rated efficacy is based on the rated wattage of the lamps, which for the F28T5 lamp is 27.8W.



### This combination of lamp and ballast represents the most common configuration for these ballasts in existing and new installations. Together, this lamp -and- ballast combination creates a system lumen package of approximately 5,419 mean lumens (and 5,908 initial lumens).

5.9.2 Candidate Standard Levels

The following discussion identifies the steps and technologies associated with each CSL

DOE considered for the 4-foot T5 MiniBP SO representative product class. As discussed in the screening analysis (preliminary TSD chapter 4), DOE used design options that achieve a higher BEF than the baseline ballast. Because the baseline ballast is a magnetic ballast, improvements required the use of the following design options: electronic ballast, improved components and improved circuit design. For the 4- foot T5 MiniBP SO representative product class, DOE identified two CSLs. The highest CSL represents the maximum technologically feasible level.

CSL1 . BEF: 1. 441; Efficiency: 87.1%

This level represents a large improvement over the baseline T5 efficiency. This level is characterized by the least efficient electronic ballasts on the market today. Magnetic ballasts

cannot meet this level

CSL2 . BEF: 1. 482; Efficiency: 89.6%

Ballasts at this level use slightly better components and circuit designs than those ballasts that

meet CSL1. This level also represents the maximum technologically feasible level.

Figure 5.9.1 illustrates the baselines and CSL on a plot of fluorescent lamp ballasts DOE is selecting to analyze. The square box and label identifies the baseline ballast. The plot also shows the replacement ballasts DOE is considering at CSL1 and CSL2.5- 46 1.250 1.300 1.350 1.400 1.450 1.500 1.550 1.600 1.650 1.700

27 28 29Ballast Efficacy Factor (BEF)



### Nominal Lamp Wattage (W) CSL1

F28T5 B aseline CSL2



### Figure 5.9.1 Candidate Standard Levels for the Four

- Foot T5 MiniBP SO Representative

Product Class

Table 5.9.4 provides detailed information on the 4 -foot MiniBP SO ballast designs used in the engineering analysis and subsequent analyses. For the F28T5 ballasts, the ballast characteristics either improve or remain the same as the magnetic baseline system.

Table 5.9.4 Ballast Designs for the Four

- Foot T5 MiniBP SO Representative Product ClassCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast Efficiency

V W

Baseline 2 F28T5 Lamps Magnetic PS 277 Single N/A N/A 1.02 77.8 1.309 79.1%*

CSL1 2 F28T5 Lamps Electronic PS 277 Universal >0.99 <10% 1.02 64.9 1. 441 87.1%

CSL2 2 F28T5 Lamps Electronic PS 277 Universal >0.98 <10% 1.06 65.4 1. 482 89.6%5- 47 * DOE was unable to test the efficiency of this particular ballast. DOE estimates are based on the relationship between BEF and ballast efficiency determined by the acti ve mode test procedure

. For the 4

- foot T5 MiniBP SO representative product class, t he BEF of a ballast is related to ballast efficiency in the following manner: BEF= 1.655 *BE

.



### 5.9.3 Lamp and Ballast Prices

DOE analyzed each CSL for the 4-foot T5 MiniBP SO repre sentative product class to develop appropriate MSPs. Both the CSL1 and CSL2 MSPs were estimated using the online price scaling technique described in section 5.3.3 . To determine a price for the baseline magnetic T5 ballast, DOE assumed that the ratio of the baseline magnetic 2 -lamp, 8- foot T12 RDC HO

ballast to the electronic 2 -lamp, 8- foot T12 RDC HO ballast would be the same as the magnetic

to electronic 4 -foot T5 MiniBP SO ballasts. Using this ratio, DOE calculated the price for the magnetic T5 MiniBP SO baseline ballast using the price for the 4-foot T5 MiniBP SO ballast at
CSL1

. DOE found that the MSP increased with increased efficiency as depicted in the table

below.

Table 5.9.5 Manufacturing Selling Prices for the Four -Foot T5 MiniBP SO Representative

Product Class

Candidate Standard Level Lamp Type MSP $

Baseline F28T5 16.19

CSL1 F28T5 16.43

CSL2 F28T5 16.56



### The following table depicts the appropriate lamp prices for the baseline lamps as used in the 2009 Lamps Rule.

Table 5.9.6 Retail Prices for Four

- Foot MiniBP SO Fluorescent Lamps

Lamp Type Retail Price (2007$)

F28T5 $3.20



### 5.9.4 Results

Table 5.9.7 presents the engineering characteristics of the ballast replacement options for the baseline F28T5 system in the 4-foot T5 MiniBP SO representative product class. Because the

BF of the standards- case system at CSL2 is slightly higher than the baseline system, the normalized input power is slightly lower than the measured input power. If a direct substitution is made, mean lumen output does not change by more than 4 .2 percent relative to the mean lumen output of the baseline system.5- 48 

### Table 5.9.7 Four -Foot T5 MiniBP SO Representative Product Class with F28T5 BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 2 F28T5 Lamps Magn etic PS 277 Single N/A N/A 1.02 77.8 1.309 79.1 %* 5,908 5,419 N/A 16.19 6.40 77.8

CSL1 2 F28T5 Lamps Electronic PS 277 Universal >0.99 <10% 1.02 64.9 1. 441 87.1% 5,908 5,419 0.0% 16.43 6.40 64.9

CSL2 2 F28T5 Lamps Electronic PS 277 Universal >0.98 <10% 1 .06 65.4 1. 482 89.6% 6,155 5,646 4.2% 16.56 6.40 62.7

* DOE was unable to test the efficiency of this particular ballast. DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the 4

- foot T5 MiniBP SO representative product class, t he BEF of a ballast is related to ballast efficiency in the following manner:

BEF= 1.655 *BE

.5- 49 

### 5.10 BALLASTS THAT OPERATE TWO FOUR

- FOOT MINIBP T5 HO LA MPS

In this section, DOE analyzes th e representative produ ct class designated by number 44 in the table below. All BEF and BE values presented in this section were calculated according to the active mode test procedure unless otherwise specified.

Table 5.10.1 Representative Product Classes for Ballasts that O perate Two Four -Foot

MiniBP T5 H O Lamps

Ballast and Lamp Type Starting

Method Ballast

Factor Number of Lamps

One Two Three Four Five Six

Four

- Foot T5 MiniBP HO All All 43 44 45 46 N/A N/A

Shading indicates a representative product class.



### 5.10.1 Baseline Models

For the 2- lamp 4 -foot MiniBP T5 HO normal BF product class (designated by product

class 44 in Table 5.10.1 ; hereafter referred to as the 4 -foot T5 MiniBP HO representative produc t class), DOE chose to analyze one baseline ballast. DOE believes that F54T5HO lamps encompass the vast majority of 4

- foot MiniBP T5 HO lamps sales. 10



### Currently there is no federal min imum energy conservation standard for ballasts that operate F54T5HO lamps. In addition, only 4-foot T5 MiniBP HO electronic ballasts are sold on the U.S. market. Like the 4-foot T5 MiniBP SO product class, DOE recognizes that 4-foot T5 MiniBP HO magnetic b allasts may be introduced to the U.S. market and purchased widely by

consumers if a BEF standard for 4

- foot T5 MiniBP HO ballasts is not established. Because 4

- foot T5 MiniBP HO magnetic ballasts do not exist currently, DOE developed a baseline model 4-

foo t T5 MiniBP HO magnetic ballast by determining the difference in BEF between magnetic and electronic ballasts. More information on how DOE developed this baseline model is outlined in appendix 5B and section Therefore, DOE has chosen to only analyze the F54T5HO baseline ballast.

5.9.1

. The baseline 4-foot T5 MiniBP HO ballast has the characteristics shown in the table below. Although this ballast is not commercially available today, it is the lowest efficiency ballast that may be commercially available when standards take

effect.

Table 5.10.2 Baseline Ballast for the Four -Foot T5 MiniBP HO Representative Product

Class

For Operation

of BF Ballast Type Input

Power

(W) Ballast Efficiency BEF Federal Energy

Conservation

Standard

F54T5HO 0.99 Magnetic 143.5 7 4 .2% * 0.688 N/A

* DOE was unable to test the efficiency of this particular ballast. DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test

10 Currently only two manufacturers sell a 4

- foot MiniBP T5 HO lamp t hat is not a F54T5HO. One manufacturer sells a reduced wattage (F51T5HO). Another manufacturer sells a F49T5HO.5- 50 procedure

. For the 4

- foot T5 MiniBP HO representative pro duct class, t he BEF of a ballast is related to ballast efficiency in the following manner: BEF= 0.927 *BE

.



### DOE paired the 2- lamp 4 -foot MiniBP HO ballast with an appropriate F54T5HO lamp.

DOE chose a 4

- foot MiniBP HO lamp that just meets the ECS issued in the 2009 Lamps Rule which becomes effective in 2012 as this will be the most common lamp available after the ballast rule takes effect. The characteristics of this lamp are listed in the table below.

Table 5.10.3 Lamps for Use with F 54 T5 HO Ballasts

Lamp Type CCT Rated Efficacy* Initial Light Output Mean Light Output Life CRI

K lm/W lm lm hr

F54T5HO 4,100 92.9 5,000 4,600 20,000 85

* Rated efficacy is based on the rated wattage of the lamps, which for th e F54T5HO lamp is

53.8W.



### This combination of lamp and ballast represents the most common configuration for these ballasts in existing and new installations. Together, this lamp -and- ballast combination creates a system lumen package of approximately 9,087 mean lumens (and 9,877 initial lumens).

5.10.2 Candidate Standard Levels

The following discussion identifies the steps and technologies associated with each CSL

DOE considered for the 4-foot T5 MiniBP HO representative product class. As discussed in the

screen ing analysis (preliminary TSD chapter 4), DOE used design options that achieve a higher BEF than the baseline ballast. Because the baseline ballast is a magnetic ballast, improvements required the use of the following design options: electronic ballast, improved components and improved circuit design. For the 4- foot T5 MiniBP HO representative product class, DOE identified two CSLs. The highest CSL represents the maximum technologically feasible level.

CSL1 . BEF: 0.791; Efficiency: 85. 4 percent

This level r epresents a large improvement over the baseline T5 efficiency. This level is characterized by the least efficient electronic ballasts on the market today. Magnetic ballasts

cannot meet this level

CSL2 . BEF: 0.837; Efficiency: 90.3 percent

Ballasts at this level use slightly better components and circuit designs than those ballasts that meet CSL1. This level also represents the maximum technologically feasible level.

Figure 5.10.1 illustrates the baseline and CSLs on a plot of fluor escent lamp ballasts DOE is selecting to analyze. The square box and label identifies the baseline ballast. The plot also shows the replacement ballasts DOE is considering at CSL1 and CSL2.5- 51 0.650 0.700 0.750 0.800 0.850 0.900

53 54 55Ballast Efficacy Factor (BEF)



### Nominal Lamp Wattage (W) CSL1

F54T5HO B aseline CSL2



### Figure 5.10.1 C andidate Standard Levels for the Four

- Foot T5 MiniBP HO Representative

Product Class

Table 5.10.4 provides detailed information on the 4- foot MiniBP HO ballast designs used in the engineering analysis and subsequent analyses. For the F54T5HO ballasts, the ballast characteristics either improve or remain the same as the magnetic baseline system.

Table 5.10.4 Ballast Designs for the Four

- Foot T5 MiniBP HO Representative Product

ClassCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast Efficiency

V W

Baseline 2 F54T5HO Lamps Magnetic PS 277 Single N/A N/A 0.99 143.5 0.688 74 .2% *

CSL1 2 F54T5HO Lamps Electronic PS 277 Universal ≥0.98 ≤10% 0.99 124.8 0.791 85.4%*

CSL2 2 F54T5HO Electronic PS 277 Universal >0.98 <10% 1.02 122.4 0.8 37 90.3%5- 52 Lamps



### 5.10.3 Lamp and Ballast Prices

DOE analyzed each CSL for the 4-foot T5 MiniBP HO representative product class to develop appropriate MSPs. Both the CSL1 and CSL2 MSPs were estimated using the online price scaling technique described in section 5.3.3 . DOE used the same technique described for establishing the magnetic T5 SO ballast MSP to establish an MSP for the magn etic T5 HO baseline. DOE assumed that the ratio of the baseline magnetic 2 -lamp, 8- foot T12 RDC HO

ballast to the electronic 2 -lamp, 8- foot T12 RDC HO ballast would be the same as the ratio between the magnetic to electronic 4 -foot T5 MiniBP HO ballasts. U sing this 8 -foot HO ratio, DOE adjusted the price assigned to CSL1 to calculate the price for the model magnetic T5 H O baseline. DOE found that the MSP increased with increased efficiency as depicted in the table

below.

Table 5.10.5 Manufacturing Selling Prices for the Four -Foot T5 MiniBP HO Representative Product Class

Candidate Standard Level Lamp Type MSP $

Baseline F54T5HO 15.09

CSL1 F54T5HO 15.32

CSL2 F54T5HO 18. 27



### The following table depicts the app ropriate lamp prices for the baseline lamps as used in the 2009 Lamps Rule.

Table 5.10.6 Retail Prices for Four

- Foot MiniBP HO Fluorescent Lamps

Lamp Type Retail Price (2007$)

F54T5HO $4.28



### 5.10.4 Results

Table 5.10.7 presents the engineering characteristics of the ballast replacement options

for the baseline F54 T5 HO system in the 4 -foot T5 MiniBP HO representative product class.

Because the BF of the standards

- case system is slightly higher than the baseline system at CSL2, the normalized input power is slightly lower than the measured input power. If a direct substitution is made, mean lumen output does not change by more than 3 percent relative to the mean lumen output of the baseline system.5- 53 

### Table 5.10.7 Four -Foot T5 MiniBP H O Representative Product Class with F 54 T5 HO BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 2 F54T5HO Lamps Magnetic PS 277 Single N/A N/A 0.99 143.5 0.688 74 .2% * 9,877 9,087 N/A 15.09 8.56 143.5

CSL1 2 F54T5HO Lamps Electronic PS 277 Universal ≥0.98 ≤10% 0.99 124.8 0.791 85.4%* 9,877 9,087 0.0% 15.32 8.56 124.8

CSL2 2 F54T5HO Lamps Electronic PS 277 Universal >0.98 <10% 1.02 122.4 0.8 37 90.3% 10,152 9,340 2.8% 18.27 8.56 119.15- 54 

### 5.11 BALLASTS THAT OPERATE TWO FOUR

- FOOT MBP AND TWO

- FOOT U

SHAPED LAM PS IN THE RESIDENTIAL SECTOR

In this section, DOE analyzes the representative product class designated by number 58 in the table below. All BEF and BE values presented in this section were calculated according to the active mode test procedure unless othe rwise specified.

Table 5.11.1 Representative Product Classes for Ballasts that Operate Two Four

- Foot MBP

and Two -Foot U- Shaped Lamps in the Residential Sector

Ballast and Lamp Type Starting

Method Ballast

Fac tor Number of Lamps

One Two Three Four Five Six

Residential Ballast, Four

- Foot

MBP and Two

- Foot U

- Shaped IS and RS All 57 58 59 60 N/A N/A

PS All 61 62 63 64 N/A N/A

Shading indicates a representative product class.



### 5.11.1 Baseline Models

For the Resid ential 2

- lamp 4 -foot MBP and 2- foot U -Shaped IS and RS product class (designated by product class 58 in Table 5.11.1 ; hereafter referred to as the residential representative product class) , DOE chose to analyze two baseline ballasts. Census data indicates that the market share of low power factor magnetic ballasts was about 7 percent during the years from 1995 to 2002, and then decreased to about 1.5 percent in 2005. 11



### 5.5.1 However, DOE believes

that the Census data does not accurately reflect the residential ballast market. First, electronic ballasts are a common option for residential fluorescent lighting fixtures, but they are not reported in the Census data. Second, many residential ballasts are manufactured overseas b y foreign companies which do not share shipment data with the U.S. Census. Through manufacturer interviews, DOE learned that both T12 and T8 ballasts are popular in the residential market. Therefore, DOE analyzed both a T12 and T8 ballast as a baseline bal last.

Because the 2009 Lamps Rule eliminated all currently commercially available T12 lamps by 2012, DOE created an F34T12 lamp that complied with the 2009 Lamps Rule to pair with T12 ballasts (see section ). Because only the most efficient T12 lamps will be available when this ballast rulemaking takes effect, DOE chose to analyze only those T12 ballasts that operate F34T12 lamps for this rulemaking. For the T8 baseline, DOE paired its T8 baseline ballast with an F32T8 lamp because DOE believed that that was the most common wattage lamp at that

diameter.

Currently there is no federal minimum energy conservation standard for ballasts that operate lamps in the residential sector. Therefore, in choosing the baseline ballast for this market sector, DOE chose the most common and least efficient ballast on the market. DOE research discovered that most ballasts sold in the residential market are sold as part of a fixture. Therefore, DOE researched the most common fixtures sold in th e residential market. DOE then

11 Low power factor ballasts are ballasts with a power factor less than 0.9 and are typically used in residential applications.5- 55 

### obtained the fixtures, removed the ballast, and tested the ballast to determine the least efficient and most common option. The majority of ballasts in the residential market operate two lamps, have an input voltage of 120V, have a low power factor (0.5<PF<0.9), and are sold in striplights (also known as shoplights). The baseline T12 ballast exhibits these characteristics. The BEF, BF, and input power of this ballast are shown in Table 5.11.2

.

For the T8 baseline, DOE also chose the most common, least efficient ballast on the market. DOE tested a range of F32T8 ballasts from multiple ballast manufacturers and in multiple fixtures. DOE found that the least efficient but most common ballast exhibited the characteristics shown in the table below. The majority of F32T8 ballasts in the residential sector operate two lamps, are electronic, are IS, and operate at a single voltage of 120V. The

characteristics of the T8 baseline ballast are summarized in Table 5.11.2

.

Table 5.11.2 Baseline Ballasts for the Residential Representative Product Class

For Operation

of Starting Method, Input Voltage, Ballast Type, PF BF Input

Power

(W) Ballast

Eff iciency BEF Federal Energy

Conservation

Standard

2, F34T12

Lamps RS, 120V, Electronic, Single Voltage, >0.50

PF 0.59 45.9 75.7%* 1.277 N/A

2, F32T8

Lamps IS, 120V, Electronic, Single Voltage, >0.50

PF 0.78 53.1 86.4% 1.4 57 N/A

* DOE was unable to test the efficiency of this particular ballast. DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the residential representative product class, t he BEF of a ballast is related to bal last efficiency in the following manner:

BEF= 1.686 *BE

.



### DOE paired 4 -foot MBP ballasts with an appropriate F34T12 or F32T8 lamp. DOE chose

4- foot MBP lamps that just meet the ECS adopted in the 2009 Lamps Rule which becomes effective in 2012 as these will be the most common lamps available after the ballast rule takes effect. The characteristics of these lamps are listed in the table below.

Table 5.11.3 Lamps for Use with F32T8 and F34T12 Ballasts

Lamp Type CCT Rated Efficacy* Initial Light Output Mean Light Output Life CRI

K lm/W lm lm hr

F34T12 4,100 92.3 3,138 2,825 24,000 N/A

F32T8 4,100 92.3 3,000 2,850 24,000 85

* Rated efficacy is based on the rated wattage of the lamps, which for the F34T12 lam p is 34W and for the F32T8 lamp is 32.5W.



### This combination of lamp and ballast represents the most common configuration for these ballasts in existing and new installations. Together, these lamp-and- ballast combinations create a system lumen package of a pproximately 3,310 mean lumens (and 3,676 initial lumens) for the5- 56 

### baseline F34T12 ballast, and approximately 4,447 mean lumens (and 4,682 initial lumens) for

the baseline F32T8 ballast.

5.11.2 Candidate Standard Levels

The following discussion identifies the ste ps and technologies associated with each CSL

DOE considered for the r esidential representative product class. As discussed in the screening analysis (preliminary TSD chapter 4), DOE used design options that achieve a higher BEF than the baseline ballast. Because the baseline ballasts are electronic ballasts, improvements required the use of the improved components and improved circuit design. For the r esidential representative product class, DOE identified two CSLs. CSL2 represents the maximum technological ly feasible level.

CSL1 . BEF: 1.457; Efficiency: 86.4%

This level affects the F34T12 baseline ballast but not the F32T8 baseline ballast. It requires the use of improved lamp diameters (T8 instead of T12). Therefore, no T12 ballasts meet this level.

CSL2

. BEF: 1. 492; Efficiency: 88.5%

This level affects both baseline ballasts and represents the maximum technologically feasible level. This level represents a modest improvement in efficiency over CSL1. Ballasts at this level use slightly better components and circuit designs than those T8 ballasts that meet CSL1.

Figure 5.11.1 illustrates the baselines and CSLs on a plot of fluorescent lamp ballasts DOE is selecting to analyze. The square box and label identifies the baseline ballas ts. The plot also shows the replacement ballasts DOE is considering at CSL1 and CSL2.5- 57 1.25 1.30 1.35 1.40 1.45 1.50 1.55

31 32 33 34 35Ballast Efficacy Factor (BEF)



### Nominal Lamp Wattage (W) CSL2

CSL1 F34T12 F32T8

F32T8 Baseline

F34T12 Baseline



### Figure 5.11.1 Candidate Standard Levels for the Residential Representative Product Class

Tabl e 5.11.4 provides detailed information on the 4-foot MBP ballast designs used in the engineering analysis and subsequent analyses.

Table 5.11.4 Ballast Designs for the Residential Representative Product Clas sCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast Efficiency

V W

Baseline 2 F34T12 Lamps Electronic IS 120 Single >0.50 <10 0.59 45.9 1.277 75.7%*

Baseline

/CSL1 2 F32T8 Lamps Electronic IS 120 Single >0.50 <20 0.78 53.1 1.4 57 86.4%

CSL2 2 F32T8 Lamps Electronic IS 120 Single >0.50 <10 0.83 55.3 1. 492 88.5%

* DOE was unable to test the efficiency of this particular ballast. D OE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the residential representative5- 58 product class, t he BEF of a ballast is related to ballast efficiency in the following manner: BEF = 1.686 *BE

.



### 5.11.3 Lamp and Ballast Prices

DOE analyzed each CSL for the residential representative product class to develop appropriate MSPs

. Because ballasts in the residential sector are typically sold in fixtures, DOE discovered that the most common ballasts could not be obtained individually. Rather, these ballasts could only be purchased as part of a fixture. Therefore, DOE revised its pricing methodology for this product class. For the striplight fixtures analyzed, DOE assumed that the

MSP of the resident ial ballast represented a fixed percentage of the retail price of the fixture. To determine this, DOE compared the MSP of a commercial ballast that closely resembled the characteristics of its residential counterpart to the total retail price of the fixtur e. DOE then applied this percentage to the retail price of the fixtures to calculate the MSP for the residential

ballast. DOE found that the MSP increased with increased efficiency as depicted in Table 5.11.5

.

Table 5.11.5 Manufacturing Selling Prices for the Residential Representative Product

Class

Candidate Standard Level Lamp Type MSP $

Baseline F34T12 3.68

CSL1 F32T8 7.07

CSL2 F32T8 10.13



### The following table depicts the appr opriate lamp prices for the baseline lamps as used in the 2009 Lamps Rule.

Table 5.11.6 Retail Prices for Four

- Foot MBP Fluorescent Lamps

Lamp Type Retail Price (2007$)

F34T12 $5.83

F32T8 $2.82



### 5.11.4 Results

Table 5.11.7 presents the engineering characteristics of the ballast replacement options for the baseline F34T12 system in the r esidential representative product class. Because the BF of

the standards

- case system is higher than th e baseline system, the normalized input power is lower than the measured input power. If a direct substitution is made, mean lumen output can increase by as much as 43 percent over the mean lumen output of the baseline system because of

the difference in b allast factor. Additionally, as seen in the table below, input power increases at each CSL relative to the baseline. For the residential sector, DOE believes that consumers will5- 59 

### not purchase direct ballast replacements, but rather replacement fixtures. The refore, the normalized input power is the most relevant scenario because fixture spacing can be easily adjusted when a new fixture is installed.5- 60 

### Table 5.11.7 Residential Representative Product Class with F34 T12 BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 2 F34T12 Lamps Electronic IS 120 Single N/A N/A 0.59 45.9 1.277 75.7%* 3,676 3,310 N/A 3.68 11.65 45.9

CSL1 2 F32T 8 Lamps Electronic IS 120 Single N/A N/A 0.78 53.1 1. 457 86.4% 4,682 4,447 34.4% 7.07 5.65 39.5

CSL2 2 F32T8 Lamps Electronic IS 120 Single N/A N/A 0.83 55.3 1. 492 88.5% 4,989 4,740 43.2% 10.13 5.65 38.6



### Table 5.11.8 presents t he engineering characteristics of the ballast replacement options for the baseline F32T8 system in the

r esidential representative product class. Because the BF of the standards

- case system is slightly higher than the baseline system, the normalized input power is slightly lower than the measured input power. If a direct substitution is made, mean lumen output does not change by more than 7 percent relative to the mean lumen output of the baseline system.

Table 5.11.8 Residential Representative Product Class with F32T8 BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystemInitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline/CSL1 2 F32T8 Lamps Electronic IS 120 Single N/A N/A 0.78 53 .1 1.4 57 86.4% 4,682 4,447 N/A 7.07 5.65 53.1

CSL2 2 F32T8 Lamps Electronic IS 120 Single N/A N/A 0.83 55.3 1. 492 88.5% 4,989 4,740 6.6% 10.13 5.65 51.85- 61 

### 5.12 BALLASTS THAT OPERATE FOUR EIGHT

- FOOT HO LAMPS IN COLD

TEMPERATURE APPLICAT IONS OR OUTDOOR SIGN S

I n this section, DOE analyzes the representative product class designated by number 68 in the table below. All BEF and BE values presented in this section were calculated according to the active mode test procedure unless otherwise specified.

Table 5.12.1 Representative Product Classes for Ballasts that Operate Four Eight -Foot HO Lamps in Cold Temperature Applications or Outdoor Signs

Ballast and Lamp Type Starting

Method Ballast

Factor Number of Lamps

One Two Three Four Five Six

Sign Ballast, All Lamp Types All All 65 66 67 68 69 70

Shading indicates a representative product class.



### 5.12.1 Baseline Models

For the 4- lamp 8 -foot HO product class for cold temperature or sign ballasts (designated by product class 68 in Table 5.12.1 ; hereafter referred to as the sign ballast representative product class), DOE chose to analyze one baseline ballast. DOE evaluated the cold temperature ballast market and found the market share to be relatively small – about 1 percent in 2005. However, despite their small market share, high output ballasts designed for cold- temperature outdoor signage have large potential energy savings per ballast. Moving from a magnetic to an electronic sign ballast can reduce energy consumption by as much as 25 to 35 percent. DOE research indicated that ballasts that operate in outdoor signs or in other cold temperature applications are designed for use with T12 lamps. Therefore, DOE chose a T12 ballast as a

baseline for this product class. DOE paired the ballast with an F96T12HO lamp that represented the most common cold temperature lamp available in the market today.

Current ballast standards exclude ballasts designed to operate at ambient temperatures of −20 °F or less and designed for use in an outdoor sign. (10 CFR 430.32(m)) Therefore, in choosing the baseline ballast for this market sector, DOE chose the most comm on and least efficient ballast on the market. DOE tested a range of cold temperature ballasts and sign ballasts from multiple ballast manufacturers and found that the least efficient but most common ballast exhibited the characteristics shown in the table below. The vast majority of sign ballasts are magnetic, RS, and operate at a low BF. Furthermore, the majority of the least efficient sign ballasts are single voltage and operate four 8-foot HO lamps. Finally, DOE chose a ballast that has an input voltage of 120V as the majority of ballasts operate in outdoor signs at 120V. The BEF, BF, and input power of this ballast are shown in Table 5.12.2

.

Table 5.12.2 Baseline Ballasts for the Si gn Ballast Representative Product Class

For Operation of Starting Method, Input Voltage, Ballast Type BF Input

Power

(W) Ballast Efficiency BEF Federal Minimum Energy

Conservation

Standard
4, F96T12HO RS, 120V, Magnetic, 0.7 7 393.6 74 .4%* 0. 196 N/A5- 62 Lamps Single Voltage

* DOE was unable to test the efficiency of this particular ballast. DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the sign ballast representative product clas s, t he BEF of a ballast is related to ballast efficiency in the following

manner: BEF= 0.263 *BE

.



### DOE paired 8 -foot HO ballasts with an appropriate F96T12HO lamp. Because lamps used in cold temperature applications were not covered by the 2009 Lamps Rule, DOE chose an 8-foot HO lamp that represents the most common lamp available in the market today. The characteristics of this lamp are listed in the table below.

Table 5.12.3 Lamps for Use with Cold Temperatur e F96T12HO Ballasts

Lamp Type CCT Rated Efficacy* Initial Light Output Mean Light Output Life CRI

K lm/W lm lm hr

F96T12HO 4200 63.3 8,600 6,966 12,000 60



### This combination of lamp and ballast represents the most common configuration for these ballasts in existing and new installations. Together, this lamp -and- ballast combination creates a system lumen package of approximately 21,472 mean lumens (and 26,509 initial lumens) for the

baseline F96T12HO ballast.

5.12.2 Candidate Standard Levels

The following disc ussion identifies the steps and technologies associated with each CSL

DOE considered for the sign ballast representative product class. As discussed in the screening analysis (preliminary TSD chapter 4), DOE used design options that achieve a higher BEF than the baseline ballast. Because the baseline ballast is a magnetic ballast, improvements required the use of an electronic ballast. For the sign ballast representative product class, DOE identified one CSL. CSL1 represents the maximum technologically feasible level.

CSL1 . BEF: 0.238 ; Efficiency: 90.4 percent

This level represents a modest improvement in efficiency over the baseline ballast. Ballasts at this level are electronic rather than the magnetic ballasts that meet the baseline level.

Figure 5.12.1 illustrates the baselines and CSLs on a plot of fluorescent lamp ballasts DOE is selecting to analyze. The square box and label identifies the baseline ballasts. The plot also shows the replacement ballasts DOE is considering at C SL1.5- 63 0.00 0.04 0.08 0.12 0.16 0.20 0.24 0.28

109 110 111Ballast Efficacy Factor (BEF)



### Nominal Lamp Wattage (W) CSL1

F96T12HO Sign BallastBaseline



### Figure 5.12.1 Candidate Standard Levels for the Sign Ballast Representative Product Class

Table 5.12.4 provides detailed information on the 8-foot HO ballast designs used in the engineering analysis and subsequent analyses.

Table 5.12.4 Ballast Designs for the Sign Ballast Representative Product ClassCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast Efficiency

V W

Baseline 2 F96T12HO Lamps Magnetic RS 120 Single N/A N/A 0.7 7 393.6 0.1 96 74.4%*

CSL1 2 F96T12HO Lamps Electronic IS 120 Universal N/A N/ A 0.63 264.0 0.2 38 90.4%*

* DOE was unable to test the efficiency of these particular ballast s . DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the sign ballast representative product class, t he BEF of a ballast is related to ballast efficiency in the following manner: BEF= 0.263 *BE

.5- 64 

### 5.12.3 Lamp and Ballast Prices

DOE analyzed each CSL for the sign ballast representative product class to develop appropriate MSPs . Both the baseline an d CSL1 MSPs were estimated using the online price scaling technique described in section 5.3.3 . As depicted in the table below, DOE found the CSL1 MSP to be greater than the baseline. The CSL1 ballast is an electronic ballast t hat operates a wide variety of design constraints, whereas the baseline ballast is a magnetic ballast with a typical set of specifications. The simplification and reduction of inventory may rationalize this finding of lower cost with higher efficiency. In addition, manufacturers indicated the magnetic ballast (baseline) would be sold at a higher price than the more efficient electronic ballast (CSL1).

Table 5.12.5 Manufacturing Selling Prices for the Sign Ball ast Representative Product

Class

Candidate Standard Level Lamp Type MSP $

Baseline F96T12HO 40.23

CSL1 F96T12HO 35.58



### Because DOE did not analyze 8 -foot HO cold temperature fluorescent lamps in the 2009 Lamps Rule, DOE developed the price for that lamp using the same methodology employed in the 2009 Lamps Rule. The resultant price is shown in the table below.

Table 5.12.6 Retail Prices for Eight

- Foot HO Cold Temperature Fluorescent Lamps

Lamp Type Retail P rice (2007$)

F96T12HO $4.84



### 5.12.4 Results

Table 5.12.7 presents the engineering characteristics of the ballast replacement options for the baseline F96T12HO system in the sign ballast representative product class. Because the

BF of the standards- case system is lower than the baseline system, the normalized input power is higher than the measured input power. If a direct substitution is made, mean lumen output would decrease by 19 percent because of the lower ballast factor.5- 65 

### Table 5.12.7 Sign Ballast Representative Product Class with F96T12HO BaselineCandidate StandardLevelFor Operation OfBallast TypeStarting MethodInput VoltageUniversal or SingleVoltagePower FactorTHDBallast FactorInput PowerBEFBallast EfficiencySystem InitialLight OutputSystem MeanLight OutputPercentageChange MeanLumen OutputBallastManufacturerSelling PriceLamp Retail PriceNormalized InputPower

V W lm lm % $ $ W

Baseline 4 F96T12HO Lamps Magnetic RS 120 Single N/A N/A 0.7 7 393.6 0.1 96 74.4%* 26,509 21,472 N/A 40.23 19.34 393.6

CSL1 4 F96T12HO Lamps Electronic IS 120 Universal N/A N/A 0.63 2 64 .0 0.2 38 90.4%* 21,599 17,495

- 18.5 % 35.58 19.34 324.1

* DOE was unable to test the efficien cy of these particular ballast s . DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode test procedure

. For the sign ballast representative product class, the BEF of a ballast is related to ballast efficiency in the following manner: BEF= 0.263 *BE

.5- 66 

### 5.13 SCALING TO PRODUCT CLASSES NOT ANALYZED

DOE identified and selected certain product classes as “representative” product classes on which to concentrate its analytical effort. DOE chose these representative product classes primarily due to their high market volumes. DOE focused its analytical efforts on extensive test

data obtained for ballasts that operate 4

- foot MBP lamps. DOE analyzed ballasts of this type to observe relationships between ballasts that op erate different numbers of lamps , have different ballast factors, orhave different starting methods. The following sections discuss how DOE identified these relationships and then applied scaling factors to determine CSLs for those product classes that it did not analyze.

5.13.1 Number of Lamps

The more lamps a ballast operates, the lower the ballast’s BEF. This is because as the number of lamps increases, the total ballast input power increases, which appears in the denominator of the equation to calculate BEF. Thus, ballasts that operate two or four lamps have lower BEFs than ballasts that operate one or three lamps, respectively. To determine how to scale CSLs to account for the number of lamps a ballast operates, DOE focused its analytical

effort on ballasts that operate 4

- foot MBP lamps. Within this category there are four representative product classes , shown in the table below. DOE obtained test data for these representative product classes and then strategically ch ose additional classes to aid its scaling

effort. The following table indicates the 4 -foot MBP product classes for which DOE obtained

test data.

Table 5.13.1 Test Data Obtained for Ballasts that Operate Four

- Foot Medium Bipin Lamps

Ballast and Lamp T ype Starting

Method Ballast

Factor Number of Lamps

One Two Three Four Five Six

Four

- Foot MBP and Two

- Foot

U- Shaped IS and RS High 1 2 3 4 5 6

Normal 7 8 9 10 11 12

Low 13 14 15 16 17 18

PS High 19 20 21 22 23 24

Normal 25 26 27 28 29 30

Low 31 32 33 34 35 36

Shading indicates a representative product class . Diagonal lines represent product classes for which DOE obtained test

data.



### To determine how to scale between ballasts that operate different numbers of lamps,

DOE examined the ava ilable test data. The test data showed a strong correlation between the ballast efficacy factor and total rated lamp power operated by a ballast. The total rated lamp power is equal to the rated lamp power multiplied by the number of lamps. DOE found that this relationship existed even after considering differences between ballast manufacturers and standard versus high efficiency ballasts. Given the available test data, DOE also examined this relationship among ballasts that operate 4 -foot T5 MiniBP HO lamp s and cold temperature5- 67 

### lamps. This data verified DOE’s assumption that the relationship between BEF and total rated lamp power present among ballasts that operate 4

- foot MBP lamps is also present for ballasts that opera te other lamp types. Equation 5.13-1 shows the equation DOE used to scale CSLs in representative product classes to those that were not directly analyzed based on the number of lamps operated by a ballast

.

Equation 5.13-1

Power Lamp Rated Total -0.942 t Coefficien Factor Efficacy Ballast **∗ =** 

To determine the appropriate coefficient in the equation above, DOE relied on the analysis performed for each r epresentative product class. For each CSL in each representative product class, DOE calculated the coefficient in Equation 5.13-1 such that the relationship would hold true for each representative ballast. For example, for product class 8, DOE determined a different coefficient for CSLs 1 through 3 such that the BEF in Table 5.5.12 was equal to the coefficient times the total rated lamp power (65W for two 4

- foot MBP T8 lamps) raised to the

- 0.942 power. As higher CSLs represent more efficient ballasts, and therefore have higher BEFs, the scaling coefficient was large r for higher CSLs.

5.13.2 Starting Method

As discussed in preliminary TSD chapter 3 , the starting method of a ba llast affects its efficiency. Rapid start and programmed start ballasts are inherently less efficient than instant

start ballasts

, as these ballasts u se extra power to provide filament heat to the lamp to increase

the lamp ’s lifetime. Although these ballasts can cut out the filament power during lamp operation, the extra circuit to remove this power uses some amount of power. As explained in preliminary TSD chapter 3, DOE is establishing a separate product class for programmed start ballasts due to their primary use with occupancy sensors and limited use as a substitute for either instant start or rapid start ballasts.

To determine how to scale to ball asts that operate programmed start ballasts, DOE examined pairs of ballasts for which the only difference between the two was the starting method. For example, DOE identified a single ballast in product class 8, and identified its pair in product class 26. These ballasts had the same manufacturer and ballast factor and operated the same number and type of lamps. Upon identifying these ballast pairs, DOE calculated the average reduction in BEF associated with programmed start ballasts. DOE found this average reduction to be 2.2% and therefore applied this scaling factor when scaling to product classes with programmed start ballasts.

5.13.3 Ballast Factor

DOE’s analysis found that ballasts with a high or low ballast factor had a lower BE F than

ballasts with a normal ballast factor

. 12

12 In general, bal lasts designed with a ballast factor of around 0.88 are deemed normal ballast factor. Low ballast factor ballasts have a ballast factor of 0.78 or less; high ballast factor ballasts typically have a ballast factor of 1.10 or higher. 

### To determine how to scale to product classes containing5- 68 

### ballasts with either high or low ballast factor, DOE followed a similar methodology described

above in section 5.13.2 . DOE identified pairs of ballasts for which the only difference was ballast factor. For example, DOE identified a ballast in product class 8 and then identified the ballast with the same manufacturer, starting method, and number of lamps but either a high or low ballast factor in product class 2 or 14 respectively. DOE located similar pairs of ballasts between product classes 4 and 10 and 10 and 16. DOE calculated the average reduction associated with high or low ballast factor. DOE found this average reduction to be 3.4% for high ballast factor and 1.0% for low ballast factor and therefore applied these scaling factors as needed.

5.13.4 Scaling

As indicated by Table 5.13.2 , some product classes (such as product class 1) require more than one scaling factor to determine the appropriate CSLs. This section describes the order in which DOE applied the scaling factors described in the above sections.

When scaling to product classes not analyzed, DOE first scaled based on the number of lamps the ballast operates. For example , in Table 5.13.2

, DOE scaled from product classes 8 and 26 to product classes 7 and 25 respectively. For 4- lamp ballasts, DOE scaled from product class 10 to product classes 9, 11, and 12 and from product class 28 to product classes 27, 29, and 30. In the table below, the gray boxes designate representative product classes whereas the green

boxes designate product classes with CSLs that were calculate d using the number -of- lamps relationship.

Table 5.13.2 Example of Scaling Based on Number of Lamps

Ballast and Lamp Type Starting

Method Ballast

Factor Number of Lamps

One Two Three Four Five Six

Four

- Foot MBP and Two

- Foot

U- Shaped IS and RS High 1 2 3 4 5 6

Normal 7 8 9 10 11 12

Low 13 14 15 16 17 18

PS High 19 20 21 22 23 24

Normal 25 26 27 28 29 30

Low 31 32 33 34 35 36

Gray s hading indicates a representative product class

. G reen shading indicates a product class with CSLs scaled based

on t he number

- of

- lamps relatio nship

– with light green representing classes scaled from the 2

- lamp representative product class and dark green representing classes scaled from the 4

- lamp representative product class.



### When necessary, DOE then scaled based on starting method. For ball asts that operate 4

- foot MBP lamps, this scaling was not required because DOE selected representative product classes for programmed start ballasts. However, for both ballasts that operate 8- foot RDC HO lamps and ballasts that operate in the residential sector, it was necessary to scale based on starting method. In these cases, after adjusting CSLs based of number of lamps, DOE applied the programmed start scaling factor. An example for the residential representative product class is

shown below.5- 69 

### Table 5.13.3 Example of Scaling Based on Starting Method

Ballast and Lamp Type Starting

Method Ballast

Factor Number of Lamps

One Two Three Four Five Six

Residential Ballast, Four

- Foot

MBP and Two

- Foot U

- Shaped IS and RS All 57 58 59 60 N/A N/A

PS All 61 62 63 64 N/A N/A

Gray s hading indicates a representative product class. Green shading indicates a product class with CSLs scaled based

on the number

- of

- lamps relationship. Red shading indicates a product class w ith CSLs scaled based on the starting method relationship.



### Last, when required, DOE scaled based on ballast fa ctor. As discussed in section 5.13.3

, DOE developed scaling factors for both high and low BF ballasts. For ballast s that operate 4 -foot MBP lamps in the commercial sector, DOE applied those scaling factors after first adjusting for the number of lamps a ballast operates. In the table below, the blue shading denotes product classes for which DOE applied a scaling facto r for BF.

Table 5.13.4 Example of Scaling Based on Ballast Factor

Ballast and Lamp Type Starting

Method Ballast

Factor Number of Lamps

One Two Three Four Five Six

Four

- Foot MBP and Two

- Foot

U- Shaped IS and RS High 1 2 3 4 5 6

Normal 7 8 9 10 11 12

Low 13 14 15 16 17 18

PS High 19 20 21 22 23 24

Normal 25 26 27 28 29 30

Low 31 32 33 34 35 36

Gray s hading indicates a representative product class . Green shading indicates a product class with CSLs scaled based

on the number

- of

- lamps relationship

– with light green representing classes scaled from the 2

- lamp representative product class and dark green representing classes scaled from the 4

- lamp representative product class. Blue shading

indicate s a product class with CSLs scaled based on the ballast factor relationship

– with light blue representing classes scaled from the 2

- lamp representative product class and dark blue representing classes scaled from the 4

- lamp representative product class



### 5.13.5 All CSLs

The following tables show the values for each CSL in every product class.5- 70 

### Table 5.13.5 CSLs for All Ballasts That Operate Four

- Foot MBP and Two -Foot U- Shaped Lamps

Ballast and Lamp Type Starting

Me thod Ballast

Factor CSL Number of Lamps

One Two Three Four Five Six

4- Foot MBP,

and 2

- Foot U

Shaped IS and RS High 1 2.692 1.401 0.990 0.754 0.612 0.515

2 2.850 1.483

3 2.898 1.508

Normal 1 2.786 1.450 1.024 0.781 0.633 0.5 33

2 2.949 1.535

3 2.999 1.561

Low 1 2.758 1.435 1.014 0.773 0.627 0.528

2 2.919 1.519

3 2.969 1.545

PS High 1 2.816 1.466 0.957 0.729 0.591 0.498

Normal 1 2.914 1.517 0.990 0.755 0.612 0.515

Low 1 2.885 1.502 0.980 0.747 0.606 0.510

Gray shading indicates a representative product class.



### Table 5.13.6 CSLs for All Ballasts That Operate Eight

- Foot SP Slimline Lamps

Ballast and Lamp Type Starting

Method Ballast

Factor CSL Number of Lamps

One Two Three Four Five Six

8- Foot SP

Slimline All High 1 1.498 0.780

Normal 1 1.550 0.807

Low 1 1.535 0.799

Gray shading indicates a representative product class.



### Table 5.13.7 CSLs for All Ballasts That Operate Eight

- Foot RDC HO Lamps

Ballast and Lamp Type Starting

Method Ballast

Factor CSL Number of Lamps

One Two Three Four Five Six

8- Foot RDC

HO IS and RS All 1 0.961 0.500

2 1.055 0 .549

PS All 1 0.940 0.489

2 1.032 0.537

Gray shading indicates a representative product class.5- 71 

### Table 5.13.8 CSLs for All Ballasts That Operate Four

- Foot T5 MiniBP SO Lamps

Ballast and Lamp Type Starting

Method Ballast

Factor CSL Number of Lamps

One Two Three Four Five Six

4- foot T5

MiniBP SO All High 1 2.675 1.392

2 2.751 1.432

Normal 1 2.768 1.441

2 2.847 1.482

Low 1 2.741 1.426

2 2.819 1.467

Gray shading indicates a representative product class.



### Table 5.13.9 CSLs for All Ballasts That Operate Four

- Foot T5 MiniBP HO Lamps

Ballast and Lamp Type Starting

Method Ballast

Factor CSL Number of Lamps

One Two Three Four Five Six

4- foot T5

MiniBP HO All All 1 1.520 0.791 0.540 0.412

2 1.608 0.837 0.571 0.436

Gray shading indicates a representative product class.



### Table 5.13.10 CSLs for All Re sidential Ballasts That Operate Four

- Foot MBP and Two

Foot U- Shaped Ballasts

Ballast and Lamp Type Starting

Method Ballast

Factor CSL Number of Lamps

One Two Three Four Five Six

4- Foot MBP,

and 2

- Foot U

Shaped IS and RS All 1 2.801 1.458 0.995 0.759

2 2.866 1.492 1.018 0.777

PS All 1 2.740 1.426 0.974 0.742

2 2.804 1.460 0.996 0.760

Gray shading indicates a representative product class.



### Table 5.13.11 CSLs for All Cold Temperature or O utdoor Sign Ballasts

Ballast and Lamp Type Starting

Method Ballast

Factor CSL Number of Lamps

One Two Three Four Five Six

Sign Ballast All All 1 0.878 0.457 0.312 0.238 0.193 0.162

Gray shading indicates a representative product class.5- 72 

### REFERENCES

1 

### U.S. Department of Energy, Energy Efficiency and Renewable Energy Office of Building

Research and Standards. Energy Conservation Program for Consumer Products: Technical Support Document: Energy Efficiency Standards for Consumer Products: Fluorescent Lamp Ballast Proposed Rule . Chapter 3. Engineering Analysis. Section 3.7. January 2000. (Last accessed June 30, 2009).

< http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/chap3.pdf >

2 

### U.S. Census Bureau. Manufacturing, Mining, and Construction Statistics. Current Industrial Reports, Fluorescent Lamp Ballasts, MQ335C . (Last accessed June 30, 2009). <http://www.census.gov/mcd>

### CHAPTER 6. ENERGY USE CHARACTERIZATION

TABLE OF CONTENTS

6.1 PURPOSE OF THE DOCUMENT

.................................................................................... 6-1

6.2 LAMP AND BALLAST SYS TEM OPERATING HOURS

.............................................. 6-1

6.3 RESULTS OF THE ENERGY USE CHARACTERIZATION

......................................... 6-5

REFERENCES

..................................................................................................................... ....... 6-9

LIST OF TABLES

Table 6.2.1. Average Annual Lamp-and-Ballast System Operating Hours by Sector

................ 6-2 Table 6.2.2. Two- and Four-Lamp 4-Foot MB P PS Product Classes (F32T8 Baseline) – Adjusted Average Annual Operating Hours for Commercial Sector

.................. 6-4 Table 6.3.1. Two-Lamp RS and IS Ballasts Oper ating 4-Foot MBP and 2-Foot U-Shaped Lamps (F32T8 Baseline) – System Power Rating and Annual Energy Consumption, Commercial Sector

....................................................................... 6-5 Table 6.3.2. Two-Lamp PS Ballasts Operating 4- Foot MBP and 2-Foot U-Shaped Lamps – System Power Rating and Annual Energy Consumption, Commercial

Sector

................................................................................................................... 6-5 Table 6.3.3. Two-Lamp RS and IS Ballasts Oper ating 4-Foot MBP and 2-Foot U-Shaped Lamps (F34T12 Baseline) – System Power Rating and Annual Energy Consumption, Commercial Sector

....................................................................... 6-5 Table 6.3.4. Four-Lamp RS and IS Ballasts Oper ating 4-Foot MBP and 2-Foot U-Shaped Lamps – System Power Rating and Annual Energy Consumption,

Commercial Sector

............................................................................................... 6-6 Table 6.3.5. Four-Lamp PS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps – System Power Rating and Annual Energy Consumption, Commercial

Sector

................................................................................................................... 6-6 Table 6.3.6. Two-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps (F96T12HO/ES Baseline) – System Power Rating and Annual Energy Consumption, Industrial Sector

........................................................................... 6-6 Table 6.3.7. Two-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps (F96T8HO Baseline) – System Power Rating and Annual Energy Consumption, Industrial Sector

........................................................................... 6-6 Table 6.3.8. Two-Lamp IS Ballasts Operatin g 8-Foot Slimline Lamps (F96T12/ES Baseline) – System Power Rating and Annual Energy Consumption,

Commercial Sector

............................................................................................... 6-6 Table 6.3.9. Two-Lamp IS Ballasts Operating 8-Foot Slimline Lamps (F96T8 Baseline) – System Power Rating and Annual Energy Consumption, Commercial

Sector

................................................................................................................... 6-7 Table 6.3.10. Two-Lamp PS Ballasts Operating 4- Foot T5 MiniBP SO Lamps – System Power Rating and Annual Energy C onsumption, Commercial Sector

................ 6-7 Table 6.3.11. Two-Lamp PS Ballasts Operating 4-Foot T5 MiniBP HO Lamps – System Power Rating and Annual Energy C onsumption, Industrial Sector

.................... 6-7

6-i

### Table 6.3.12. Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot UShaped Lamps (Low Power Factor, F34T12 Baseline) – System Power Rating and Annual Energy Consum ption, Residential Sector

............................. 6-7 Table 6.3.13. Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot UShaped Lamps (Low Power Factor, F32T8 Baseline) – System Power Rating and Annual Energy Consum ption, Residential Sector

............................. 6-7 Table 6.3.14. Four-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps (Cold Temperature/Sign Ballasts) – System Power Rating and Annual Energy Consumption, Commercial Sector

....................................................................... 6-8 Table 6.3.15. Four-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps (Cold Temperature/Sign Ballasts) – System Power Rating and Annual Energy Consumption, Industrial Sector

........................................................................... 6-8

LIST OF FIGURES

Figure 6.2.1. Residential Sector Annual Operating Hour Distri bution by Building Type

.......... 6-3 Figure 6.2.2. Commercial Sector Annual Operating Hour Distribution by Building Type

........ 6-3 Figure 6.2.3. Industrial Sector Annual Operatin g Hour Distribution by Building Type

............. 6-4

6-ii

### CHAPTER 6. ENERGY USE CHARACTERIZATION

6.1 PURPOSE OF THE DOCUMENT

This chapter presents the methodology the U.S. Department of Energy (DOE) follows to estimate the annual energy consumption of the fl uorescent lamp-and-ballast system designs DOE considers in the ballast rulemaking analyses. Becau se fluorescent lamp ballasts are designed to operate fluorescent lamps, DOE chooses the most common fluorescent lamp used with each ballast to develop representative lamp-and-ballast systems. Fluorescent lamps will not be regulated under the proposed ba llast rulemaking; however, the input power of the complete lamp-and-ballast system is considered for the energy use analysis. The results of this analysis, which represent typical energy consumption in th e field, are critical inputs to the life-cycle cost (LCC) and payback period (PBP) analyses (preliminary technical support document [TSD] chapter 8) and the national impact analysis (NIA; preliminary TSD chapter 10). DOE requires information on annual energy consumption to dete rmine the potential energy and operating cost savings to consumers from the use of more efficient equipment.

DOE determines the annual energy consump tion of the lamp-and-ballast systems using information on their rated input power ( i.e. , the rate of energy they consume) and the way consumers use them ( i.e. , operating hours per year). The engineering analysis (chapter 5) discusses the power ratings of lamp-and-ballast systems. The following sections discuss the inputs and calculations DOE uses to devel op annual operating hours and annual energy consumption for the products considered in this analysis.

6.2 LAMP AND BALLAST SYSTEM OPERATING HOURS

To characterize the country’s average use of lamp-and-ballast systems for a typical year, DOE develops annual operating hours by sector. For the LCC, DOE accounts for variability in operating hours by developing a distribution of operating hours for the LCC spreadsheet. The operating hour distributions capture variation across nine census divisions (New England, Middle Atlantic, East North Central, West North Central, South Atlantic , East South Central, West South Central, Mountain, a nd Pacific) and large States (Ca lifornia, Florida, New York, and Texas), building types, and lamp-and-ballast systems for three sectors (residential, commercial, and industrial).

In conjunction with data from the U.S. Lighting Market Characterization (LMC) Volume 1, 1 

### DOE uses data from the Energy Information Administration’s (EIA) 2003 Commercial Building Energy Survey (CBECS), 2 

### 2005 Residential Energy Consumption Survey (RECS), 3 

### and 2002 Manufacturer Energy Consumption Survey (MECS). 4 

### These EIA studies provide information on the distribution of U.S. buildings by building type and census division. The LMC, which is based on thousands of buildin g audits and surveys, provides national-level data on annual operating hours by building type and lamp type for all sectors. These operating hours are divided by application (a ssembly, athletic, bathroom, boarding, class, dining, display, exit, exterior-architectural, exterior-parking , exit-sign, exterior, food preparation, hall, healthcare, office, ship/rec, shop, storage, ta sk, unknown, and utility) for the commercial and

6-1

### industrial sectors and room type (bathroom, be droom, closet, dining room, family room, garage, hall, kitchen, living room, office, outdoor, utility room, and other) for the residential sector.

DOE associates LMC operating hour data by building type with EIA data by building type and census division to derive annual oper ating hours by census division and large States. This allows DOE to correlate the electricity price distribution (chapt er 8), and sales tax distribution (chapter 7) with the operating hour dist ribution by census division and large States in the LCC spreadsheet. The following paragraphs describe data sources DOE uses to develop annual operating hours by sector.

For the residential sector, DOE uses RECS building data and LMC residential sector operating hour data to develop a distribution of annual operating hours fo r fluorescent lamp-and

ballast systems. The 2005 RECS data indicates the probability that a certain building type resides

within a census division. The LMC indicates the occu rrence of certain room types within a given building type and the operating hour characteristics in these rooms. DOE then uses aggregated data from the LMC to associate average annual operating hours per building type. DOE chose to aggregate operating hour data to the building rather than at the room le vel because DOE believes it more closely represents the impact on an individual consumer. However, DOE will use operating hour data at the room level to perform uncertainty results in the notice of proposed rulemaking (NOPR) stage of this analysis.

DOE uses a similar approach to develop a distribution of annual operating hours in the commercial sector. However, instead of room type, DOE aggregates LMC annual operating hour data by application to develop average a nnual operating hours by building type. The 2003 CBECS data indicates the probability a certain building type in a certain census division exists. Once the LCC model selects a building, DOE associates the aggregated LMC annual operating hour average with the building type selected. Like the residential sector, DOE chose to aggregate LMC operating hour data to the building level fo r the commercial and industrial sectors because it more closely represents the impact on consumers.

To develop a distribution of annual operating hours in the industrial sector, DOE uses an approach consistent with that used for the co mmercial sector. The 2002 MECS data indicates the probability a certain building type exists. DOE aggregates LMC annual operating hour data by industrial application to deve lop average annual operating hours by building type. Once the model selects a building, DOE associates the aggregated LMC operating hour average with the building type selected. Because MECS does not provide the location of industrial sector buildings, DOE uses 2008 U.S. Census Bureau population information to establish the probability that a certain industrial building exists in a certain census division or large State. Table 6.2.1 summarizes the weighted average annual operating hours per sector.

Table 6.2.1. Average Annual Lamp-and-Ballast System Operating Hours by Sector

Sector Average Annual Operating Hours hrs/year

Residential 789

Commercial 3,435

Industrial 4,795

6-2

### Figure 6.2.1 displays the probability distribu tion of annual operating hours DOE uses for lamp-and-ballast systems in the residential sector. DOE uses th ese annual operating hours in the

LCC calculation.

5

4 3 2

1

0% 10% 20% 30% 40% 50% 60% 70%Residential Sector FL System Probability 1: Mobile home 2: Single-family detached 3: Single-family attached 4: Multifamily 2-4 units 5: Multifamily > 4 units

686 806 739 806 790

Annual Operating Hours by Building Type (hrs/year) 

### Figure 6.2.1. Residential Sector Annual Operati ng Hour Distribution by Building Type

Figure 6.2.2 displays the annual operating hour probability distributions for lamp-and

ballast systems operating in th e commercial sector. DOE uses this distribution of annual operating hours in the LCC calculation.

20%

1: Vacant 8: Outpatient health care 16: Inpatient health care

18%ty 2 2: Office 4: Laboratory 11: Refrigerated warehouse 12: Religious worship 17: Nursing 18: Lodging

16%abili 5: Nonrefrigerated warehouse

6: Food sales 13: Public assembly

14: Education 25: Retail other than mall

26: Serviceob 7: Public order and safety 15: Food service 91: Other

14%Pr 26em 5

12%Syst

10%FL 25

8%Sector

12 14

6%ercial

6 13 15

4%Comm 1

8 18

2% 7 91

4 11 16 17

0%3,5453,6864,9733,4605,2243,5703,3313,8191,7052,5702,6434,5985,7514,3853,7803,6813,3943,638

Annual Operating Hours by Building Type (hrs/year)



### Figure 6.2.2. Commercial Sector Annual Operating Hour Distribution by Building Type

6-3Chemicals & allied products

s 

### Figure 6.2.3 displays the annual operating hour probability distribution for lamp-and

ballast systems operating in the industrial sector . DOE uses this distribution of annual operating

hours in the LCC calculation.Commercial Sector FL System Probability 20%

18%

16%

14%

12%

10%

8%

6%

4%

2%

0% 39

38 37 36 35 34

33 32

31 30

29 28 27

26 25 24

23 22

21 20 20. Food & kindred products

21. Tobacco

22. Textile mill 23. Apparel & other textile products

24. Lumber & wood products

25. Furniture & fixtures 26. Paper & allied products 27. Printing & publishing

28. 29. Petroleum & coal products

30. Rubber & miscellaneous plastics products

31. Leather and leather products 32. Stone, clay & glass product 33. Primary metal industries 34. Fabricated metal prorducts 35. Industrial machinery & equip.

36. Electronic & other electric equip. 37. Transportation equip.

38. Instruments & related products.

39. Miscellaneous5,8695,0914,9113,6475,7073,8885,8935,3235,2745,3005,4754,5165,3875,6804,0325,1674,4545,9763,5922,831

Annual Operating Hours by Building Type (hrs/year)



### Figure 6.2.3. Industrial Sector Annual Operating Hour Distribution by Building Type

In the case of programmed-star t (PS) ballasts operating two- lamp and four-lamp 4-foot MBP F32T8 lamps, DOE assumes that these lamp-and-ballast systems are operated on occupancy sensors in the commercial sector. Occupancy sensors detect the presence or absence of people within their coverage area and turn lights on and off accordingly, thereby reducing operating time and energy consumption. DOE examin ed a range of estimates for energy savings from occupancy sensors compiled in Esource 5 

### and assumes, based on this estimate, energy savings of 30 percent for operating lamp and ballast systems on occupancy sensors in the commercial sector. To account for these energy savings, DOE reduces average operating hours for affected lamp-and-ballast systems by 30 percent. Table 6.2.2 presents the adjusted average annual operating hours for PS lamp -and-ballast systems operating on occupancy sensors in the

commercial sector.

Table 6.2.2. Two- and Four-Lamp 4-Foot MBP PS Product Classes (F32T8 Baseline) – Adjusted Average Annual Operating Hours for Commercial Sector

Sector Average Annual Operating Hours hrs/yr
Commercial 2,405

6-4

### 6.3 RESULTS OF THE ENERGY USE CHARACTERIZATION

This section presents the annual energy use estimates for fluorescent lamp-and-ballast system designs. DOE calculates the annual en ergy consumption using annual operating hours and input power rating estimates. DOE uses the annual energy consumption results in the LCC and PBP analyses and the NIA to calculate the operating cost of systems and estimate the potential energy savings of candidate standard levels (CSLs).

Using annual operating hours and system rate d input power ratings, DOE calculates the annual energy consumption of the entire lamp-a nd-ballast system. The engineering analysis (chapter 5) references both measured system input power and normalized system input power, with the latter used to normalize input power between baseline and standards-case systems to maintain the same approximate light output.

Table 6.3.1 through Table 6.3.15 detail (1) the measured and normalized input power ratings for all the lamp-and-ballast systems DOE assesses in the LCC and PBP analysis for each product class; and (2) average annual energy c onsumption per lamp-and-ba llast system based on measured and normalized input power, using th e U.S. weighted average of annual operating hours in each sector. The average annual operatin g hours for the U.S. residential, commercial, and industrial sectors are 789, 3,435, and 4,795, respectively.

Table 6.3.1. Two-Lamp RS and IS Ballasts Op erating 4-Foot MBP and 2-Foot U-Shaped Lamps (F32T8 Baseline) – System Power Ra ting and Annual Energy Consumption,

Commercial Sector

CSL For Operation Of Starting

Method Input Power

W Annual Energy Consumption

kWh

Measured Normalized Measured Normalized

Baseline/1 2 F32T8 Lamps IS 60.4 60.4 207.5 207.5

2 2 F32T8 Lamps IS 56.0 57.0 192.4 195.8

3 2 F32T8 Lamps IS 56.4 56.5 193.7 194.1



### Table 6.3.2. Two-Lamp PS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps – System Power Rating and Annual Energy Consumption, Commercial Sector

CSL For Operation Of Starting

Method Input Power

W Annual Energy Consumption *

kWh

Measured Normalized Measured Normalized

Baseline 2 F32T8 Lamps PS 63.5 63.5 152.7 152.7

1 2 F32T8 Lamps PS 56.9 59.1 136.8 142.1

* Based on adjusted average annual operating hours to reflect operation on occupancy sensors (Table 6.2.2).



### Table 6.3.3. Two-Lamp RS and IS Ballasts Op erating 4-Foot MBP and 2-Foot U-Shaped Lamps (F34T12 Baseline) – System Power Rating and Annual Energy Consumption,

Commercial Sector

CSL For Operation Of Starting

Method Input Power

W Annual Energy Consumption

kWh

Measured Normalized Measured Normalized

Baseline 2 F34T12 Lamps RS 63.5 63.5 218.1 218.1

1 2 F32T8 Lamps IS 60.4 59.0 207.5 202.7

2 2 F32T8 Lamps IS 56.0 55.7 192.4 191.3

3 2 F32T8 Lamps IS 56.4 55.2 193.7 189.6

6-5

### Table 6.3.4. Four-Lamp RS and IS Ballasts Op erating 4-Foot MBP and 2-Foot U-Shaped Lamps – System Power Rating and Annual Energy Consumption, Commercial Sector

CSL For Operation Of Starting

Method Input Power

W Annual Energy Consumption

kWh

Measured Normalized Measured Normalized

Baseline 4 F32T8 Lamps IS 111.5 111.5 383.0 383.0

1 4 F32T8 Lamps IS 114.4 110.6 393.0 379.9



### Table 6.3.5. Four-Lamp PS Ballasts Operating 4- Foot MBP and 2-Foot U-Shaped Lamps – System Power Rating and Annual Energy Consumption, Commercial Sector

CSL For Operation Of Starting

Method Input Power

W Annual Energy Consumption *

kWh

Measured Normalized Measured Normalized

Baseline 4 F32T8 Lamps PS 120.3 120.3 289.3 289.3

1 4 F32T8 Lamps PS 116.1 114.2 279.2 274.7

* Based on adjusted average annual operating hours to reflect operation on occupancy sensors (Table 6.2.2).



### Table 6.3.6. Two-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps (F96T12HO/ES Baseline) – System Power Rating and Annual Energy Consumption,

Industrial Sector

CSL For Operation Of Starting

Method Input Power

W Annual Energy Consumption

kWh

Measured Normalized Measured Normalized

Baseline 2 F96T12HO/ES Lamps RS 208.4 208.4 999.3 999.3

1 2 F96T12HO/ES Lamps RS 170.0 183.4 815.2 879.4 2 F96T8HO Lamps RS 160.0 188.3 767.2 902.9

2 2 F96T8HO Lamps IS 142.8 218.8 684.7 1,049.1



### Table 6.3.7. Two-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps (F96T8HO Baseline) – System Power Rating and Annua l Energy Consumption, Industrial Sector

CSL For Operation Of Starting

Method Input Power

W Annual Energy Consumption

kWh

Measured Normalized Measured Normalized

Baseline/1 2 F96T8HO Lamps RS 160.0 160.0 767.2 767.2

2 2 F96T8HO Lamps IS 142.8 185.9 684.7 891.4



### Table 6.3.8. Two-Lamp IS Ballasts Operating 8- Foot Slimline Lamps (F96T12/ES Baseline)

–

System Power Rating and Annual Energy Consumption, Commercial Sector

CSL For Operation Of Starting

Method Input Power

W Annual Energy Consumption

kWh

Measured Normalized Measured Normalized

Baseline 2 F96T12ES Lamps IS 111.1 111.1 381.6 381.6

1 2 F96T12ES Lamps IS 109.5 109.6 376.1 376.5

6-6

### Table 6.3.9. Two-Lamp IS Ballasts Operating 8-Foot Slimline Lamps (F96T8 Baseline) – System Power Rating and Annual Energy Consumption, Commercial Sector

CSL For Operation Of Starting

Method Input Power

W Annual Energy Consumption

kWh

Measured Normalized Measured Normalized

Baseline 2 F96T8 Lamps IS 109.7 109.7 376.8 376.8

1 2 F96T8 Lamps IS 108.0 106.9 371.0 367.2



### Table 6.3.10. Two-Lamp PS Ballasts Operating 4-Foot T5 MiniBP SO Lamps – System Power Rating and Annual Energy Consumption, Commercial Sector

CSL For Operation Of Starting

Method Input Power

W Annual Energy Consumption

kWh

Measured Normalized Measured Normalized

Baseline 2 F28T5 Lamps PS 77.8 77.8 267.2 267.2

1 2 F28T5 Lamps PS 64.9 64.9 222.9 222.9

2 2 F28T5 Lamps PS 65.4 62.7 224.6 215.4



### Table 6.3.11. Two-Lamp PS Ballasts Operating 4-Foot T5 MiniBP HO Lamps – System Power Rating and Annual Energy Co nsumption, Industrial Sector

CSL For Operation Of Starting

Method Input Power

W Annual Energy Consumption

kWh

Measured Normalized Measured Normalized

Baseline 2 F54T5HO Lamps PS 143.5 143.5 688.1 688.1

1 2 F54T5HO Lamps PS 124.8 124.8 598.4 598.4

2 2 F54T5HO Lamps PS 122.4 119.1 586.9 571.1



### Table 6.3.12. Two-Lamp RS and IS Ballasts Op erating 4-Foot MBP and 2-Foot U-Shaped Lamps (Low Power Factor, F34T12 Baseline) – System Power Rating and Annual Energy Consumption, Residential Sector

CSL For Operation Of Starting

Method Input Power

W Annual Energy Consumption

kWh

Measured Normalized Measured Normalized

Baseline 2 F34T12 Lamps IS 45.9 45.9 36.2 36.2

1 2 F32T8 Lamps IS 53.1 39.5 41.9 31.2

2 2 F32T8 Lamps IS 55.3 38.6 43.6 30.5



### Table 6.3.13. Two-Lamp RS and IS Ballasts Op erating 4-Foot MBP and 2-Foot U-Shaped Lamps (Low Power Factor, F32T8 Baseline) – System Power Rating and Annual Energy Consumption, Residential Sector

CSL For Operation Of Starting

Method Input Power

W Annual Energy Consumption

kWh

Measured Normalized Measured Normalized

Baseline/1 2 F32T8 Lamps IS 53.1 53.1 41.9 41.9

2 2 F32T8 Lamps IS 55.3 51.8 43.6 40.9

6-7

### Table 6.3.14. Four-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps (Cold Temperature/Sign Ballasts) – System Power Rating and Annual Energy Consumption,

Commercial Sector

CSL For Operation Of Starting

Method Input Power

W Annual Energy Consumption

kWh

Measured Normalized Measured Normalized

Baseline 4 F96T12HO Lamps RS 393.6 393.6 1,352.0 1,352.0

1 4 F96T12HO Lamps IS 264.0 324.1 906.8 1,113.3



### Table 6.3.15. Four-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps (Cold Temperature/Sign Ballasts) – System Pow er Rating and Annual Energy Consumption,

Industrial Sector

CSL For Operation Of Starting

Method Input Power

W Annual Energy Consumption

kWh

Measured Normalized Measured Normalized

Baseline 4 F96T12HO Lamps RS 393.6 393.6 1,887.3 1,887.3

1 4 F96T12HO Lamps IS 264.0 324.1 1,265.9 1,554.1

6-8

### REFERENCES

1. U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Energy Conservation Program for Consumer Produc ts: Final Report: U.S. Lighting Market Characterization, Volume I: National Lighting Inventory and Energy Consumption Estimate. September 2002.

< http://apps1.eere.energy.gov/buildings /publications/pdfs/ssl/lmc_vol1_final.pdf >

2. U.S. Department of Energy–Energy Info rmation Administrati on. Commercial Building Energy Consumption Survey: Micro-level Data, File 2 Building Activities, Special Measures of Size, and Multi-building Facilities. 2003.

< http://www.eia.doe.gov/emeu/cbecs/public_use.html >

3 U.S. Department of Energy–Energy Info rmation Administration. Residential Energy Consumption Survey: File 1: Housing Unit Characteristic. 2006.

< http://www.eia.doe.gov/emeu/recs/recspubuse05/pubuse05.html >

4. U.S. Department of Energy–Energy Inform ation Administration. Manufacturing Energy Consumption Survey, Table 1.4: Number of Esta blishments by First Use of Energy for All Purposes (Fuel and Nonfuel). 2002.

< http://www.eia.doe.gov/emeu/mecs /mecs2002/data02/shelltables.html >

5. E Source. Purchasing Advisor Web Page – Lighting: Occupancy Sensors. 2009. (Last Accessed May 5, 2009.) < http://www.esource.com/BEA/demo/BEA_esource/PA_10.html >

6-9

### CHAPTER 7. MARKUPS ANALYSIS

TABLE OF CONTENTS

7.1 INTRODUCTION

.............................................................................................................. 7 -1

7.1.1 Baseline Markups

................................................................................................. 7-3

7.1.2 Incremental Markups

........................................................................................... 7-3

7.1.3 Overall Markups

.................................................................................................. 7-4

7.2 ESTIMATION OF OEM, WHOLESALER, CONTRACTOR AND SALES TAX

MARKUPS

........................................................................................................................ . 7-4

7.2.1 Financial Information Sources

............................................................................. 7-4

7.2.2 Weighted Markups

............................................................................................... 7-8

7.2.3 Sales Tax

.............................................................................................................. 7- 9

REFERENCES

..................................................................................................................... ..... 7-11

LIST OF TABLES

Table 7.2.1 Gross Profit Margins for Fixture OEMs *



### .................................................................. 7-5 Table 7.2.2 Gross Profit Margins for Electrical Wholesalers *



### ..................................................... 7-6 Table 7.2.3 Calculated OEM Baseline Markups for Fluorescent Lamp Ballasts

........................ 7-6

Table 7.2.4 Calculated Electrical Wholesaler Baseline Markups for Fluorescent Lamp

Ballasts

....................................................................................................................... ...... 7-6

Table 7.2.5 Calculated OEM Incremental Ma rkups for Fluorescent Lamp Ballasts *



### ................. 7-7

Table 7.2.6 Calculated Electrical Wholesaler Incremental Markups for Fluorescent Lamp

Ballasts *



### ............................................................................................................................ 7-8 Table 7.2.7 Weighted Total Baseline and In cremental Markups for Fluorescent Lamp

Ballasts

....................................................................................................................... ...... 7-9

Table 7.2.8 State and Local Sales Tax Ra tes

............................................................................... 7-9 Table 7.2.9 Regional Aver age Tax Rates

.................................................................................. 7-10

LIST OF FIGURES

Figure 7.1.1 Ballast Distribution Channels

.................................................................................. 7-1

7-i

### CHAPTER 7. MARKUPS ANALYSIS

7.1 INTRODUCTION

This chapter describes the methodology the U. S. Department of Energy (DOE) followed in developing end-user prices and sales tax in the rulemaking analysis for fluorescent lamp ballasts. This chapter also provides initial results for ballast end-user prices and sales tax.

In this rulemaking, DOE performed teardo wn analyses and a manufacturer markup analysis to develop manufacturer selling prices (MSPs) for representative ballast designs (chapter 5). DOE then applied distribution cha nnel markups and sales tax to derive end-user prices. By combining the engineering analysis results and the distri bution channel markups analysis, DOE derived typical inputs for use in the life-cycle cost (LCC) analysis and the national impact analysis (NIA). In particular, DO E developed end-user prices for ballast designs

associated with a candi date standard level.

The end-user equipment price depends on how the end-user purchases the equipment. Two types of distribution channels describe how most ballasts pass from the manufacturer to the

end-user. The first distribution cha nnel applies to ballasts installed in fixtures. In this distribution channel, the manufacturer sells the ballast to an original equipment manufacturer (OEM)—in this case, the fixture manufacturer—who in turn sells it to an electrical wholesaler ( i.e.

, distributor), then to a contractor, and finally to the end-user . The second distribution channel applies to ballasts not in stalled in fixtures ( e.g. , replacement ballasts). In this distribution channel, the manufacturer sells the ballast to an electrical wholesaler, then to a contractor, and finally to the end-user. Figure 7.1.1 illustrates th e two main distribution channels for ballasts.

Figure 7.1.1 Ballast Distribution Channels

7-1

### DOE assumes ballasts in fixtures represent 63 percent of the market, and replacement ballasts represent 37 percent. These percentages are from the Fluorescent Ballasts Energy Conservation Standards Final Rule published on September 19, 2000 (hereafter “the 2000 Ballast Rule”). 65 FR 56740. 1



### To meet new or amended energy conservati on standards, manufacturers often introduce design changes to their product lines that re sult in increased production costs and MSPs. DOE

assumes that some or all of th e increased production costs can be passed through the distribution channels and eventually to end-users in the form of higher sales prices.

At each point in the distribution channel, companies apply “markup” to the MSP to cover their business costs and profit margin. DOE mode ls this markup as a multiplier. In financial statements, gross profit is the difference between the company revenue and the company cost of sales. It includes all corporate overhead costs (s ales, general, and adminis tration), materials and labor costs, research and devel opment and interest expenses, depreciation and taxes, and profits. In order for sales of a product to contribut e positively to company cash flow, the product’s markup must be greater than the sum of cost of sales and business costs for that product. DOE calculates the end-user sales price by multiplyin g the MSP by the various markups and applying

sales tax.

The end-user prices and installation costs are key inputs to the LCC analysis, payback period (PBP) analysis, and the NIA. Through th e use of the distribution channel markups and installation costs, DOE can calculate the first costs that customers would face under the various efficiency levels evaluated. DOE evaluates the tradeoff between the increase in first cost and the resulting energy cost savings at each efficiency level in the LCC and PBP analyses (chapter 8) and NIA analysis (chapter 10).

The following equation describes how DOE dete rmined the equipment prices for ballast designs installed in fixtures:

P

END 

### = ( P MFR 

### × MU OEM 

### × MU WHOLE 

### × MU CONT 

### × MU TAX 

### ) 

### Eq. 7.1

Where:

P

END 

### = equipment price to the end-user ($),

P

MFR 

### = MSP of baseline or standard-level equipment ($),

MU OEM 

### = OEM markup,

MU WHOLE 

### = wholesaler markup,

MU CONT 

### = contractor markup, and

MU TAX 

### = sales tax markup.

For replacement ballasts, the equation is th e same as above, except that the OEM markup ( MU OEM 

### ) is omitted.

For each of the parties involved in the di stribution of the equipment, the markups presented above are further differentiated betw een a “baseline markup” and an “incremental

7-2

### markup,” as described below. A third type of markup, the “ overall markup,” describes the product of all the markups within a distribution channel.

7.1.1 Baseline Markups

Baseline markups are defined as coefficients th at relate the manufacturer price of baseline ballast designs to the OEM, wholesaler or cont ractor baseline sales price, as shown in the following equations:

P OEM

_ BASE 

### = ( P MFR

_ BASE 

### × MU OEM

_ BASE 

### ) 

### Eq. 7.2

P WHOLE

_ BASE 

### = ( P OEM

_ BASE 

### × MU WHOLE

_ BASE 

### ) 

### Eq. 7.3

P CONT

_ BASE 

### = ( P WHOLE

_ BASE 

### × MU CONT

_ BASE 

### ) 

### Eq. 7.4

P

END

_ BASE 

### = ( P CONT

_ BASE 

### × MU TAX 

### ) 

### Eq. 7.5

Where:

P OEM

_ BASE 

### = OEM selling price of baseline equipment ($),

P

MFR

_ BASE 

### = MSP of baseline equipment ($),

MU OEM

_ BASE 

### = OEM markup for baseline equipment,

P WHOLE

_ BASE 

### = wholesaler selling price of baseline equipment ($),

MU WHOLE

_ BASE 

### = wholesaler markup for baseline equipment,

P CONT

_ BASE 

### = contractor selling price of baseline equipment ($),

MU CONT

_ BASE 

### = contractor markup for baseline equipment,

P

END

_ BASE 

### = end-user purchase price fo r baseline equipment ($), and

MU TAX 

### = sales tax markup.

For replacement ballasts, the equations ar e the same as above, except that the OEM ( P OEM

_ BASE 

### = ( P MFR

_ BASE 

### × MU OEM

_ BASE 

### ) 

### ) is omitted, and the wholesaler baseline selling price is
determined by applying the wholesaler base line markup to the MSP for baseline equipment:

P WHOLE

_ BASE 

### = ( P MFR

_ BASE 

### × MU WHOLE

_ BASE 

### ) 

### Eq. 7.6

7.1.2 Incremental Markups

Incremental markups are defined as coefficien ts that relate changes in the manufacturer price of higher-efficiency equipment to change the OEM, wholesale, or contractor sales price, as shown in the following equations:

P OEM

_ INCR 

### = ( P MFR

_ INCR 

### × MU OEM

_ INCR 

### ) 

### Eq. 7.7

P WHOLE

_ INCR 

### = ( P OEM

_ INCR 

### × MU WHOLE

_ INCR 

### ) 

### Eq. 7.8

P CONT

_ INCR 

### = ( P WHOLE

_ INCR 

### × MU CONT

_ INCR 

### ) 

### Eq. 7.9

7-3

### P END

_ INCR 

### = ( P WHOLE

_ INCR 

### × MU TAX 

### ) 

### Eq. 7.10

Where:

P OEM

_ INCR 

### = incremental OEM price for equipment with increased efficiency ($),

P

MFR

_ INCR 

### = incremental manufacturer price for equipment with increased efficiency ($),

MU OEM

_ INCR 

### = incremental OEM markup for equipment with increased efficiency,

P WHOLE

_ INCR 

### = incremental wholesaler price for equipment with increased efficiency ($),

MU WHOLE

_ INCR 

### = incremental wholesaler markup for equipment with increased efficiency,

P CONT

_ INCR 

### = incremental contractor price for equipment with increased efficiency ($),

MU CONT

_ INCR 

### = incremental contractor markup for equipment with increased efficiency,

P

END

_ INCR 

### = incremental end-user price for baseline equipment ($), and

MU TAX 

### = sales tax markup.

For replacement ballasts, the equations are the same as above, except that incremental OEM ( P OEM

_ INCR 

### = ( P MFR

_ INCR 

### × MU OEM

_ INCR 

### ) 

### ) is omitted, and the incremental wholesaler price
is determined by applying the incremental w holesaler markup to the incremental manufacturer price for equipment with increased efficiency:

P WHOLE

_ INCR 

### = ( P MFR

_ INCR 

### × MU WHOLE

_ INCR 

### ) 

### Eq. 7.11

7.1.3 Overall Markups

Overall markups, including bot h overall baseline a nd overall incrementa l markups, relate the manufacturer price to the final customer price ( P END 

### ) as indicated by the following equation

P

END 

### = ( P END

_ BASE 

### + P END

_ INCR 

### ) 

### Eq. 7.12

7.2 ESTIMATION OF OEM, WHOLESALER, CONTRACTOR AND SALES TAX

MARKUPS

7.2.1 Financial Information Sources

Publicly owned companies are required by la w to disclose financial information on a regular basis by filing different forms with the U.S. Securities and Exchange Commission (SEC). Filed annually, the SEC form 10-K provides a comprehensive overview of the company’s

business and financial conditions . Relevant information in the 10-K reports includes the company’s revenues and direct and indirect co sts. For the OEM and wholesaler markups, DOE used 10-K reports from publicly owned lighting fi xture manufacturers and el ectrical wholesalers, respectively. The financial figures necessary for calculating the company markup are net sales, costs of sales, and gross profit. The income statement section of the 10-K reports often lists these figures. DOE used averages of the financial figures spanning 2002 to 2008 to calculate the markups.

7-4

### DOE used the following equations to calculate the gross profit and gross profit margins:

Gross Profit ($) = Net Sales – Cost of Sales Eq. 7.13

Gross Profit Gross Profit Margin = 

### Eq. 7.14 N et Sales



### To calculate the time-average gross profit margin for each company, DOE first summed the gross profit for all the years and then divided the result by the sum of the net sales for the same years. DOE then used the gross profit ma rgins to calculate baseline markups on existing equipment ( i.e. , prior to efficiency changes resulting from enactment of proposed efficiency standards). Each company’s base line markup was calculated as:

1 Net Sales Baseline Markup = = Eq. 7.15 (1

− Gross Profit Margin) Cost of Sales

Table 7.2.1 and Table 7.2.2 contain the calculate d gross profit margins for a sample of fixture OEMs and electrical wholesalers, respectively.

Table 7.2.1 Gross Profit Margins for Fixture OEMs *

Company Financial Figure
$ Year

2008 2007 2006 2005 2004 2003 2002

A Net Sales 2,026,644 1,964,781 1,841,039 2,172,854 2,104,167 2,049,308 1,972,796

Cost of Sales 1,210,849 1,220,466 1,188,202 1,324,311 1,253,380 1,235,900 1,169,282

Gross Profit 815,795 744,315 652,8 37 848,543 850,787 813,408 803,514

Gross Profit Margin ( % ) 40.3 37.9 35.5 39.1 40.4 39.7 40.7

Average Gross Profit Margin: 39.1%

B Net Sales 6,521,300 5,903,100 5,184,600 4,730,400 4,462,900 4,061,400 3,960,500

Cost of Sales 4,396,700 3,970,000 3,521,500 3,243,800 3,119,700 2,871,900 2,830,900

Gross Profit 2,124,600 1,933,100 1,663,100 1,486,600 1,343,200 1,189,500 1,129,600

Gross Profit Margin ( % ) 32.6 32.7 32.1 31.4 30.1 29.3 28.5

Average Gross Profit Margin: 31.0%

C ** Net Sales 1,484,833 1,252,194 1,179,069 1,033,899 970,304

Cost of Sales 896,027 785,973 760,938 671,322 630,433

Gross Profit 588,806 466,221 418,131 362,577 339,871

Gross Profit Margin ( % ) 39.7 37.2 35.5 35.1 35.0

Average Gross Profit Margin: 36.5%

D Net Sales 2,704,400 2,533,900 2,414,300 2,104,900 1,993,000 1,770,700 1,587,800

Cost of Sales 1,901,000 1,798,100 1,757,500 1,509,900 1,431,100 1,289,200 1,178,700

Gross Profit 803,400 735,800 656,8 00 595,000 561,900 481,500 409,100

Gross Profit Margin ( % ) 29.7 29.0 27.2 28.3 28.2 27.2 25.8

Average Gross Profit Margin: 27.9%

* Unless noted, all numbers are in thousands of dollars. This table includes 2002, 2003, 2004, 2005, 2006, 2007, and 2008 SEC 10-K reports.

** Data are not available for missing years.

7-5

### Table 7.2.2 Gross Profit Margin s for Electrical Wholesalers *

Company Financial Figure
$ Year

2008 2007 2006 2005 2004 2003 2002

A Net Sales 5,400,154 5,258,301 5,009,143 4,288,043 4,079,553 3,802,452 3,974,892

Cost of Sales 4,354,935 4,225,983 4,047,692 3,477,009 3,295,772 3,067,986 3,229,791

Gross Profit 1,045,219 1,032,318 961,451 811,034 783,781 734,466 745,101

Gross Profit Margin ( % ) 19.4 19.6 19.2 18.9 19.2 19.3 18.7

Average Gross Profit Margin: 19.2%

B Net Sales 6,110,840 6,003,452 5,320,603 4,421,103 3,741,253 3,286,766 3,325,780

Cost of Sales 4,904,164 4,781,336 4,234,079 3,580,398 3,029,132 2,676,701 2,735,006

Gross Profit 1,206,676 1,222,116 1,086,524 840,705 712,121 610,065 590,774

Gross Profit Margin ( % ) 19.7 20.4 20.4 19.0 19.0 18.6 17.8

Average Gross Profit Margin: 19.3%

C Net Sales 6,850,032 6,418,014 5,883,654 5,526,636 5,049,785 4,667,014 4,643,898

Cost of Sales 4,041,810 3,814,391 3,529,504 3,365,095 3,143,133 2,975,513 2,984,548

Gross Profit 2,808,222 2,603,623 2,354,150 2,161,541 1,906,652 1,691,501 1,659,350

Gross Profit Margin ( % ) 41.0 40.6 40.0 39.1 37.8 36.2 35.7

Average Gross Profit Margin: 38.6%

D ** Net Sales 90,837,000 81,511,000 73,09 4,000 64,816,000 58,247,000 53,553,000

Cost of Sales 61,054,000 54,191,000 48, 664,000 44,236,000 40,139,000 37,406,000

Gross Profit 29,783,000 27,320,000 24,43 0,000 20,580,000 18,108,000 16,147,000

Gross Profit Margin ( % ) 32.8 33.5 33.4 31.8 31.1 30.2

Average Gross Profit Margin: 32.1%

* Unless noted, all numbers are in thousands of dollars. This table includes 2002, 2003, 2004, 2005, 2006, 2007, and 2008 SEC 10-K reports.

** Data are not available for missing years.



### The baseline markup covers non-production costs and profit. Table 7.2.3 and Table 7.2.4 show the baseline markups using this method for OEMs and electrical wholesalers, respectively.

Table 7.2.3 Calculated OEM Baseline Mar kups for Fluorescent Lamp Ballasts

Company Baseline Markup

OEM – A 1.64

OEM – B 1.45

OEM – C 1.57

OEM – D 1.39 Average 1.51



### Table 7.2.4 Calculated Electrical Wholesaler Baseline Markups for Fluorescent Lamp

Ballasts

Company Baseline Markup

Wholesaler A 1.24

Wholesaler B 1.24

Wholesaler C 1.63

Wholesaler D 1.47 Average 1.39

7-6

### The incremental markup applied to higher-e fficiency equipment is lower than the baseline markup because DOE assumes that expe nses like labor and occupancy costs remain fixed and need not be recovered in the markup. Profits and other operatin g costs are assumed to

be variable and to scale with the MSP.

The surveyed SEC 10-K reports did not typi cally separate labor and occupancy costs from overall expenses, so DOE assumes that these fixed costs are encompassed by “Selling, Distribution, and Administrative Expenses” (the most common terminology observed in the surveyed reports). DOE assumes that “Opera ting Profit” (operating income) covers other operating costs and profit ( i.e. , variable costs). Each company’s incremental markup was

calculated as:

⎛ ⎜ ⎝ Operating Profit ⎞ ⎟ ⎠ Incremental Markup = 1 + 

### Eq. 7.16 Cost of Sales



### Table 7.2.5 and Table 7.2.6 contain the calcula ted incremental markups for the sampled fixture OEMs and electrical wholesalers, respectively.

Table 7.2.5 Calculated OEM Incremental Markups for Fluorescent Lamp Ballasts *

Company Financial Figure
$ Year

2008 2007 2006 2005 2004 2003 2002

A Cost of Sales 1,210,849 1,220,466 1,188,202 1,324,311 1,253,380 1,235,900 1,169,282 Operating Profit 261,060 222,423 152, 119 106,745 137,927 110,276 120,127

Calculated

Incremental

Markup 1.22 1.18 1.13 1.08 1.11 1.09 1.10

Average Incremental Markup: 1.13

B Cost of Sales 4,396,700 3,970,000 3,521,500 3,243,800 3,119,700 2,871,900 2,830,900 Operating Profit 877,600 844,100 694, 100 559,800 496,600 392,000 354,700

Calculated

Incremental

Markup 1.20 1.21 1.20 1.17 1.16 1.14 1.13

Average Incremental Markup: 1.17

C ** Cost of Sales 896,027 785,973 760,938 671,322 630,433 Operating Profit 208,334 149,342 149,342 108,252 96,418

Calculated

Incremental

Markup 1.23 1.19 1.20 1.16 1.15

Average Incremental Markup: 1.19

D Cost of Sales 1,901,000 1,798,100 1,757,500 1,509,900 1,431,100 1,289,200 1,178,700 Operating Profit 346,000 299,400 233, 900 226,800 212,600 171,900 138,500

Calculated

Incremental

Markup 1.18 1.17 1.13 1.15 1.15 1.13 1.12

Average Incremental Markup: 1.15

ALL Average Incremental Markup (All OEMs): 1.16

* Except for calculated incremental markup, all numbers are in thousands of dollars. This table includes 2002, 2003, 2004, 2005, 2006, 2007, and 2008 SEC 10-K reports.

** Data are not available for missing years.

7-7

### Table 7.2.6 Calculated Electrical Wholesaler Incremental Markups for Fluorescent Lamp

Ballasts *

Company Financial Figure
$ Year

2008 2007 2006 2005 2004 2003 2002

A Cost of Sales 4,354,935 4,225,983 4,047,692 3,477,009 3,295,772 3,067,986 3,229,791 Operating Profit 151,863 161,787 122, 022 64,789 41,844 30,895 42,153

Calculated

Incremental

Markup 1.03 1.04 1.03 1.02 1.01 1.01 1.01

Average Incremental Markup: 1.02

B Cost of Sales 4,904,164 4,781,336 4,234,079 3,580,398 3,029,132 2,676,701 2,735,006 Operating Profit 345,667 394,224 364, 983 209,286 149,446 86,045 76,625

Calculated

Incremental

Markup 1.07 1.08 1.09 1.06 1.05 1.03 1.03

Average Incremental Markup: 1.06

C Cost of Sales 4,041,810 3,814,391 3,529,504 3,365,095 3,143,133 2,975,513 2,984,548 Operating Profit 782,672 670,653 578, 071 518,989 439,530 387,261 393,155

Calculated

Incremental

Markup 1.19 1.18 1.16 1.15 1.14 1.13 1.13

Average Incremental Markup: 1.16

D ** Cost of Sales 61,054,000 54,191,000 48, 664,000 44,236,000 40,139,000 37,406,000 Operating Profit 9,673,000 9,363,000 7,926,000 6,846,000 5,830,000 4,932,000

Calculated

Incremental

Markup 1.16 1.17 1.16 1.15 1.15 1.13

Average Incremental Markup: 1.15

ALL Average Incremental Markup (All Wholesalers): 1.10

* Except for calculated incremental markup, all numbers are in thousands of dollars. This table includes 2002, 2003, 2004, 2005, 2006, 2007, and 2008 SEC 10-K reports.

** Data are not available for missing years.



### 7.2.2 Weighted Markups

DOE adjusted the calculated average baseline and incremental markups to reflect estimated proportions of ballasts sold through the OEM and w holesaler distribution channels. DOE used information from the 2000 Ballast Rule, which estimates that ballasts sold to OEM fixture manufacturers represent 63 percent of the market while ballasts sold to electrical wholesalers represent 37 percent of the market. DOE then multiplied by a contractor markup of

1.13 (obtained from the 2000 Ballast Rule) to the resulting weighted average baseline and incremental markups to devel op total weighted markups. The weighted total baseline and incremental markups are provided in Table 7.2.7.

7-8

### Table 7.2.7 Weighted Total Baseline and Incremental Markups for Fluorescent Lamp

Ballasts

Markup Type Weighted Total

Baseline 2.08

Incremental 1.37



### 7.2.3 Sales Tax

The sales tax represents State and local sales taxes applied to and is a multiplicative

factor that increases the end-user cost. DOE obtained information on State and local sales tax from the Sales Tax Clearinghouse (Table 7.2.8). 2 

### These data represent weighted averages that include county and city rates. DOE then calcula ted population-weighted average tax values for each census division and four large States. These values allowed DOE to correlate the sales tax distribution with the electricity price distribution (chapter 8) a nd the operating hour distribution (chapter 6) that DOE uses in the LCC spr eadsheet. DOE also calculated a national populationweighted average sales tax for use as a single-val ue input to the LCC, should users want singleaverage results. DOE also used this result in th e NIA, where DOE did not use a distribution of inputs. 3



### Table 7.2.8 State and Local Sales Tax Rates

State Combined State

and Local Tax Rate

% State Combined State

and Local Tax Rate

% State Combined State

and Local Tax Rate

%

Alabama 8.15 Kentucky 6.00 North Dakota 5.75

Alaska 1.50 Louisiana 8.75 Ohio 6.85

Arizona 7.15 Maine 5.00 Oklahoma 8.10

Arkansas 8.25 Maryland 6.00 Oregon 0.00

California 9.00 Massachusetts 5.00 Pennsylvania 6.25

Colorado 6.40 Michigan 6.00 Rhode Island 7.00

Connecticut 6.00 Minnesota 6.85 South Carolina 7.05

Delaware 0.00 Mississippi 7.00 South Dakota 5.45

D.C. 5.75 Missouri 7.10 Tennessee 9.40

Florida 6.70 Montana 0.00 Texas 8.05 Georgia 6.90 Nebraska 6.00 Utah 6.70

Hawaii 4.40 Nevada 7.50 Vermont 6.05

Idaho 6.05 New Hampshire 0.00 Virginia 5.00

Illinois 8.40 New Jersey 6.95 Washington 8.75

Indiana 7.00 New Mexico 6.40 West Virginia 6.00

Iowa 6.80 New York 8.25 Wisconsin 5.40

Kansas 6.95 North Carolina 6.80 Wyoming 5.40



### Table 7.2.9 shows the distribution of sales tax rates that DOE developed for the LCC and PBP analyses. The distribution ranges from a minimum of 4.98 percent in New England to a maximum of 9.00 percent in Ca lifornia with a weighted average value of 7.12 percent

nationwide.

7-9

### Table 7.2.9 Regional Average Tax Rates

Region or Large State Weighted

Sales Tax

% New England 4.98

Mid Atlantic 6.54

East North Central 6.94

West North Central 6.76

South Atlantic 6.19

East South Central 7.89

West South Central 8.40

Mountain 6.46

Pacific 5.20

New York 8.25

California 9.00

Texas 8.05

Florida 6.70 U.S. Average 7.12

7-10

### REFERENCES

1. U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Energy Conservation Program for Consumer Produc ts: Technical Support Document: Energy Efficiency Standards for Consumer Products ; Fluorescent Lamp Ba llast Proposed Rule. January 2000. (Last accessed June 30, 2009.)

< http://www.eere.energy.gov/buildings/applia nce_standards/resi dential/pdfs/chap3.pdf >

2. The Sales Tax Clearinghouse. State Aggreg ate Tax Rates. 2009. (Last accessed June 30, 2009.) < http://thestc.com/STrates.stm >

3. U.S. Census Bureau. Population Estimates Change: April 1, 2000 to July 1, 2008. 2008. (Last accessed June 30, 2009.) < http://www.census.gov/popest/s tates/tables/NST-EST2008

- 02.csv >

7-11

### CHAPTER 8. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES

TABLE OF CONTENTS

8.1 INTRODUCTION

........................................................................................................... 8-1

8.1.1 General Approach for LCC and PBP Analyses

................................................... 8-1

8.1.2 Overview of LCC and PBP Inputs

....................................................................... 8-3

8.2 LIFE-CYCLE COST INPUTS

........................................................................................ 8-6

8.2.1 Definition

............................................................................................................. 8- 6

8.2.2 Total Installed Cost Inputs

................................................................................... 8-7

8.2.2.1 Installation Costs

...................................................................................... 8-8

8.2.3 Operating Cost Inputs

.......................................................................................... 8-9

8.2.3.1 Operating Hours

..................................................................................... 8-10

8.2.3.2 Power Rating

.......................................................................................... 8-11

8.2.3.3 Electricity Prices

.................................................................................... 8-11

8.2.3.4 Electricity Price Trend

........................................................................... 8-12

8.2.4 Lifetime

.............................................................................................................. 8-1 3

8.2.5 Replacement Cost

.............................................................................................. 8-14

8.2.6 Disposal Cost

..................................................................................................... 8-15

8.2.7 Analysis Period

.................................................................................................. 8-15

8.2.8 Discount Rate

..................................................................................................... 8-15

8.2.8.1 Residential Discount Rate

...................................................................... 8-16

8.2.8.2 Commercial Discount Rate

.................................................................... 8-18

8.2.9 Effective Date of Standard

................................................................................. 8-22

8.3 PAYBACK PERIOD INPUTS

...................................................................................... 8-23

8.3.1 Definition

........................................................................................................... 8-23

8.3.2 Rebuttable Presumption Payback Period

........................................................... 8-23

8.3.3 Inputs

.................................................................................................................. 8 -24

8.4 BALLAST PURCHASING EVENTS

........................................................................... 8-24

8.5 LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS

...................................... 8-26

REFERENCES

..................................................................................................................... ..... 8-34

LIST OF TABLES

Table 8.1.1. Summary Information of Inputs for the Life-Cycle Cost and Payback Period Analyses

............................................................................................................... 8-6 Table 8.2.1. Labor Times for Fluorescent Lamp -and-Ballast System s (Commercial and Industrial) *



### ............................................................................................................ 8-8 Table 8.2.2. Relamping and Lamp-and-Ballast Labor Costs for Fluorescent Lamp-andBallast Systems (Commercial and Industrial) *



### .................................................... 8-9 Table 8.2.3. Average Operatin g Hours by Sector

...................................................................... 8-10 Table 8.2.4. Average Operating Hours for Two- and Four-Lamp PS Ballasts Operating 4­ Foot MBP and 2-Foot U-Shaped Lamps in the Commercial Sector

................. 8-11 Table 8.2.5. Electricity Prices by Census Division, 2008

.......................................................... 8-11

8-i

### Table 8.2.6. Average Percentage Shares of Household Debt and Equity Types

....................... 8-16 Table 8.2.7. Average Nominal and Real Interest Rates for Household Debt Classes

............... 8-17 Table 8.2.8. Average Nominal and Real Interest Rates for Household Equity Types

.............. 8-17

Table 8.2.9. Shares and Interest or Return Rates Used for Household Debt and Equity Types

.................................................................................................................. 8-18

Table 8.2.10. Variables Used to Estima te Company Discount Rates

........................................ 8-20 Table 8.2.11. Real Discount Rates by Ballast Ownership Category

......................................... 8-21

Table 8.2.12. Estimated Share of Ballast Purc hases by Ownership Category in the

Commercial Sector *



### ........................................................................................... 8-21 Table 8.2.13. Ballast Ownership by Sector *



### .............................................................................. 8-21 Table 8.2.14. Average Discount Rate by Sector

........................................................................ 8-22

Table 8.2.15. Effective Dates of Standards for Ballast Designs Addre ssed in Life-Cycle Cost and Payback Period Analyses *



### .................................................................. 8-22 Table 8.4.1. Framework of Event-Type Scenar ios for Ballasts Operating 4-Foot and 8­ Foot T12 Lamps (including MBP, Slimline, and RDC)

.................................... 8-25 Table 8.4.2. Framework of Event-Type Scenar ios for Ballasts Operating 4-Foot and 8­ Foot T8 Lamps (including MBP, Slimline, and RDC)

...................................... 8-25 Table 8.4.3. Framework of Event-Type Scenar ios for Ballasts Operating 4-Foot T5 MiniBP Lamps

................................................................................................... 8-26 Table 8.5.1. LCC and PBP Results for Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps in the Commercial Sector (F32T8 Baseline)

............................................................................................................ 8-27

Table 8.5.2. LCC and PBP Results for Two-La mp PS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps in the Commercial Sector

................................... 8-27 Table 8.5.3. LCC and PBP Results for Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps in the Commercial Sector (F34T12 Baseline)

............................................................................................................ 8-28 Table 8.5.4. Summary of the LCC and PBP Results for 4-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps in the Commercial

Sector

................................................................................................................. 8-28

Table 8.5.5. LCC and PBP Results for Four-L amp PS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps in the Commercial Sector

................................... 8-29 Table 8.5.6. LCC and PBP Results for Two-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps in the Industrial S ector (F96T12HO/ES Baseline)

................ 8-29 Table 8.5.7. LCC and PBP Results for Two-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps in the Industrial Sector (F96T8HO Baseline)

........................ 8-30 Table 8.5.8. LCC and PBP Results for Two-Lamp IS Ballasts Operating 8-Foot Slimline Lamps in the Commercial Sector (F96T12ES Baseline)

................................... 8-30 Table 8.5.9. LCC and PBP Results for Two-Lamp IS Ballasts Operating 8-Foot Slimline Lamps in the Commercial Sector (F96T8 Baseline)

.......................................... 8-31 Table 8.5.10. LCC and PBP Results for Two-Lamp PS Ballasts Operating 4-Foot T5 MiniBP SO Lamps in the Commercial Sector

................................................................... 8-31

Table 8.5.11. LCC and PBP Results for Two- Lamp PS Ballasts Operating 4-Foot T5 MiniBP HO Lamps in th e Industrial Sector

........................................................ 8-31

8-ii

### Table 8.5.12. LCC and PBP Results for Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps in the Residential Sector (Low Power Factor, F34T12 Baseline)

................................................................................... 8-32 Table 8.5.13. LCC and PBP Results for Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps in the Residential Sector (Low Power Factor, F32T8 Baseline)

..................................................................................... 8-32

Table 8.5.14. LCC and PBP Results for Four-Lam p RS and IS Ballasts Operating 8-Foot RDC HO Lamps (Cold Temperature/Sign Ballasts) in the Commercial

Sector

................................................................................................................. 8-33

Table 8.5.15. LCC and PBP Results for Four-Lam p RS and IS Ballasts Operating 8-Foot RDC HO Lamps (Cold Temperature/Sign Ballasts) in the Industrial Sector

.... 8-33

LIST OF FIGURES

Figure 8.1.1. Flow Diagram of Inputs for th e Determination of LCC and PBP

.......................... 8-5 Figure 8.2.1. Residential Sector Electricity Price Trend

........................................................... 8-12 Figure 8.2.2. Commercial Sector Electricity Price Trend

.......................................................... 8-13 Figure 8.2.3. Industrial Sector El ectricity Price Trend

.............................................................. 8-13

8-iii

### CHAPTER 8. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES

8.1 INTRODUCTION

This chapter describes the analysis the U.S. Department of Energy (DOE) conducts to evaluate the economic impacts on individua l consumers of proposed amended energy

conservation standards for fluoresce nt lamp ballasts (hereafter “ballasts”). Because ballasts are designed to operate fluorescent lamps, DOE chooses the most common fluorescent lamp used with each ballast to develop re presentative lamp-and-ballast syst ems. Fluorescent lamps will not be regulated under the proposed amended energy conservation standards for ballasts; however, the characteristics of complete lamp-and-ballast systems ( e.g. , energy consumption, installed cost, etc.) must be considered for estimating economic impacts of analyzed ballast designs.

Amended standards usually decrease operatin g costs and increase purchase costs for consumers. This chapter describes the three metrics used in this analysis to determine the impact

of standards on individual consumers:

• 

### Life-cycle cost (LCC) is the total (discount ed) consumer cost over the analysis period including purchase price, operating costs (including energy expenditures), and

installation costs.

• 

### Payback period (PBP) is the number of years it takes a customer to recover the generally higher purchase price of a more energy-e fficient product through the operating cost savings of using the more energy-efficient product. The PBP is calculated as the change in first cost divided by the change in operating costs in the first year.

• 

### Rebuttable payback period is a special case in which the PBP is calculated based on laboratory conditions, specifically DOE test procedure inputs. DOE calculates the aforementioned LCC and PBP using a range of inputs, which are designed to reflect

actual conditions.

Sections 8.2 and 8.3 discuss inputs to the LCC and PBP, respectively. Section 8.4 discusses the different purchasing events DOE analyzes, which affect consumer economics. Section 8.5 presents the results for the LCC a nd PBP. Key variables and calculations are presented for each metric. DOE performs the ca lculations discussed here using a series of Microsoft Excel spreadsheets developed for this rulemaking. Stakeholders are invited to download and examine the spreadsheets available at www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_ballasts.html

. Appendix 8A presents details and instructions for using the spreadsheets.

8.1.1 General Approach for LCC and PBP Analyses

Recognizing that several inputs to the LCC and PBP analysis are either variable or uncertain, DOE will incorporate Monte Carlo simulation and probability distributions into its LCC and PBP model in the notice of proposed ru lemaking (NOPR) stage of this rulemaking.

8-1

### DOE incorporates both Monte Carlo simulation and probability distributions by using Microsoft Excel spreadsheets combined with Crystal Ball, a commercially available add-in program.

The relationship between increasing selling price and increasing energy efficiency is the predominant influence on the LCC and PBP resu lts. However, other factors related to the characteristics of the consumer using the pr oducts also affect the results. Based on the geographic region, sector, and application in which a consumer uses the ballasts, factors such as energy prices, sales tax, and energy usage ca n vary. DOE will account for this variability by using the Monte Carlo simulation and separate sensitivity runs.

For the LCC and PBP analyses, DOE considers variability in the discount rate. DOE also models variability in operating hours by sector, ballast type, and building applications. By developing samples by building type, DOE can perform the LCC and PBP calculations and account for the variability in operating hours, electricity price, and sales tax among a variety of buildings. DOE uses the Energy Information Administration’s (EIA) 2005 Residential Energy Consumption Survey (RECS), 2003 Commercial Buildings Energy Consumption Survey (CBECS), and 2002 Manufacturing Energy Consump tion Survey (MECS) to develop samples by building type, as well as U.S. Lighting Market Characterization: Volume I (LMC) to develop the operating hour characteristics by application in those buildings. The LCC and PBP spreadsheets present the results of the analysis as average values, relative to the baseline conditions. (Appendix 8B presents more information on the distribution of results from the LCC and PBP analysis, including the average and median PBP va lues and the percentages of trials which result in positive or negative LCCs).

In the standards case for the LCC and PBP analyses, DOE assumes that consumers will achieve energy savings by choosing a ballast that meets or exceeds the standard while generally keeping system light output within 10 percent of the output of the baseline system. While

consumers would have other choi ces in addition to those presented in the LCC, DOE considers only energy-saving ballast designs in the LCC.

DOE considers various scenarios that prompt consumers to buy a ballast in the base versus standards cases. Specifically, the “event” that prompts the purchase of a new ballast (either a ballast failure or ne w construction/renovation) is a ssumed to influence the costeffectiveness of the consumer purchase decisi on. For example, DOE assumes that a consumer will replace a failed ballast with an identical ba llast in the base case, or a new standardscompliant lamp-and-ballast system with comparable light output in the standards case. Section

8.4 discusses the ballast purchasing events in more detail. The LCC and PBP analyses spreadsheet reports results per purchasing event.

DOE is conducting the LCC and PBP anal yses on the baseline ballasts from the representative product classes identified in the ballast mark et and technology assessment (preliminary technical support document [TSD] chapter 3). The following list shows the representative product classes that DOE is evaluating in this analysis.

8-2

### • Two-Lamp Instant Start (IS) and Rapid-Star t (RS) Ballasts Operating 4-Foot Medium Bipin (MBP) and 2-Foot U-Shaped Lamps (C ommercial Sector Only) (F32T8 Baseline)

• Two-Lamp Programmed-Start (PS) Ballasts Op erating 4-Foot MBP and 2-Foot U-Shaped Lamps (Commercial Sector Only)

• Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps (Commercial Sector Only) (F34T12 Baseline)

• Four-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps (Commercial Sector Only)

• Four-Lamp PS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps (Commercial Sector Only)

• Two-Lamp RS and IS Ballasts Operating 8- Foot Recessed Double Contact (RDC) HighOutput (HO) Lamps (Industrial Sector Only) (F96T12HO/ES Baseline)

• Two-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps (Industrial Sector Only) (F96T8HO Baseline)

• Two-Lamp IS and RS Ballasts Operating 8-Foot Single-Pin Slimline (Slimline) Lamps (Commercial Sector Only) (F96T12ES Baseline)

• Two-Lamp IS and RS Ballasts Operating 8-Foot Slimline Lamps (Commercial Sector Only) (F96T8 Baseline)

• Two-Lamp PS Ballasts Operating 4-Foot T5 Mi niature Bipin (MiniBP) Standard Output (SO) Lamps (Commercial Sector Only)

• Two-Lamp PS Ballasts Operating 4-Foot T5 MiniBP HO Lamps (Industrial Sector Only)

• Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps (Residential Sector Only, Low Po wer Factor) (F34T12 Baseline)

• Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps (Residential Sector Only, Low Power Factor) (F32T8 Baseline)

• Four-Lamp RS and IS Ballasts Operating 8- Foot RDC HO Lamps (Cold Temperature and Sign Ballasts) (Commercial and Industrial Sectors Only)

The time period used for the LCC and PBP analyses in this rulemaking is the service life of the baseline ballast, assumed as 49,054 hours (commercial and industr ial sectors) and 11,385 hours (residential sector).

8.1.2 Overview of LCC and PBP Inputs

As mentioned previously, the LCC represen ts the total consumer expense over the analysis period, including purchase expenses, ope rating costs (including energy expenditures), and installation costs. DOE discounts future ope rating costs to the time of purchase and sums them over the analysis period. The PBP represen ts the number of years it takes customers to recover the purchase price of more energy-effic ient equipment through lower operating costs.

8-3

### The PBP is calculated as the change in first cost divided by the change in operating costs in the first year.

DOE categorizes inputs to the LCC and PBP analysis as follows: (1) inputs for establishing the purchase expense, otherwise known as the total installed cost; and (2) inputs for calculating the expenses incurred during operation of the lamp-and-ballast system otherwise known as the operating cost.

The primary inputs for establishing the LCC and PBP are:

• 

### End-User Product Price: The end-user product prices represent the consumer price before

tax and installation.

• 

### Sales Tax: DOE then applies sales tax to convert the end- user product price to a final product price including sales tax. Chapter 7 describes the sales ta x markup in detail.

• 

### Installation Cost: This input represents the co st to the commercial or industrial customers of installing the lamp-and-ballast systems. The installation cost represents all costs required to install the system but does not include the end-user product price. The

installation cost includes labor and overhead. Thus, the total in stalled cost equals the enduser product price including sales tax plus the installation cost.

• 

### Disposal Costs: After a ballast or fluorescent lamp reaches its end of life, some consumers pay to recycle those items. The dispos al costs represent the cost of recycling a ballast or fluorescent lamp, a nd are only applicable to those consumers in the commercial

and industrial sectors.

The primary inputs for calculating the operating cost include the following:

• 

### Annual Operating Hours: Th e annual operating hours are the hours that a lamp-andballast system is estimated to be in use during 1 year. The energy use characterization (chapter 6) details how DOE determines the system operatin g hours as a function of enduser sector, geographic region, and building type.

• 

### Power Rating: The power consumption is the site-energy usage rate associated with operating the lamp-and-ballast system. The energy use characterization (chapter 6) details how DOE determines the power ratings for th e lamp-and-ballast systems considered in the analyses.

• 

### Electricity Prices: DOE uses the average price per kilowatt-hour ( i.e. , $/kWh) paid by customers. DOE determines electricity prices using national average residential, commercial, and industrial electricity prices for the sample calculation. For the Monte Carlo distribution, DOE will use average residential, commercial, and industrial values for 13 regions and large States. DOE develops all electricity price inputs using 2009 EIA data.

• 

### Electricity Price Trends: DOE uses the EIA’s Annual Energy Outlook 2009 ( AEO2009 ) to forecast electricity prices. 1 

### For the results presented in this chapter, DOE uses the original (March) AEO2009 reference case.

8-4

### • 

### Lifetime: Lifetime is the total hours in opera tion after which the consumer retires the

ballast from service.

• 

### Discount Rate: The discount ra te is the rate at which DOE discounts future expenditures to establish their present value.

• 

### Analysis Period: Analysis period is the time span over which DOE calculates the LCC.

Figure 8.1.1 depicts the relationships between the installed cost and operating cost inputs

for the calculation of the LCC and PBP. In this figure, the rectangular box es indicate the inputs, the parallelograms indicate intermediate calcul ated values, and the diamond boxes indicate the analysis outputs (the LCC and PBP).

Legend

End-User

Product Price

Sales Tax Final

Product

Price Installation

Cost

Total

Installed

Cost

Electricity

Prices Annual Electricity

Usage

Cost PBP

Electricity

Price Trend

Discount Rate

Analysis

Period Operating

Cost Over Analysis

Period

Replacement

Cost LCC

Product

Lifetime Service

Life Energy Consumption

Total Replacement

Cost Calculated

Value LCC Input LCC Output

Disposal Cost

Power Rating

Operating

Hours



### Figure 8.1.1. Flow Diagram of Inputs for the Determination of LCC and PBP

8-5

### Table 8.1.1 summarizes the input values that DOE uses to calculate the LCC and PBP for ballasts. Each row summarizes the total installed cost inputs, operating cost and replacement cost, including the lifetime, discount rate, and elec tricity price trend. DOE characterizes all of the total cost inputs with single-point values, but will characterize severa l of the operating cost inputs with probability distributions that capture the input’s uncertainty and/or variability in the Monte Carlo analysis. Table 8.1.1 also lists the TSD chapter that details the inputs.

Table 8.1.1. Summary Information of Inputs for the Life-Cycle Cost and Payback Period
Analyses

Factor Weighted-Average Value TSD Reference Section Total Installed Cost Primary Inputs

End-User Product Price Varies with lamp-and-ballast system Chapters 5, 7

Sales Tax Varies by census region Chapter 7

Installation Cost Varies by equipment installed and sector Chapter 8 Operating Cost Primary Inputs

Annual Operating Hours Vary by lamp-and-ballast system type, sector, and building type Chapter 6

Power Rating Varies with lamp-and-ballast type Chapter 6 Electricity Prices Vary by sect or and census region Chapter 8 Electricity Price Trends Vary with price forecast scenario Chapter 8

Discount Rate Varies with sector Chapter 8 Analysis Period Varies with sector Chapter 8 Replacement Cost Primary Inputs

Total Installed Cost Varies with lamp-and-ballast system, census region, equipment installed and sector Chapters 7, 8

Ballast Lifetime Varies with lamp-and-ballast system Chapters 5, 8

Disposal Cost Varies by lamp-and ballast system type and

sector Chapter 8

Discount Rate Varies with sector Chapter 8 Analysis Period Varies with sector Chapter 8



### Sections 8.2 and 8.3 discuss the inputs depicted in this table of installed costs and operating costs.

8.2 LIFE-CYCLE COST INPUTS

8.2.1 Definition

LCC is the total customer cost over the life of a product, including total installed costs, operating costs, replacement costs, and residual va lue. Future operating costs and replacement costs are discounted to the analysis start year (2014) and summed over the analysis period. The LCC is defined by the following equation:

N 

### ⎛ OC

t 

### + RC

t 

### DC ⎞ LCC = IC + 

# ∑ ⎜ ⎜

t 

### +

t 

### ⎟ ⎟

t = 1 

### (1 + r ) (1 + r ) ⎝ ⎠ Eq. 8.1

Where:

LCC = life-cycle cost ($),

8-6

### IC = total installed cost ($),

N = analysis period, ∑ = sum over the analysis period, from year 1 to year N

, OC = operating cost ($),

RC = lamp replacement cost ($),

r

= discount rate,

t = year for which operating cost, repl acement cost, or disposal cost is determined, and

DC = disposal cost of the ballast or lamp.

DOE expresses all the costs in its LCC and PBP analyses in 2008$.

8.2.2 Total Installed Cost Inputs

The total installed cost to the customer is defined by the following equation:

IC = FPP + INST 

### Eq. 8.2

Where:

FPP = final product price ( i.e. , customer price for the product only, including sales tax; $), and

INST = installation cost or the cust omer price to install products ( i.e. , the cost for labor and materials; $).

In the markups analysis (chapter 7), DOE develops end-user pr oduct prices and sales taxes to derive final product prices. DOE then applies in stallation costs where necessary to derive the total installed costs for use in the LCC. The following shows inputs to determine total

installed costs.

• end-user product price ($)

• sales tax ($)

• installation cost ($)

The end-user product price represents the average purchase price a consumer pays before sales tax for lamp-and-ballast designs. The sales tax represents State and local sales taxes applied to the end-user product price. It is a multiplica tive factor that increases the end-user product price. The installation cost represents all costs required to install the lamp-and-ballast system but does not include the final product price. The inst allation cost includes labor and overhead. Thus, the total installed cost equals th e final product price plus the inst allation cost. DOE calculates the total installed cost for the ballasts analyzed based on the following equation:

8-7

### IC = F P

P + I NS T 

### Eq. 8.3

= PRICE × MU TAX 

### + INST



### Where:

IC = total installed cost,

FPP = final product price,

INST = installation cost,

PRICE = end-user product price, and

MU TAX 

### = sales tax mark up.

Chapter 7 provides detail on the end-user product price and sales tax. Discussion on the

installation costs follows.

8.2.2.1 Installation Costs

On September 19, 2000, DOE issued a final rule establishing energy conservation standards for ballasts (hereafter “the 2000 Ba llast Rule”). 65 FR 56740; 10 CFR 430.23(m)(4). To account for relamping that occurs during th e analysis period, DOE uses estimates of the prevalence of group versus spot relamping from the 2000 Ballast Rule. DOE then weighs the spot and group relamping times by the percent oc currence of spot versus group relamping to derive weighted averaged relamping times. A ccording to the 2000 Ballast Rule, group relamping occurs, on average, 25 percent of the time for 4-foot MBP systems, 37 percent for 8-foot slimline systems, and 31 percent for 8-foot recessed double contact (RDC) high output (HO) systems. 2


### These percentages are used to calculate an average time to change fluorescent lamps in conjunction with ballast purchase events. The 2000 Ballast Rule did not address relamping for 8­ foot RDC HO cold temperature/sign applications; consequently, DOE assumes that labor times and costs are the same as for standard 8-foot RDC HO systems.

Table 8.2.1 lists average labor times to insta ll a fluorescent lamp and ballast. For new construction and renovation purchase events, DOE adds 2.5 minutes to the labor times in the

table to account for the installation of a luminai re disconnect. This is because the 2005 National Electric Code requires a means for disconnecting luminaires before they are serviced for lamp or ballast replacements. 3

8-8

### Table 8.2.1. Labor Times for Fluorescent Lamp-and-Ballast Systems (Commercial and
Industrial) *

Lamp-and-Ballast System Type Time

minutes Relamp Install Lamps and

Ballasts ** Spot Group Average Two-Lamp 4-foot MBP and 2-foot U-Shaped 27.0 14.0 23.8 30.0 Four-Lamp 4-foot MBP and 2-foot U-Shaped 28.0 15.0 24.8 40.0 Two-Lamp 8-foot Slimline 20.5 10.5 16.8 55.0 Two-Lamp 8-foot RDC HO 26.5 13.5 22.5 60.0 Two-Lamp 4-foot MiniBP 27.0 14.0 23.8 30.0 Four-Lamp 8-foot RDC HO (Sign Ballasts) 26.5 13.5 22.5 60.0

* Labor times are obtained from the 2000 Ballast Rule.

** For new construction and renovation ballast purchase events, labor times are increased by 2.5 minutes to

allow for the installation of a luminaire disconnect.



### For lamp-and-ballast system installations, DOE derives labor rates for electricians and helpers from RS Means . Labor rates are the sum of the wage rate, employer-paid fringe benefits ( i.e. , vacation pay, employer-paid health, and welf are costs), and any appropriate training and industry advancement funds costs. According to RS Means , an electrician’s average hourly rate with overhead and profit is typically $69.79 (in 20 08$), and a helper’s average hourly rate is $45.28 (in 2008$). DOE assumes that 50 percent of the electrician labor rate plus 50 percent of the helper labor rate (for a total of $55.41) comprise the lamp-and-ballast syst em installation rate.

For lamp replacements in the commercial sector, DOE assumes that the task is performed by a general maintenance worker. The labor rate of $16.55 (adjusted to 2008$ from $15.01 in 2005) was obtained from the U.S. Bureau of Labor Statistics for a General Maintenance

Worker. 4 

### Using these labor rates and the labor times listed in Table 8.2.1, DOE derives the average cost to install a lamp and the average cost to install a lamp and ballast, as shown in Table

8.2.2.

Table 8.2.2. Relamping and Lamp-and-Ballast Labor Costs for Fluorescent Lamp-andBallast Systems (Commercial and Industrial) *

Lamp-and-Ballast System Type Labor Cost
$
Relamping Installation
Two-Lamp 4-Foot MBP and 2-Foot U-Shaped 6.55 31.17 Four-Lamp 4-Foot MBP and 2-Foot U-Shaped 6.83 40.76 Two-Lamp 8-Foot Slimline 4.63 55.14 Two-Lamp 8-Foot RDC HO 6.20 59.93 Two-Lamp 4-Foot MiniBP 6.55 31.17 Four-Lamp 8-Foot RDC HO (Sign Ballasts) 6.20 59.93

* For new construction and renovation ballast purchase events, labor times are increased by

2.5 minutes to allow for the installation of a luminaire disconnect.



### 8.2.3 Operating Cost Inputs

The operating cost represents the costs incu rred in the operation of the lamp-and-ballast system. Below are the inputs for operating costs:

8-9

### • annual operating hours

• power rating (W)

• electricity prices ($/kWh)

• electricity price trends

• discount rate (%)

• analysis period (yrs)

The analysis period, discount rate, and effe ctive date of the amended standard are required for determining the operatin g cost and for establishing the operating cost present value. The electricity consumption for the baseline a nd other candidate standard levels (CSLs) examined enable comparison of standards’ operating costs.

The annual operating hours are the estimated hours that a lamp-and-ballast system is in use during 1 year. Power rating refers to the rate of site energy usage associated with operating the lamp-and-ballast system. Both the annual operating hours and power rating are used to calculate the total annual energy c onsumption. Electricity prices used in the analysis are the price per kilowatt-hour in cents or dollars ( e.g. , $/kWh) paid by each customer for electricity. DOE uses electricity price trends to forecast electricity prices for future year analysis. These trends with the electricity price and annual energy consumption are used to calculate the energy cost in each year. DOE defines energy cost by the following equation:

OC = E × EP × EPT

cons 

### Eq. 8.4

= 

# ( PWR × OH 

# ) × EP × EPT

Where:

OC = operating costs,

E

cons 

### = annual energy consumed,

EP = electricity price,

EPT = electricity price trend factor relative to 2007,

PWR = power rating (rate of energy use, measured in watts), and

OH = annual operating hours.

The remainder of this section provides in formation about each of the above input variables that DOE used to calculate the operating costs.

8.2.3.1 Operating Hours

The energy use characterization (chapter 6) details how DOE de termines the annual energy consumption for baseline and standard -compliant products. An important input to determining the energy consumption is the total hours per year that the product is in operation. The operating hours are also used to calculate the ba llast service life, which is ultimately used in calculating the total replacement cost.

8-10

### As described in chapter 6, DOE establishe s operating hour distributions for fluorescent lamp-and-ballast systems. In conjunction with data from LMC, DOE uses data from EIA’s CBECS 2003, RECS 2001, and the MECS 2002. These EIA studies provide information on the distribution of buildings within the United States by building type and census division. DOE associates the LMC’s operating hour data by build ing type with the EIA’s data by building type and census division to derive operating hours by census division and large States. This allowed DOE to correlate its electricity price distribution and sales tax distribution (chapter 7) with its operating hour distribution by census division and large State in the LCC spreadsheet. Table 8.2.3 presents the mean operating hours for lamp-and-ballast systems for each sector.

Table 8.2.3. Average Operating Hours by Sector

Sector Average Annual Operating hrs/yr

Residential 789

Commercial 3,435

Industrial 4,795



### In this rulemaking, DOE evaluates two- a nd four-lamp PS ballasts operating 4-foot MBP and 2-foot U-shaped lamps in the commercial sector, and assumes these lamp-and-ballast systems are operated on occupancy sensors. Occupanc y sensors detect the presence or absence of people within their coverage area and turn lights on and off accordingly, thereby reducing operating time and energy consum ption. Based on a range of estimated energy savings from occupancy sensors compiled in E Source, 5 

### DOE assumes energy savings of 30 percent for operating lamp-and-ballast systems on occupancy sensors in the commercial sector. To account for these energy savings, DOE reduces averag e operating hours for affected lamp-and-ballast systems by 30 percent. Table 8.2.4 presents th e adjusted mean operating hours for lamp-andballast systems operating on occupancy sensors in the commercial sector.

Table 8.2.4. Average Operating Hours for Two- and Four-Lamp PS Ballasts Operating 4

- Foot MBP and 2-Foot U-Shaped Lamps in the Commercial Sector

Sector Lamp-and Ballast System Type Annual Operation hrs/yr

Commercial Two- and Four-Lamp PS Ballast Operating 4-Foot T8 MBP Lamps 2,405



### 8.2.3.2 Power Rating

As described in the energy use and end load characterization (chapter 6), DOE uses the power rating (in watts) with the annual operating hours (i n hours) to calculate the annual energy usage (in kilowatt-hours) of the lamp-a nd-ballast designs DOE considers.

8.2.3.3 Electricity Prices

DOE estimates electricity prices for residential, commercial, and industrial consumers in each of the 13 regions and large States by using EIA Form 861 data. 6 

### Table 8.2.5 lists the 13 geographic regions.

8-11

### Table 8.2.5. Electricity Prices by Census Division, 2008

Census Division Electricity Prices *

2008$/kWh

Residential Commercial Industrial New England 0.150 0.103 0.085

Middle Atlantic 0.124 0.096 0.066

East North Central 0.100 0.076 0.050

West North Central 0.086 0.071 0.053

South Atlantic 0.098 0.075 0.053

East South Central 0.087 0.084 0.052

West South Central 0.093 0.083 0.062

Mountain 0.097 0.080 0.056

Pacific 0.091 0.083 0.060

New York State 0.162 0.104 0.066

California 0.149 0.123 0.089

Texas 0.128 0.102 0.082

Florida 0.117 0.101 0.081 U.S. Weighted Average 0.110 0.090 0.061

* DOE converts dollars to 2008$ by multiplying costs in 2007$ by the ratio of 2008 CPI (215.30) to 2007 CPI (207.34). DOE converts the price in 2006 to the price in 2008 by multiplying the 200 price by the ratio of the average AEO electricity price in 2008 to the average AEO electricity price in 2006.



### The EIA Form 861 data are published annually and include annual electricity sales in kilowatt-hours; revenues from electricity sales; and number of consumers for the residential, commercial, and industrial sectors for every utility serving final consumers. The calculation of an average electricity prices proceeds in two steps:

1. For each utility, estimate an average reside ntial, commercial, or industrial price by dividing the residential, comme rcial, or industrial revenues by residentia l, commercial, or

industrial sales.

2. Calculate a regional average price, weighting each utility with customers in a region by the number of residential, co mmercial, or industrial consum ers served in that region.

The calculation uses the most recent availabl e EIA data at the time the analysis was conducted, from 2007. Table 8.2.5 shows the results for each geographic region. Because DOE conducted the LCC and PBP analyses in 2008$, it need ed to convert all electricity prices into 2008$. To perform the necessary monetary conversion, DOE uses the consumer price index (CPI) to convert the electricity prices from 2007$ to 2008$. As described in the following section on electricity price trends, DOE normalizes energy prices to 2008. Therefore, to forecast energy prices for any given future year, DOE estab lishes energy prices in 2008$. In Table 8.2.5, DOE uses data from the original March version of the AEO2009 to estimate the electricity prices in
2008$. 1 

### DOE multiplies the electricity price in 2007 by the ratio of the AEO2009- estimated residential, commercia l, or industrial prices for 2008 and 2007.

8.2.3.4 Electricity Price Trend

The electricity price trend pr ojects the future cost of electricity to 2030. DOE calculates the LCC and PBP using three separate projections from AEO2009 : reference case, low economic

8-12

### growth, and high economic growth. 7 

### These three cases reflect the uncertainty of economic growth in the forecast period. The high and low growth cases show the projected effects of alternative growth assumptions on energy markets. DOE normalizes these three AEO2009 scenarios to the 2008 electricity price, and then uses that electricity pri ce factor to scale the 2008 electricity prices. Figure 8.2.1 through Figure 8.2.3 show the residential, commercial, and industrial electricity price trends , respectively, based on the three AEO2009 projections. The LCC results presented in this chapter are based on the AEO2009 reference case.

Figure 8.2.1. Residential Sector Electricity Price Trend

Figure 8.2.2. Commercial Sector Electricity Price Trend

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### Figure 8.2.3. Industrial Sector Electricity Price Trend

In the LCC spreadsheet, these electricity price trends are used to project electricity prices into the future, which are then multiplied by the annual energy usage. The resulting operating costs are presented in both the LCC spreadsheets and the LCC results tables in this chapter.

8.2.4 Lifetime

DOE defines lifetime as the age in hours in ope ration when a ballast or lamp is retired from service. For ballasts in the commercial and industrial sectors, DOE uses the average ballast

lifetime used in the 2000 Balla st Rule (49,054 hrs). Combinin g DOE’s estimate of 49,054 hours and the average operating hours for fluorescent la mps in the commercial and industrial sectors (Table 8.2.3) yields average ballast lifetimes of 14.2 years and 10.2 years, respectively. The commercial sector lifetime is consistent with a study on the “measure life” of ballasts ( i.e. , the true service life of a ballast in the field), which found that the average ballast lifetime after a retrofit in the commercial sector is 13 years, and the average ballast lifetime after new construction is 15 years. 8 

### Manufacturer interviews indicate that ballasts in the industrial sector are typically operated in higher temperature environments and are commonly replaced on an approximate 10-year renovation cycle, which corroborates the shorter estimated lifetime. DOE found in a separate measure life report that the aver age fixture and ballast in the residential sector lasts for 15 years. 9 

### Therefore, DOE established 15 years as the average ballast lifetime in the residential sector. Assuming the average annual operating lifetime of a fluorescent lamp in the

residential sector of 789 hours as discussed in section 8.2.3.1, the ballast lifetime is therefore 11,835 hours in the residential sector.

As with the calculation of relamping costs, DOE averages the group versus spot relamping impact on lamp lifetime by their percent occurrence. DOE assumes a lamp subject to group relamping practices operates for 75 percent of its rate d life. DOE obtained this estimate from the 2000 Ballast Rule. DOE then applies this life impact factor to the rated lifetimes from the manufacturing literature for the lamps in the lamp-and-ballast systems it is analyzing. For 4­ foot MBP lamps and 4-foot MiniBP lamps, the average lifetime DOE uses in the analysis is 94 percent of the rated lifetime. For 8-foot slimline lamps, the average lifetime is 91 percent of the rated lifetime. For 8-foot RDC HO lamps, the average lifetime is 92 percent of the rated lifetime.

8-14

### As discussed in the technology assessmen t (chapter 3), ballast technology options ( e.g. , starting method) often affect the lifetime of the lamp. Fo r this reason, the baseline and standard level designs for the LCC and PBP analyses have a range of lamp lifetimes.

8.2.5 Replacement Cost

As stated previously, the lifetime is the age (t otal hours in operation) at which a ballast or lamp is retired from service. The lifetime paired with the operating hours yields the service life of the ballast or lamp in years. Because lamp lifetimes are typically shorter than ballast lifetimes, DOE must address lamp replacements within the analysis period for the lamp-and-ballast system designs considered. Replacement costs include the labor and materials costs associated with replacing a lamp at the end of its lifetime. By using the service life and replacement cost, one can calculate the total replacement cost each year.

Each year in which a lamp reaches the end of its life, a new lamp is purchased and installed at the beginning of that year, and the fi rst cost and installation cost are discounted back to the base year of the analysis period. During years in which replacement is necessary, DOE based the replacement costs on the total installed co st inputs, as seen in the following equation:

RC = FPP L 

### + INST
L 

### Eq. 8.5

= PRICE × MU + INST L TAX L



### Where:

RC = replacement cost, expressed in dollars,

FPP L 

### = final product price (price for the product only) expressed in dollars,

INST L 

### = installation cost,

PRICE L 

### = end-user product price ex pressed in dollars, and

MU TAX 

### = sales tax.

For the years when no replacement is necessary, the replacement costs are set to zero. The replacement costs only include the end-user product price of the lamp and the installation cost of the lamp, rather than prices or costs associated with the entire lamp-and-ballast system. For the LCC and PBP analyses, the analysis period corresponds with the ballast lifetime; for this reason, ballast replacement is not considered and only lamp price and labor costs are included in

the calculation of total installed costs.

8.2.6 Disposal Cost

When a ballast or fluorescent lamp fails, some consumers choose to recycle these system components. The cost of recycling the ballast or lamp is its disposal cost. DOE performed research on recycling costs for ballasts and fluorescent lamps and found that, on average, disposing of a ballast costs about $3.50 and dis posing of lamps costs about 10 cents per linear

foot. 10 

### Ballast recycling rate data are not availabl e, so DOE conservatively assumes 5 percent of

ballasts used in the commercial and industrial sectors are recycled, and assumes no ballasts are recycled in the residential sector. A report rele ased by the Association of Lighting and Mercury Recyclers in 2004 noted that, nationwide, approxima tely 30 percent of lamps used by businesses

8-15

### and 2 percent of lamps in the re sidential sector are recycled. 11 

### Thus, DOE applies a cost of 10 cents per linear foot in the commercial and i ndustrial sectors every time a lamp is replaced during the LCC analysis period. In the Monte Carlo analysis, DOE will assume that commercial and industrial consumers pay recycling costs for approximately 5 percent of ballast failures and 30 percent of lamp failures. DOE does not expect the 2 percent residential lamp recycling rate to impact the residential sector LCC substantially, however, and thus does not apply the recycling

costs to this sector.

8.2.7 Analysis Period

The analysis period is the time span over which the LCC is calculated. DOE bases the analysis period on the baseline ballast life in a certain sector divided by the annual operating

hours of that ballast. If the user chooses to run the LCC using weighted average values ( i.e. , in “sample calculation” mode), then the analysis pe riod is based on the baseli ne ballast life divided by the average annual operating hours for that ballast in a chosen sector. For example, the

baseline ballast life for commercia l and industrial sectors is 49,054 hour s. If the user chooses to analyze this ballast in the commercial sector, then the analysis period is the ballast lifetime of 49,054 hours divided by the average annual opera ting hours of this produc t in the commercial sector, 3,435 hours per year, or 14.3 years. If the user chooses to run the LCC using the Monte Carlo simulation ( i.e. , in “Crystal Ball mode”), the analysis period is based on the baseline ballast life divided by Crystal Ball’s chosen annual operating hours. For example, the user may choose to evaluate a product in the commercial sector using Crysta l Ball. If Crystal Ball selects a building used for religious worship, the analysis period for the ballast for that selection will be

based on a ballast lifetime of 49,054 hours divided by the annual operating hours in a building used for religious worship, 1,609 hours per year (30.5 years).

8.2.8 Discount Rate

The discount rate is the rate at which DOE di scounts future expenditures to establish their present values. DOE derives the discount rates for this rulemaking separate ly for residential and

commercial/industrial consumers. Fo r residential consumers, DOE estimates the discount rate by looking across all possible debt or asset classes that might be us ed to purchase ballasts. For the

commercial and industria l consumers, DOE estimates the cost of capital fo r commercial and industrial companies by examining both debt and equity capital, and develops an appropriately weighted average of the cost to the company of equity and debt financing.

8.2.8.1 Residential Discount Rate

DOE’s approach involves identifying all possible debt or asset classes that might be used to purchase replacement equipment, including household assets that might be affected indirectly ( e.g. , household assets sold to pay off a loan or cr edit card debt that might have been used to finance the actual equipment purchase). DOE does not include debt from primary mortgages and equity of assets considered non- liquid (such as retirement account s), since these would likely not be used to finance lighting equipment purchases. DOE estimates the average shares of the various debt and equity classes in the average U.S. household equity and debt portfolios using

the Federal Reserve’s Survey of Consumer Finances ( SCF ) data for 1989, 1992, 1995, 1998, 2001, and 2004. 12 

### Table 8.2.6 shows the average shares of each considered class. DOE uses the

8-16

### mean share of each class across the six survey years (15 years) as the basis for estimating household financing of lighting equipment.

Table 8.2.6. Average Percentage Shares of Household Debt and Equity Types

Type SCF

1989 1992 1995 1998 2001 2004 Mean

% Home Equity Loans 4.3 4.5 2.7 2.8 2.8 4.4 3.6

Credit Cards 1.6 2.1 2.6 2.2 1.7 2.0 2.0

Other Installment Loans 2.8 1.7 1.4 1.7 1.1 1.3 1.7

Other Residential Loans 4.4 6.9 5.2 4.3 3.1 5.8 4.9

Other Line of Credit 1.1 0.6 0.4 0.2 0.3 0.5 0.5 Checking Accounts 5.8 4.7 4.9 3.9 3.6 4.2 4.5 Savings and Money Market 19.2 18.8 14.0 12.8 14.2 15.1 15.7 Certificate of Deposit (CD) 14.5 11.7 9.4 7.0 5.4 5.9 9.0 Savings Bond 2.2 1.7 2.2 1.1 1.2 0.9 1.5

Bonds 13.8 12.3 10.5 7.0 7.9 8.4 10.0

Stocks 22.4 24.0 25.9 36.9 37.5 28.0 29.1

Mutual Funds 8.0 11.1 20.9 20.1 21.3 23.4 17.5

Total * 100.1 100.1 100.1 100.0 100.1 99.9 100.0

* Total may not equal 100 percent due to rounding.



### DOE estimates interest or return rates associated with each ty pe of equity and debt. The data source for the interest rates for loans, credit cards, and lines of credit is the Federal Reserve

Board’s SCF in 1989, 1992, 1995, 1998, 2001, and 2004. The top half of Table 8.2.7 shows the average nominal interest rates in each year and the inflation rates used to calculate real rates. For home equity loans, DOE calculates effective interest rates in a similar manner as for mortgage rates, since interest on such loans is tax de ductible. The bottom half of the table shows the average effective real interest rates in each year and the mean rate across all the years. Since the interest rates for each debt carried by households in these years were established over 15 years, DOE believes they are representative of rate s that may be in effect in 2014.

Table 8.2.7. Average Nominal and Real Interest Rates for Household Debt Classes

Type SCF

1989 1992 1995 1998 2001 2004 Mean

%

8-17Nominal Interest Rates (%) Home Equity Loans 11.5 9.6 9.6 9.8 8.7 5.7 9.2

Credit Cards *

-­ -­ 14.2 14.5 14.2 11.7 13.6

Other Installment Loans 9.0 7.8 9.3 7.8 8.7 7.4 8.3

Other Residential Loans 8.8 7.6 7.7 7.7 7.5 6.0 7.5

Other Line of Credit 14.8 12.7 12.4 11.9 14.7 8.8 12.5

Inflation Rate 4.82 3.01 2.83 1.56 2.85 2.66

-­ Real Interest Rates (%) Home Equity Loans 3.8 4.3 4.4 5.8 3.8 1.9 4.0

Credit Cards *

-­ -­ 11.0 12.7 11.1 9.1 11.0

Other Installment Loans 4.9 5.8 7.0 6.6 6.1 5.4 6.0

Other Residential Loans 4.0 4.7 4.8 6.0 4.6 3.3 4.6

Other Line of Credit 9.6 9.4 9.3 10.2 7.3 6.0 8.7

* No interest rate data available for credit cards in 1989 or 1992.



### To account for variation among new households , DOE samples a rate for each household

from a distribution of rates for each of the above debt classes. DOE develops a probability

distribution of interest rates fo r each debt class based on the SCF data. Appendix 8C presents the probability distribution of interest rates for each debt class that DOE used in the LCC and PBP analyses.

Similar rate data are not available from the SCF for the asset classes, so DOE derives

data for these classes from national historical data. The interest rates associated with certificates of deposit (CDs), 13 

### savings bonds, 14 

### and bonds (AAA corporate bonds) 15 

### are from Federal

Reserve Board time-series data 1977–2005. DOE assumes rates on check ing accounts to be zero. Rates on savings and money market accounts are from Cost of Savings Index data covering

1984–2005. 16 

### The rates for stocks are the annual retu rns on the Standard and Poor’s (S&P) 500

1977–2005. 17 

### The mutual fund rates are a weighted aver age of the stock rates (two-thirds weight) and the bond rates (one-third weight) in each year from 1977 to 2005. DOE adjusts the nominal rates to real rates using the annua l inflation rate in each year. Average nominal and real interest

rates for the classes of assets are shown in Tabl e 8.2.8. Since the interest and return rates for each asset type cover a range of time, DOE believes they are representative of rates that may be in

effect in 2014.

Table 8.2.8. Average Nominal and Real Interest Rates for Household Equity Types

Type Average Rate

%

Nominal Real Checking Accounts

-­ 0.0 Savings and Money Market 5.5 2.3

CDs 6.9 2.4 Savings Bonds 8.0 3.5

Bonds 8.8 4.2

Stocks 13.3 8.8

Mutual Funds 11.6 7.0



### To account for variation among new households , DOE samples a rate for each household

from a distribution of rates for each of the above asset types. DOE deve lops a normal probability distribution of interest rates for each asset type by using the mean value and standard deviation

8-18

### from the distribution. Appendix 8C presents the probability distribution of interest rates for each asset type that DOE used in the LCC and PBP analysis.

Table 8.2.9 summarizes the mean real effective rates of each type of equity or debt. DOE determines the average share of each debt and asset using SCF data for 1989, 1992, 1995, 1998, 2001, and 2004. Each year of SCF data provides the debt and asset shares for U.S. households. DOE averages the debt and asset shares over the 6 years of survey data to arrive at the shares shown below. The average rate across all types of household debt and equity, weighted by the shares of each class, is 5.6 percent.

Table 8.2.9. Shares and Interest or Return Rates Used for Household Debt and Equity
Types

Type Average Share of Household Debt Plus Equity

% * Mean Effective Real Rate

% **

Home Equity Loans 3.6 4.0

Credit Cards 2.0 11.0

Other Installment Loans 1.7 6.0

Other Residential Loans 4.9 4.6

Other Line of Credit 0.5 8.7 Checking Accounts 4.5 0.0 Savings and Money Market Accounts 15.7 2.3

CDs 9.0 2.4 Savings Bonds 1.5 3.5

Bonds 10.0 4.2

Stocks 29.1 8.8

Mutual Funds 17.5 7.0 Total/Weighted-Average Discount Rate 100.0 5.6

* Not including primary mortgage or retirement accounts.

** Adjusted for inflation and, for home equity loans, loan interest tax deduction.



### 8.2.8.2 Commercial Discount Rate

Most companies use both debt and equity capital to fund investments; for most companies, therefore, the cost of capital is the weighted average of the cost to the firm of equity

and debt financing. 18



### DOE estimates the cost of equity financing using the Capital Asset Pricing Model (CAPM). Among the most widely used models to estimate the cost of equity financing, the

CAPM assumes that the cost of e quity is proportional to the amount of systematic risk associated with a firm. For example, the cost of equity financing tends to be high when a firm faces a large degree of systematic risk, and the cost tends to be low when the firm faces a small degree of systematic risk.

The degree of systematic risk facing a firm and the subsequent cost of equity financing are determined by several variables, including the risk coefficient of a firm (beta, 

## β ), the expected return on risk-free assets (R f 

### ), and the additional return expected on assets facing average market risk (known as the equity risk premium, or ERP). The beta indicates the degree of risk associated with a given firm, relative to the level of risk (or price variability) in the

8-19

### overall stock market. Beta s usually vary between 0.5 and 2.0. A fi rm with a beta of 0.5 faces half the risk of other stocks in the market; a firm with a beta of 2.0 faces twice the overall stock

market risk.

Following this approach, the cost of equity financing for a particular company is by the equation:

k

e 

### = R f 

### + 

# ( β × ERP 

# ) Eq. 8.6

Where:

k

e 

### = the cost of equity for a company, expressed in dollars,

R

f 

### = the expected return of the risk free asset, expressed in dollars,



## Β = the risk coefficient, and

ERP = the expected equity risk premium, expressed in dollars.

The cost of debt financing (k d 

### ) is the yield or interest rate paid on money borrowed by a company (raised, for example, by selling bonds). As defined here, the cost of debt includes compensation for default risk a nd excludes deductions for taxes.

DOE estimates the cost of debt for companies by adding a risk adjustment factor to the current yield on long-term corporate bonds (the risk -free rate). This procedure is used to estimate current and future company costs to obtain debt financing. The adjustment factor is based on indicators of company risk, such as credit rating or variability of stock returns.

The discount rate of companies is the weighted average cost of debt and equity financing, less expected inflation. DOE estimates th e discount rate using the equation:

k = k × w + k × w e e d d 

### Eq. 8.7

Where:

k

= the (nominal) cost of capital,

k

e 

### and k d 

### = the expected rates of return on e quity and debt, respectively, and

w e 

### and w d 

### = the proportion of equity and debt financing, respectively.

The real discount rate deducts expected inflation from the nominal rate.

The expected return on risk-free assets, or the risk-free rate, is defined by the current yield on long-term (20-year) government bonds , as suggested by Ibbotson’s Associates 19 

### and

Damodaran. 20 

### The ERP represents the difference between the expected (average) stock market

return and the risk-free rate. As Table 8.2.10 show s, DOE uses an ERP estimate of 5.1 percent, which it took from the Damodaran Online site (a private website associated with New York University’s Stern School of Business, which aggregates information on corporate finance, investment, a nd valuation). 21

8-20

### Table 8.2.10. Variables Used to Esti mate Company Discount Rates

Variable Symbol Average Value

% Source

Risk-Free Asset Return R f 7.3 Damodaran Online Equity Risk Premium ERP 5.6 Damodaran Online Expected Inflation R 3.1 U.S. Bureau of Economic Analysis Cost of Debt (After Tax) k d 6.9 Damodaran Online Percent Debt Financing w d 25.6 Damodaran Online Systematic Firm Risk B 1.02 Damodaran Online



### DOE calculates an expected inflation of 3.1 percent from the average of five quarters’ change in gross domestic product prices. 22 

### DOE obtained the cost of debt, percent debt financing, and systematic firm risk from the Damodaran Online website. Table 8.2.10 shows average values across all private companies. Howeve r, the cost of debt, percent debt financing, and systematic firm risk vary by sector.

In the commercial building sector, ballasts are purchased and owned by commercial building property owners, commercial companies, industrial companies and the government. DOE uses a sample of 4,207 companies drawn from these owner categories to represent ballast purchasers. It took the sample from the list of companies included in the Value Line investment

survey 23 

### and listed on the Damodaran Online website. DOE obtained the cost of debt, the firm beta, the percent of debt and equity financing, the risk-free return, and the equity risk premium

from Damodaran Online.

DOE estimates the cost of debt financing for these companies from the long-term government bond rate and the standard deviation of the stock price. For government-office-type owners, the discount rate represents an average of the Federal rate and the State and local bond rate. DOE drew the Federal rate directly fro m the U.S. Office of Management and Budget discount rate for investments in gove rnment building energy efficiency. 24 

### DOE estimates the

State and local discount rate from the interest rate on State and local bonds between 1977 and

2001. 25 

### DOE uses this information to estimate the weighted-average cost of capital for the sample of companies included in the commercial property owne r, commercial, and industrial company database.

The cost of capital may be viewed as the di scount rate that should be used to reduce the future value of typical company project cash flows. It is a nominal discount rate, since anticipated future inflation is included in both stock and bond expected returns. Deducting expected inflation from the cost of capital provides estimates of the real discount rate by ownership category (Table 8.2.11). The mean real discount rate for these companies varies between 2.3 percent (government offices) and 8.3 percent (comme rcial companies).

Table 8.2.11. Real Discount Rates by Ballast Ownership Category

Ownership Category Mean Real

Discount Rate

% Standard

Deviation

% Number of

Observations

8-21Industrial Companies 7.6 2.3 1942 Commercial Companies 8.3 2.4 2339 Commercial Property Owners 6.3 2.0 7

Government Offices 2.3 1.1 N/A



### DOE’s approach for estimating the cost of cap ital provides a measure of the discount rate spread as well as the average discount rate. DOE infers the discount rate spread by ownership category from the standard deviation, which rang es between 1.1 and 2.4 percent (Table 8.2.11).

Different combinations of co mmercial property owners and commercial, industrial, and government buyers purchase the ballast types c onsidered in the LCC analysis. Accordingly, DOE

constructs the discount rates associated with each building sector from different combinations of commercial property owner, commercial, industrial, and government rates.

To estimate the share of each ownership catego ry in total commercial sector purchases of ballasts, DOE uses the share of each category in total commercial building square footage with lighting provided by EIA’s 2003 CBECS. 26 

### Table 8.2.12 presents the estimated shares of commercial ballast purchases by ownership category of commercial building space.

Table 8.2.12. Estimated Share of Ballast Purch ases by Ownership Category in the

Commercial Sector *

Ownership Category Percent Property Owners and Managers 22.3

Industrial Firms 10.1

Commercial Firms 54.8

Government 12.8

* Source: 2003 CBECS. The share of total square footage occupied by property owners is actually 44.6 percent. However, in some of these buildings, the tenants purchase ballasts. DOE assumes that this is the case for half of the square footage occupied by property owners. DOE allocates this quantity among the other categories in proportion to their shares of total square footage.



### Table 8.2.13 presents the distribution of ba llast ownership for the commercial and industrial lighting sectors.

Table 8.2.13. Ballast Ownership by Sector *

Sector Property Owners

% Industrial Companies

% Commercial Companies

% Government

%

Industrial 0.0 100.0 0.0 0.0

Commercial 22.3 10.1 54.8 12.8

* Sources: Commercial, CBECS; Industrial, DOE estimate.



### DOE estimates discount rate distributions for th e different sectors as a weighted average

of the distributions for the di fferent ownership types. The resulting weighted average discount rates are 7.6 percent for the industrial sector and 7.0 percent for the commercial sector. Table 8.2.14 summarizes the weighted average discount rates in all three sectors.

Table 8.2.14. Average Discount Rate by Sector

Sector Discount Rate

8-22%

Industrial 7.6

Commercial 7.0

Residential 5.6



### 8.2.9 Effective Date of Standard

The effective date is the date when an amended standard becomes operative ( i.e. , the date by which ballast manufacturers must manufacture products th at comply with the amended standard). DOE’s publication of a final rule in this standard s rulemaking is scheduled for completion in June 2011. For ballast designs not addressed in previous rulemakings ( i.e. , ballasts operating T8 MBP and T5 MiniBP lamps, and low power factor ballasts for residential use), the effective date of any new energy conservation stan dards for these ballasts must be at least 3 years after the final rule is published, (42 U.S.C. 6295(g)(4)(C)), which will be June 2014. For ballast designs subject to existing standards ( i.e. , certain T12 ballasts), the effective date of any amended energy conservation standards for these ballasts must be at least 5 years after the effective date of the previous amendment (42 U.S.C. 6295(g)(4)(C)(i)). Table 8.2.15 presents the anticipated effective dates of standards for representative ballast designs addressed in the LCC and PBP analyses. The new standards will also affect additional ballast designs not directly addressed in the LCC and PBP analyses ( e.g. , one- and three-lamp vers ions of ballasts operating 4-foot MBP lamps).

Table 8.2.15. Effective Dates of Standards for Balla st Designs Addressed in Life-Cycle Cost
and Payback Period Analyses *

Ballast Design Existing

Standard Effective Date of Existing Standard Effective Date

of Amended

Standard Two-Lamp F34T12 Two-Lamp F96T12/ES Two-Lamp F96T12HO/ES 42 U.S.C. 6295(g)(8) Manufactured for Luminaires July 1, 2009 July 1, 2014

Sold to Luminaire Manufacturer October 1, 2009 October 1, 2014

Incorporated into Luminaires July 1, 2010 July 1, 2015 Manufactured as Replacement July 1, 2010 July 1, 2015 Sold as Replacement October 1, 2010 October 1, 2015

Commercial and Industrial Two-Lamp F32T8 Four-Lamp F32T8 Two-Lamp F96T8 Two-Lamp F96T8HO Two-Lamp F28T5 Two-Lamp F54T5HO N/A N/A June 2014

Residential, Low-PF Two-Lamp F34T12 Two-Lamp F32T8 N/A ** N/A June 2014

* The new standards also affect additional ballast designs not directly addressed in the LCC and PBP analyses ( e.g. , one- and three-lamp versions of ballasts operating 4-foot MBP lamps), with an effective date of June 2014.

** Residential ballasts were not regulated under the 2000 Ballast Rule.



### DOE calculates the LCCs for all consumers as if each would purchase a new product in the year the amended standard takes effect. Ho wever, DOE bases the cost of the equipment on the most recent available data; all dollar values are expressed in 2008$.

8-23

### 8.3 PAYBACK PERIOD INPUTS

8.3.1 Definition

The PBP is the amount of time it takes the consumer to recover the assumed higher purchase cost of a more energy-efficient product as a result of lower operating costs. Numerically, the PBP is the ratio of the increase in purchase cost ( i.e. , from a less efficient design to a more efficient desi gn) to the decrease in annual operating expenditures. This type of calculation is known as a “simple” PBP, becaus e is does not take into account changes in operating cost over time or the time value of money. That is, the calculation is done at an effective discount rate of 0 percent.

The equation for PBP is:

Δ

IC PBP = 

### Eq. 8.9 Δ O C



### Where:

PBP = payback period (years),

∆ IC = difference in the total installed cost between the more efficacious standard level; equipment (efficacy levels 1, 2, etc.) and base line (efficacy level 0) equipment, and



### ∆ OC = difference in annual operating costs.

PBPs are expressed in years. PBPs greater than the life of the product mean that the increased total installed cost of the more efficacious product is not recovered in reduced operating costs over the lifetime of that product. Because all la mp-and-ballast designs in the LCC and PBP analyses save energy and thus yield a positive 

### ∆ OC , PBPs that are negative indicate that the total installed cost of the equipment that meets the more efficacious CSL is less

than that of the baseline.

8.3.2 Rebuttable Presumption Payback Period

Section 325(o)(2)(B)(iii) of the Energy Policy and Conservation Act (EPCA) establishes a rebuttable presumption that an amended standard for ballasts is economically justified if the Secretary finds that “the additional cost to th e consumer of purchasing a product complying with an energy conservation standard level will be less than three times the value of the energy. . . savings during the first year that the consumer will receive as a result of the standard, as calculated under the applicable test procedure.” (42 U.S.C. 6295(o)(2)(B)(iii)) This rebuttable presumption test is an alternative path to establishing economic justification compared to

consideration of the seven factors set fo rth in 42 U.S.C. 6295(o)(2)(B)(i)(I)–(VII).

The applicable ballast test procedure uses resistors to simulate a lamp load and measure input power for the lamp-and-ballast system rather than measure energy consumption ( i.e. , measured over a duration or operating time period). Therefore, to calculate energy savings for the rebuttable presumption payback period, one would need to multiply the input power

8-24

### rating of the lamp-and-ballast system by the usage profile ( i.e. , hours of operation) of that system. For the engineering analysis, DOE measur ed the input power of ballasts operating actual lamps, essentially duplicating real-world operating conditions for these lamp-and-ballast systems. Energy savings calculations in the LCC and PBP analyses use both the real-world system power ratings as well as the applicable usage profiles. Because DOE calculates PBPs in a methodology consistent with the rebuttable presum ption test in the LCC and PBP analyses, DOE is not performing a stand-alone rebuttable presump tion analysis, as it is already embodied in theLCC and PBP analyses. Because calculations of energy savings in the LCC are based under realworld conditions, DOE will also rely on standard PBPs for this rulemaking.

8.3.3 Inputs

The data inputs to PBP are the total installed cost of the product to the customer for each CSL and the annual (first year) operating costs for each CSL. The inputs to the total installed cost are the final product price a nd the installation cost. The inputs to the operating costs are the lamp-and-ballast system input pow er rating, annual operating hours, and electricity cost. The PBP uses the same inputs as the LCC calculation described in section 8.2, ex cept that electricity price trends are not required. Since the PBP is a “simple” (undiscounted) PBP, the required electricity cost is only for the year in which an amended energy conservatio n standard is to take effect ( e.g. , 2014). The electricity price DOE uses in the PBP calculation for electricity cost is the price projected for 2014, expressed in 2008$, but not discounted to 2008. DOE does not use

discount rates in the PBP calculation.

8.4 BALLAST PURCHASING EVENTS

DOE designs the LCC and PBP analyses for this rulemaking around scenarios where consumers need to purchase a ballast; DOE refers to these collectively as “ballast purchasing events.” Each of these events may present the co nsumer with a different set of ballast or lampand-ballast designs and therefore a different set of LCC savings for a certain CSL. For ballasts, DOE has identified two possible scenarios under which consumers would purchase a ballast and potentially be affected by an amended energy conservation standard. These scenarios are: (1) ballast failure; and (2) new construction/renovation. The two ba llast purchasing events are described in more detail below. In addition to these descriptions, Table 8.4.1 and Table 8.4.2 summarize the ballast purchasing events considered in this analysis.

• 

### Ballast failure: This is a scenario in which the installed ballast has failed. DOE recognizes that energy conservation sta ndards set by the 2000 Ballast Rule and the Energy Policy Act of 2005 (EPACT 2005) , Pub. L. 109–58, are effective in 2010 and may affect the types of systems available to the consumer to purchase. These standards ban the sale of most magnetic 4-foot MBP and 8-foot slimline ballasts. The 2000 Ballast Rule, however, allows the continued sale of magnetic cold temperature ballasts, which operate a large portion of the installed base of T12 RDC HO lamps. Magnetic ballasts will also continue to be sold for the residential sector. Therefore, in the baseline, most users who had a magnetic or electronic T12 ballast would be expected to replace it with an electronic T12 ballast and corresponding st andards-compliant lamp (if available), but

failed HO ballasts as well as residential ballast s and fixtures are expected to be replaced with magnetic ballasts or fixtures contai ning magnetic ballasts. Users who had a T8

8-25

### ballast fail would be expected to replace it w ith a T8 ballast and corresponding standardscompliant lamp. However, in the standards case, end-users would generally select a standards-compliant lamp-ballast combination such that the system light output never drops below 10 percent of the baseline system . There are exceptions to this assumption with residential sector products, where ty pical standards-compliant systems produce significantly ( i.e. , greater than 10 percent) more ligh t than the baseline system. Although more efficacious, the residential sector CSLs have higher input wattages than the baseline systems, yielding negative LCC values and precluding economic payback.

• 

### New construction and renovation: This ballast purchasing event encompasses all the new fixture installations where the lighting design will be completely new or can be completely changed. In response to this even t, the spatial layout of fixtures in the building space is not constrained to any previ ous configuration. Because new fixtures can be installed, consumers could install a lamp-and-ballast system that would not maintain the light output of the baseline system. For inst ance, if light output of the standards case system is lower than the base case system, consumers can increase the number of standards case lamp-and-ballast systems installed in the building by a certain percentage to maintain the light output of base case lamp-and-ballast systems. Table 8.4.1, Table 8.4.2, and Table 8.4.3 outline the events and actions taken by consumers in response to

those events both in the base case and the standards case.

Table 8.4.1. Framework of Event-T ype Scenarios for Ballasts Operating 4-Foot and 8-Foot
T12 Lamps (including MBP, Slimline, and RDC)

Event Base Case Action Standards Case Action Type 1. Ballast Failure Installs a T12 ballast and lamps in the existing fixture. HO ballasts are magnetic,

while other ballasts are electronic. Installs a new T12 or T8 ballast and lamps, where the system light output generally never drops below 90 percent of the baseline system. Type 2. New

Construction and

Renovation Installs a new T12 system. Installs a new T12 or T8 system where the system light output never drops below 90 percent of the baseline system. Light output can be maintained through spacing.



### Table 8.4.2. Framework of Event-T ype Scenarios for Ballasts Operating 4-Foot and 8-Foot
T8 Lamps (including MBP, Slimline, and RDC)

Event Base Case Action Standards Case Action Type 1. Ballast Failure Installs a T8 electronic ballast and lamps in the existing fixture. Installs new T8 ballast and lamps, where the system light output generally never drops below 90 percent of the baseline system. Type 2. New

Construction and

Renovation Installs a new T8 system. Installs a new T8 system, where the system light output never drops below 90 percent of the baseline system. Light output can be maintained through spacing.

8-26

### Table 8.4.3. Framework of Event-T ype Scenarios for Ballasts Operating 4-Foot T5 MiniBP
Lamps

Event Base Case Action Standards Case Action

Type 1. Ballast Failure/Replacement Installs a T5 electronic ballast and lamps in the existing fixture. Installs new T5 ballast and lamps, where the system light output never drops below 90 percent of the baseline system. Type 2. New

Construction and

Renovation Installs a new T5 system. Installs a new T5 system, where the system light output never drops below 90 percent of the baseline system. Light output can be maintained through spacing.



### 8.5 LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS

This section presents LCC results for each lamp-and-ballast design DOE considers. This section uses the terms “positive LCC savings” and “negative LCC savings.” When an amended standard results in “positive LCC savings,” the LCC of the standards-compliant system is less than the LCC of the baseline system and the consumer benefits. A consumer is adversely affected when an amended standard results in “negative LCC savings” ( i.e. , when the LCC of the standards-compliant system is higher than the LCC of the baseline system).

As stated earlier, DOE conducts a series ofLCC calculations for each baseline lamp-andballast system. Key inputs consist of using hi storical electricity prices from EAI File 861, electricity price projections from the AEO2009 reference case, and an analysis period of 31 years. In all cases, DOE considers only designs th at save energy and maintain light output above a maximum 10 percent decrease from the baselin e lamp or system whenever possible.

All replacement options are designed around two possible ballast purchasing events where consumers be affected by an amended energy conservation standard. These events are ballast failure/replacement, a nd new construction/renovation. The LCC spreadsheet calculates the LCC impacts for each of these scenarios separately.

DOE is analyzing 14 representative product classes for ballasts, as discussed in section

8.1.1. Table 8.5.1 thro ugh Table 8.5.15 present th e preliminary results for each of these representative product classes by ballast purchasing event, which influences the LCC and PBP results. DOE is also presenting the installed prices of the lamp-and-ballast systems in order to compare the up-front costs that consumers must bear when purchasing baseline or standards-case

systems.

In general, the results show higher installe d prices and lower operating costs at higher efficiency levels. However, this is not always the case. For example, ballasts operating 4-foot MBP and 2-foot U-shaped lamps in the residential sector (Table 8.5.12) have a lower installed price but higher operating costs at higher efficiency levels than in the base case. This is from the significantly higher input power for the evaluated CSLs, which would result in increased energy use and costs despite their more efficient designs. The evaluated CSLs also produce significantly more light output ( i.e. , greater than 30 percent more) than the baseline system, which would exceed the illumination requirements for a replacement scenario. On the other hand, for ballasts operating 4-foot MBP and 2-foot U-shaped lamps in the commercial sector (

8-27

### Table 8.5.3), the higher CSLs exhibit both lower installed prices and lower operating costs than the

F34T12 base case.

8-28Table 8.5.1. LCC and PBP Results for Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps inthe Commercial Sector (F32T8 Baseline)EventResponseCSLBallastEfficacyFactor(BEF)LampTypeLCC$LCCSavings$InstalledPrice$OperatingCost Savings$PBPyrsSystemMean Lumensfrom Baseline%I: BallastBaseline0/11.450F32T8273.24N/A55.87N/AN/AN/AFailure/Lamp and Ballast21.535F32T8264.069.1859.421.392.6(2)ReplacementReplacement31.561F32T8263.489.7657.9816.790.1(1)II: NewBaseline0/11.450F32T8275.52N/A58.27N/AN/AN/AConstruction/Lamp and Ballast21.535F32T8269.386.1461.811.063.40RenovationReplacement31.561F32T8266.189.3460.3816.100.10*A number in parentheses indicates a negative value.Table 8.5.2. LCC and PBP Results for Two-Lamp PS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps in theCommercial SectorEventResponseCSLBEFLampTypeLCC$LCCSavings$InstalledPrice$OperatingCost Savings$PBPyrsSystemMean Lumensfrom Baseline%I: BallastBaseline01.418F32T8248.26N/A55.87N/AN/AN/AFailure/ReplacementLamp and BallastReplacement11.518F32T8236.0712.2059.421.462.4(4)*II: NewBaseline01.418F32T8250.68N/A58.27N/AN/AN/AConstruction/RenovationLamp and BallastReplacement11.518F32T8243.816.8661.810.963.70*A number in parentheses indicates a negative value.8-29Table 8.5.3. LCC and PBP Results for Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps inthe Commercial Sector (F34T12 Baseline)EventResponseCSLBEFLampTypeLCC$LCCSavings$InstalledPrice$OperatingCost Savings$PBPyrsSystemMean Lumensfrom Baseline%I: BallastFailure/ReplacementBaseline01.359F34T12308.59N/A68.41N/AN/AN/ALamp and BallastReplacement11.450F32T8276.7931.8059.422.53(3.6)*(2)21.535F32T8262.6345.9657.983.92(2.7)(3)31.561F32T8245.0363.5639.5384.85(0.3)(3)II: NewConstruction/RenovationBaseline01.359F34T12310.89N/A70.81N/AN/AN/ALamp and BallastReplacement11.450F32T8275.0235.8861.812.98(3.0)021.535F32T8264.1346.7760.384.01(2.6)031.561F32T8243.9466.9541.9390.40(0.3)0*A number in parentheses indicates a negative value. For PBP, negative values indicate standards that reduce operating and installed costs.Table 8.5.4. Summary of the LCC and PBP Results for 4-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot UShaped Lamps in the Commercial SectorEventResponseCSLBEFLampTypeLCC$LCCSavings$InstalledPrice$OperatingCost Savings$PBPyrsSystemMean Lumensfrom Baseline%I: BallastBaseline00.768F32T8486.04N/A97.74N/AN/AN/AFailure/ReplacementLamp and BallastReplacement10.781F32T8497.97(11.93)*101.29(0.91)(never)**3II: NewBaseline00.768F32T8488.29N/A100.14N/AN/AN/AConstruction/RenovationLamp and BallastReplacement10.781F32T8489.25(0.96)103.680.2812.60*A number in parentheses indicates a negative value.**An entry of “never” for PBP indicates standards that do not reduce operating costs.8-30Table 8.5.5. LCC and PBP Results for Four-Lamp PS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps in theCommercial SectorEventResponseCSLBEFLampTypeLCC$LCCSavings$InstalledPrice$OperatingCost Savings$PBPyrsSystemMean Lumensfrom Baseline%I: BallastBaseline00.708F32T8447.78N/A97.74N/AN/AN/AFailure/ReplacementLamp and BallastReplacement10.755F32T8441.316.47101.290.933.82II: NewBaseline00.708F32T8450.22N/A100.14N/AN/AN/AConstruction/RenovationLamp and BallastReplacement10.755F32T8439.1611.05103.681.352.60Table 8.5.6. LCC and PBP Results for Two-Lamp RS and ISBallasts Operating 8-Foot RDC HO Lamps in the IndustrialSector (F96T12HO/ES Baseline)EventResponseCSLBEFLamp TypeLCC$LCCSavings$InstalledPrice$OperatingCost Savings$PBPyrsSystemMean Lumensfrom Baseline%I: BallastFailure/ReplacementBaseline00.440F96T12HO/ES729.92N/A123.28N/AN/AN/ALamp and BallastReplacement10.500F96T12HO/ES652.5777.34126.8311.390.3(8)*10.550F96T8HO652.5777.34126.8311.390.3(11)20.549F96T8HO489.8277.34102.27116.520.0(18)II: NewConstruction/RenovationBaseline00.440F96T12HO/ES732.38N/A125.68N/AN/AN/ALamp and BallastReplacement10.500F96T12HO/ES683.1549.24129.227.430.5010.550F96T8HO683.1549.24129.227.430.5020.549F96T8HO551.7949.24104.6774.800.10*A number in parentheses indicates a negative value.8-31Table 8.5.7. LCC and PBP Results for Two-Lamp RS and ISBallasts Operating 8-Foot RDC HO Lamps in the IndustrialSector (F96T8HO Baseline)EventResponseCSLBEFLamp TypeLCC$LCCSavings$InstalledPrice$OperatingCost Savings$PBPyrsSystemMean Lumensfrom Baseline%I: BallastBaseline0/10.550F96T8HO488.29N/A100.16N/AN/AN/AFailure/ReplacementLamp and BallastReplacement20.549F96T8HO455.6132.69103.715.100.7(8)*II: NewBaseline0/10.550F96T8HO490.69N/A102.56N/AN/AN/AConstruction/RenovationLamp and BallastReplacement20.549F96T8HO548.83(58.14)106.10(7.68)(never)**0*A number in parentheses indicates a negative value.**An entry of “never” for PBP indicate standards that do not reduce operating costs.Table 8.5.8. LCC and PBP Results for Two-Lamp IS Ballasts Operating 8-Foot Slimline Lampsin the Commercial Sector(F96T12ES Baseline)EventResponseCSLBEFLamp TypeLCC$LCCSavings$InstalledPrice$OperatingCost Savings$PBPyrsSystemMean Lumensfrom Baseline%I: BallastBaseline00.797F96T12ES502.49N/A97.09N/AN/AN/AFailure/ReplacementLamp and BallastReplacement10.807F96T12ES501.411.09100.630.507.00II: NewBaseline00.797F96T12ES504.79N/A99.49N/AN/AN/AConstruction/RenovationLamp and BallastReplacement10.807F96T12ES503.990.80103.030.477.508-32Table 8.5.9. LCC and PBP Results for Two-Lamp IS Ballasts Operating 8-Foot Slimline Lampsin the Commercial Sector(F96T8 Baseline)EventResponseCSLBEFLamp TypeLCC$LCCSavings$InstalledPrice$OperatingCost Savings$PBPyrsSystemMean Lumensfrom Baseline%I: BallastBaseline00.790F96T8455.72N/A84.57N/AN/AN/AFailure/ReplacementLamp and BallastReplacement10.809F96T8454.341.3788.110.546.61II: NewBaseline00.790F96T8457.97N/A86.97N/AN/AN/AConstruction/RenovationLamp and BallastReplacement10.809F96T8453.484.4990.510.884.00Table 8.5.10. LCC and PBP Results for Two-Lamp PS Ballasts Operating 4-Foot T5 MiniBP SO Lamps in the Commercial SectorEventResponseCSLBEFLamp TypeLCC$LCCSavings$InstalledPrice$OperatingCost Savings$PBPyrsSystemMean Lumensfrom Baseline%I: BallastBaseline01.309F28T5310.47N/A51.51N/AN/AN/AFailure/Lamp and Ballast11.441F28T5276.7133.7655.064.070.90ReplacementReplacement21.482F28T5276.7233.7553.623.910.5(2)*II: NewBaseline01.309F28T5312.98N/A53.91N/AN/AN/AConstruction/Lamp and Ballast11.441F28T5279.0133.9857.454.090.90RenovationReplacement21.482F28T5271.4241.5656.024.760.40*A number in parentheses indicates a negative value.Table 8.5.11. LCC and PBP Results for Two-Lamp PS Ballasts Operating 4-Foot T5 MiniBP HO Lamps in the Industrial SectorEventResponseCSLBEFLamp TypeLCC$LCCSavings$InstalledPrice$OperatingCost Savings$PBPyrsSystemMean Lumensfrom Baseline%I: BallastBaseline00.688F54T5HO383.90N/A50.25N/AN/AN/AFailure/Lamp and Ballast10.791F54T5HO348.0535.8553.805.540.60ReplacementReplacement20.837F54T5HO341.5642.3452.366.260.30II: NewBaseline00.688F54T5HO386.37N/A52.65N/AN/AN/AConstruction/Lamp and Ballast10.791F54T5HO350.4835.8956.195.550.60RenovationReplacement20.837F54T5HO337.0449.3354.767.240.308-33Table 8.5.12. LCC and PBP Results for Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps inthe Residential Sector (LowPower Factor, F34T12 Baseline)EventResponseCSLBEFLamp TypeLCC$LCCSavings$InstalledPrice$OperatingCost Savings$PBPyrsSystemMean Lumensfrom Baseline%I: BallastBaseline01.277F34T12123.98N/A68.41N/AN/AN/AFailure/Lamp and Ballast11.457F32T8118.115.8759.42(0.29)*(never)**29ReplacementReplacement21.492F32T8118.685.3057.98(0.49)(never)38II: NewBaseline01.277F34T12126.35N/A70.81N/AN/AN/AConstruction/Lamp and Ballast11.457F32T8108.1718.1861.810.90(10.0)0RenovationReplacement21.492F32T8105.8920.4660.380.98(10.6)0*A number in parentheses indicates a negative value.**Negative PBP values indicate standards that reduce operating costs and installed costs. Entries of “never” for PBP indicate standards that do not reduceoperating costs.Table 8.5.13. LCC and PBP Results for Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps inthe Residential Sector (Low Power Factor, F32T8 Baseline)EventResponseCSLBEFLamp TypeLCC$LCCSavings$InstalledPrice$OperatingCost Savings$PBPyrsSystemMean Lumensfrom Baseline%I: BallastBaseline0/11.457F32T8114.57N/A55.87N/AN/AN/AFailure/ReplacementLamp and BallastReplacement21.492F32T8120.11(5.54)*59.42(0.19)(never)**7II: NewBaseline0/11.457F32T8116.96N/A58.27N/AN/AN/AConstruction/RenovationLamp and BallastReplacement21.492F32T8119.37(2.41)61.810.1132.20*A number in parentheses indicates a negative value.**An entry of “never” for PBP indicates standards that do not reduce operating costs.8-34Table 8.5.14. LCC and PBP Results for Four-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps (ColdTemperature/Sign Ballasts)in the Commercial SectorEventResponseCSLBEFLamp TypeLCC$LCCSavings$InstalledPrice$OperatingCost Savings$PBPyrsSystemMean Lumensfrom Baseline%I: BallastBaseline00.196F96T12HO1479.28N/A151.24N/AN/AN/AFailure/ReplacementLamp and BallastReplacement10.238F96T12HO1108.02371.26154.7940.870.10II: NewBaseline00.196F96T12HO1481.58N/A153.64N/AN/AN/AConstruction/RenovationLamp and BallastReplacement10.238F96T12HO1284.09197.49157.1821.920.20Table 8.5.15. LCC and PBP Results for Four-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps (ColdTemperature/Sign Ballasts)in the Industrial SectorEventResponseCSLBEFLamp TypeLCC$LCCSavings$InstalledPrice$OperatingCost Savings$PBPyrsSystemMean Lumensfrom Baseline%I: BallastBaseline00.196F96T12HO1169.55N/A151.24N/AN/AN/AFailure/ReplacementLamp and BallastReplacement10.238F96T12HO900.11269.45154.7938.430.10II: NewBaseline00.196F96T12HO1171.88N/A153.64N/AN/AN/AConstruction/RenovationLamp and BallastReplacement10.238F96T12HO1029.00142.89157.1820.610.208-35

### REFERENCES

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2. U.S. Department of Energy–Energy Efficien cy and Renewable Energy. Office of Building

Research and Standards: Tec hnical Support Document: Energy Efficiency Standards for Consumer Products: Fluorescent Lamps Ballast Proposed Rule. Appendix A. Engineering Analysis Supporting Documentation. January 2000. Washington, D.C.

< http://www.eere.energy.gov/buildings/appliance_standards/residential/pdfs/appendix_a.pdf >

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< http://www.nfpa.org/freecodes/free_ access_agreement.asp?id=7005SB >

4. U.S. Department of Labor–Bureau of Labor Statistics. May 2005 Occupational Employment and Wage Estimates. National Cross-Industry Estimates. 2005. Washington,

D.C. < http://www.bls.gov/oes/oes_dl.htm >

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< http://www.esource.com/BEA/demo/BEA_esource/PA_10.html >

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< http://www.eia.doe.gov/oiaf/archive/aeo08/index.html >

8. GDS Associates, Inc. Engineers and Consultants. Measure Life Report: Residential and Commercial/Industrial Lighting and HVAC Measures (The New England State Program Working Group). 2007.

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Retention and Persistence Studies Results . 2005. Southern California Edison.

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< http://www.ehso.com/fluoresc.php >

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.
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8-36

### 13. The Federal Reserve Board. Federal Reserve Stat istical Release, Selected Interest Rates, Historical Data, Instrument: CDs (secondary market), Maturity: 6-month, Frequency: Annual, Description: Average rate on 6-mont h negotiable certificates of deposit (secondary market), quoted on an investme nt basis. 2006. Washington, D.C.

< http://www.federalreserve.gov/releases/H15/data.htm >

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8-38

### CHAPTER 9. SHIPMENTS ANALYSIS

TABLE OF CONTENTS

9.1 INTRODUCTION

.............................................................................................................. 9 -2

9.2 SHIPMENTS MODEL METHODOLOGY

....................................................................... 9-2

9.2.1 Analyzed Product Classes, Market Sectors, and Market Segments

..................... 9-2

9.2.1.1 Ballast Failure

.................................................................................................. 9-3

9.2.1.2 New Constructi on/Renovation

......................................................................... 9-4

9.3 BASE-CASE INPUTS AND FORECASTS

...................................................................... 9-6

9.3.1 Base-Case Scenar ios Analyzed

............................................................................ 9-6

9.3.2 Base-Case Scenarios

............................................................................................ 9-8

9.3.2.1 Historical Shipments

........................................................................................ 9-9

9.3.2.2 Calculation of Insta lled Stock in 2006

........................................................... 9-10

9.3.2.3 Base-Case Market-Share Apportionment

...................................................... 9-11

9.3.2.4 Base-Case Forecast Results

........................................................................... 9-14

9.3.2.5 Base-Case Forecast by Market Segment

........................................................ 9-18

9.4 STANDARDS-CASE INPUTS

........................................................................................ 9-21

9.4.1 Shipments Scenarios

.......................................................................................... 9-21

9.5 RESULTS

.................................................................................................................... ..... 9-22

REFERENCES

..................................................................................................................... ..... 9-29

LIST OF TABLES

Table 9.2.1. Product Classes and Market Sectors Analyzed in the Shipments Analysis

............. 9-3 Table 9.2.2. Modeled Fluorescent Lamp-a nd-Ballast Replacement Trends

................................ 9-4

Table 9.3.1. Total Historical Fluorescen t Ballast Shipments (millions)

...................................... 9-9 Table 9.3.2. Historical Fluorescent Ballast Shipme nts by Estimated Life Event (millions)

..... 9-10 Table 9.3.3. 2006 Ballast Stocks (millions)

............................................................................... 9-11 Table 9.3.4. Weighted Apportionments for Sta ndard- and High-Efficiency 4-Foot T8

MBP Ballasts

..................................................................................................... 9-12 Table 9.3.5. Base-Case Initial Market-Share Ap portionments for Two-Lamp RS and IS Ballasts Operating 4-Foot MBP a nd 2-Foot U-Shaped Lamps (F34T8 Baseline)

............................................................................................................ 9-12 Table 9.3.6. Base-Case Initial Market-Share Ap portionments for Two-Lamp PS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps

....................................... 9-12 Table 9.3.7. Base-Case Initial Market-Share Ap portionments for Two-Lamp RS and IS Ballasts Operating 4-Foot MBP a nd 2-Foot U-Shaped Lamps (F34T12 Baseline)

............................................................................................................ 9-12 Table 9.3.8. Base-Case Initial Market-Share Ap portionments for Four-Lamp RS and IS Ballasts Operating 4-Foot MBP a nd 2-Foot U-Shaped Lamps

......................... 9-13 Table 9.3.9. Base-Case Initial Market-Share Ap portionments for Four-Lamp PS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps

....................................... 9-13

9-i

### Table 9.3.10. Base-Case Initial Market-Share Ap portionments for Two-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps (F96T12HO/ES Baseline)

............ 9-13 Table 9.3.11. Base-Case Initial Market-Share Ap portionments for Two-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps (F96T8HO Baseline)

................... 9-13 Table 9.3.12. Base-Case Initial Market-Share Ap portionments for Two-Lamp IS Ballasts Operating 8-Foot Slimline Lamps (F96T12/ES Baseline)

................................. 9-13 Table 9.3.13. Base-Case Initial Market-Share Ap portionments for Two-Lamp IS Ballasts Operating 8-Foot Slimline Lamps (F96T8 Baseline)

........................................ 9-13 Table 9.3.14. Base-Case Initial Market-Share Ap portionments for Two-Lamp PS Ballasts Operating 4-Foot T5 MiniBP SO Lamps

........................................................... 9-14 Table 9.3.15. Base-Case Initial Market-Share Ap portionments for Two-Lamp PS Ballasts Operating 4-Foot T5 MiniBP HO Lamps

.......................................................... 9-14 Table 9.3.16. Base-Case Initial Market-Share Ap portionments for Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2- Foot U-Shaped Lamps (Low Power Factor, F34T12 Baseline)

................................................................................... 9-14 Table 9.3.17. Base-Case Initial Market-Share Ap portionments for Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2- Foot U-Shaped Lamps (Low Power Factor, F34T8 Baseline)

..................................................................................... 9-14 Table 9.3.18. Base-Case Initial Market-Share Ap portionments for Four-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps (Cold Temperature/Sign Ballasts)

.............................................................................................................. 9-14 Table 9.5.1. Cumulative Ballast Shipments Impacts by Standard Level, 2014–2044 (Existing Technologies, Shift Scenario)

............................................................ 9-26 Table 9.5.2. Cumulative Ballast Shipments Impacts by Standard Level, 2014–2044 (Emerging Technologies, Roll-up Scenario)

..................................................... 9-27

LIST OF FIGURES

Figure 9.3.1. 4-Foot MBP Base-Case Foreca sted Ballast Shipments (Existing and Emerging Technologies Scenarios)

................................................................... 9-15 Figure 9.3.2. 8-Foot RDC HO Base-Case For ecasted Ballast Shipments (Existing and Emerging Technologies Scenarios, Excluding Sign Ballasts)

........................... 9-16 Figure 9.3.3. 8-Foot Slimline Base-Case Forecasted Ballast Shipments (Existing and Emerging Technology Scenarios)

...................................................................... 9-16 Figure 9.3.4. 4-Foot MiniBP SO and HO Base-Case Forecasted Ballast Shipments (Existing and Emerging Technologies Scenarios)

............................................. 9-17 Figure 9.3.5. Base-Case Forecasted Shipments for Ballasts Operating 4-Foot MBP Lamps

in the Residential Sector (Existing a nd Emerging Technologies Scenarios)

..... 9-17 Figure 9.3.6. Base-Case Forecasted Shipments for Sign Ballasts Op erating 8-Foot RDC HO Lamps

.......................................................................................................... 9-18 Figure 9.3.7. 4-Foot MBP Base-Case Ballast Sh ipments Forecast by Market Segment

........... 9-19 Figure 9.3.8. 8-Foot RDC HO Base-Case Ballast Sh ipments Forecast by Market Segment

.... 9-19 Figure 9.3.9. 8-Foot Slimline Base-Case Ballast Sh ipments Forecast by Market Segment

...... 9-20 Figure 9.3.10. 4-Foot MiniBP SO and HO Ba llast Shipments Forecast by Market Segment

.............................................................................................................. 9-20

9-ii

### Figure 9.5.1. 4-Foot MBP Base Case and Sta ndards-Case Ballast Shipments Forecasts (Emerging Technologies, Roll-Up Scenario)

.................................................... 9-22 Figure 9.5.2. 4-Foot MBP Base Case and Sta ndards-Case Ballast Shipments Forecasts (Existing Technologies, Shift Scenario)

............................................................ 9-23 Figure 9.5.3. 8-Foot RDC HO (including Co ld Temperature/Sign) Base Case and

Standards-Case Balla st Shipments Forecasts (Existing Technologies, Shift Scenario)

............................................................................................................ 9-23 Figure 9.5.4. 8-Foot RDC HO (including Co ld Temperature/Sign) Base Case and

Standards-Case Ballast Shipments Forecasts (Emerging Technologies, Roll-Up Scenario)

.............................................................................................. 9-24 Figure 9.5.5. 8-Foot Slimline Base Case and St andards-Case Ballast Shipments Forecasts (Existing Technologies, Shift Scenario)

............................................................ 9-24 Figure 9.5.6. 8-Foot Slimline Base Case and St andards-Case Ballast Shipments Forecasts

Figure 9.5.7. 4-Foot MiniBP SO and HO Ba se Case and Standa rds-Case Ballast

Figure 9.5.8. 4-Foot MiniBP SO and HO Ba se Case and Standa rds-Case Ballast (Emerging Technologies, Roll-Up Scenario)

.................................................... 9-25

Shipments Forecasts (Existing Tec hnologies, Shift Scenario)

.......................... 9-25

Shipments Forecasts (Emerging Technologies, Roll-Up Scenario)

.................. 9-26

9-iii

### CHAPTER 9. SHIPMENTS ANALYSIS

9.1 INTRODUCTION

Shipments of fluorescent lamp ba llasts (hereafter “ballasts”) are key inputs to the national energy savings (NES) and net present value (NPV) calculations. Shipments are also a necessary input to the manufacturer impact analysis (MIA), which the U.S. Department of Energy (DOE) conducts for its notices of proposed rulemaki ng (NOPRs). This chapter describes DOE’s methodology for projecting annual shipments and pr esents initial inputs and results for ballasts.

In the shipments analysis, DOE develops a base-case shipment forecast for each ballast type to depict what would happen to energy use and consumer costs for the purchase and operation of lamp-and-ballast systems in the ab sence of amended Federal energy conservation standards. In determining the base case, DOE considers hist orical shipments, emerging technologies, the mix of efficiencies sold in th e absence of amended standards, and how that mix might change over time. To evaluate the impacts of standards on ballasts, DOE then compares the base-case projection with forecasts of wh at could happen if DOE promulgates amended standards (the standards case). DOE considers multiple shipments scenarios to characterize both

the base- and standards-case shipments. To determine the cumulative NES and NPV of standards, DOE compares forecasted shipments of a base to a standards case over the national impact analysis (NIA) analysis period, 2014–2044.

The shipments model and the national impacts model are integrated into a single Microsoft Excel spreadsheet accessible at www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_ballasts.html

. Appendix 9A discusses how to access the spreadsheet and provides basic instructions for its use. This preliminary technical support document (TSD ) chapter explains the shipments models. Section 9.2 presents the shipments model methodolog y for ballasts; section 9.3 describes the data inputs, historical shipments, ba se-case scenarios, and shipments forecasts; section 9.4 discusses the impacts of proposed amended standards on th e mix of ballast desi gns; and section 9.5 presents the shipments results for the diffe rent candidate standard levels (CSLs).

9.2 SHIPMENTS MODEL METHODOLOGY

In general, DOE followed a three-step process to forecast ballast shipments. First, DOE used 1990 to 2005 historical shipment data from U.S. Census Bureau data to estimate the total historical shipments of each ballast type analyzed. Second, DOE calculated an installed stock for each ballast type in 2005 based on the average serv ice lifetime of each ballast type. Third, by modeling ballast purchasing events, such as re placement and new construction, and applying growth rate, replacement rate, and emerging te chnologies penetration rate assumptions, DOE developed annual ship ment projections, 2006–2044.

9.2.1 Analyzed Product Classes, Market Sectors, and Market Segments

DOE forecasted annual shipments for the ba llast and market sectors presented in Table 9.2.1. The shipments model analyzes all ballast types at CSLs that assign efficiency levels for each product class.

9-2

### Table 9.2.1. Product Classes and Market Sector s Analyzed in the Shipments Analysis

Product Class Baseline Market Sectors Two-Lamp Rapid-start (RS) and Instant-Start (IS) Ballasts Operating 4-Foot Medium Bipin (MBP) and 2-Foot U-Shaped Lamps F32T8 Commercial

Two-Lamp Programmed-Start (PS) Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps F32T8 Commercial

Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps F34T12 Commercial Four-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps F32T8 Commercial Four-Lamp PS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps F32T8 Commercial Two-Lamp RS and IS Ballasts Operating 8-Foot Recessed Double Contact (RDC) High-Output (HO) Lamps F96T12HO/

ES Industrial

Two-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps F96T8HO Industrial Two-Lamp IS Ballasts Operating 8-Foot Single Pin Slimline (Slimline) Lamps F96T12ES Commercial Two-Lamp IS Ballasts Operating 8-Foot Slimline Lamps F96T8 Commercial Two-Lamp PS Ballasts Operating 4-Foot T5 Miniature Bipin (MiniBP) Standard Output (SO) Lamps F28T5 Commercial

Two-Lamp PS Ballasts Operating 4-Foot T5 MiniBP HO Lamps F54T5HO Industrial Two-Lamp RS and IS Ballasts Operating 4-Foot MBP Lamps (Residential, Low-Power Factor) F34T12 Residential

Two-Lamp RS and IS Ballasts Operating 4-Foot MBP Lamps (Residential, Low-Power Factor) F32T8 Residential

Four-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps (Cold Temperature/Sign Ballasts) F96T12HO Commercial

Industrial



### In its shipments model, DOE considers sp ecific market segments (“ballast purchase events”) to develop estimates of annual shipments. These two market segments correspond to the ballast purchase events that DOE uses in the life-cycle cost (LCC) and payback period (PBP) analyses (preliminary TSD chapter 8). These include ballast failure (Event I) and new construction/renovation (Event II). For each mark et segment, DOE makes certain assumptions about how consumers are likely to purchase new ba llasts or lamp-and-ballast systems. DOE uses these purchasing assumptions to develop the ballast shipment forecasts.

9.2.1.1 Ballast Failure

For those consumer purchases triggered by a ballast failure, DOE assumes that the consumer will purchase a ballast identical to the one that has retired, if it is available. If in the standards case, the base-case ballast design is not standards-compliant (a nd therefore unavailable as a replacement option), then DOE assumes consumers will purchase a new, standardscompliant lamp-and-ballast system from the same product class such that the system light output, if possible, never drops below 10 percent of the baseline system. In some instances this means a single ballast is replaced with two ballasts ( e.g. , replacing one two-lamp, 8-foot slimline lamp

and-ballast system with two two-lamp, 4-foot MBP lamp-a nd-ballast systems). Table 9.2.2 below presents a full listing of the modeled lamp-and-ballast system replacement trends.

9-3

### Table 9.2.2. Modeled Fluorescent Lamp-a nd-Ballast Replacement Trends

Retired Lamp-and-Ballast System Repl acement Lamp-and-Ballast System 4-foot T12 electronic MBP (commercial sector) 87.5% 4-foot T8 MBP

12.5% 4-foot T5 MiniBP SO 4-foot T12 electronic MBP (residential sector) Replace in kind 4-foot T8 MBP (commercial sector) 87.5% replace in kind

12.5% 4-foot T5 MiniBP SO 4-foot T8 MBP (residential sector) Replace in kind

8-foot T12 slimline 10% 8-foot T8 slimline
10% Replace in kind

80% two 4-foot T8 MBPs

8-foot T8 slimline Replace in kind

8-foot T12 RDC HO 80% two 4-foot T5 MiniBP HO systems

20% 8-Foot T8 RDC HO

8-foot T8 RDC HO 80% two 4-foot T5 MiniBP HO systems 20% replace in kind

4-foot T5 MiniBP SO Replace in kind

4-foot T5 MiniBP HO Replace in kind 8-foot T12 magnetic RDC HO (cold temperature/ sign ballasts) Replace in kind



### DOE establishes the timing of ballast replacem ents in response to ballast failure by tracking ballast shipments and then predicting when these ballasts are expected to retire based on their service lifetime. DOE recognizes that ballast lifetimes vary, but was unable to identify an industry consensus on failure distributions for different ballast designs. For the preliminary analyses, DOE modeled ballasts as having zero failures until the last three years of their service lifetime, in which failures were distributed as follows:

• 

### Second-to-last year: 25 pe rcent of ballasts fail

• 

### Next-to-last year: 33 percent of remaining ballasts fail

• 

### Last year: all remaining ballasts fail.

DOE invites additional comment on the distribut ion of expected failure rates throughout

ballast lifetimes.

DOE calculated average commercial and industr ial ballast service lif etimes by dividing the average ballast lifetime in hours (established in the LCC) by average annual operating hours. As noted in the preliminary TSD chapter 8, the service life in the commercial, residential and

industrial sectors is assumed as approximately 15 years, 15 years, and 10 years, respectively.

9.2.1.2 New Construction/Renovation

For consumer purchases triggered by new construction and renovation, DOE begins by assuming that consumers may purchase new lamp-and- ballast systems to service their particular lumen demand from within their current product class. DOE therefore produces initial shipment

estimates due to new constructi on and renovation by deriving gr owth rates for each product class. The growth rates are based on EIA’s Annual Energy Outlook 2009 ( AEO2009 ), 1,2 

### which

estimates annual commerc ial floor space and residentia l building growth. Because the AEO2009

considers future trends in ec onomic growth, DOE incorporated macroeconomic conditions in its

9-4

### growth forecasts. However, because the AEO does not provide industrial floor space forecasts, DOE used historical MECS floor space values to establish a growth rate for the industrial sector.

For the commercial and industrial sector, DOE assumes that the in tensity of ballasts per unit of floor space remains constant ( i.e. , sector growth rates are assu med to be the only source of overall growth in the ballasts market). For the residential sector, DOE assumes a slight growth rate in intensity over time. DOE invites further comment on future growth rates for the ballasts industry overall.

However, for several product classes DOE rese arch indicates that the ballasts market is moving in a particular direction. In such instances, DOE adjusts its forecasted growth rates for particular ballast types accordingly. In almost all cases DOE’s approach is to make these adjustments by substituting growth in one product class for another, without adjusting the overall number of forecasted shipments. The only excepti on is that wherever ballasts operating 4-foot lamps replace ballasts operating 8-foot lamps, DOE assumes this occurs at a 2:1 ratio. In determining what shipment trends to assume for this rulemaking, DOE references its previous analysis of fluorescent lamp-and-ballast shipments, performed as part of its proposed rulemaking for general service fluorescent and incandescent reflector lamps (GSFL/IRL; hereafter “the lamps rulemaking”).

For the commercial sector, historical lamps shipment data and manufacturer interviews indicate significant growth for only 4-foot T8 MBP and 4-foot T5 MiniBP SO systems; consequently, DOE models all purchases due to new construction in the commercial sector as being one of these two lamp-and-ballast system s. DOE models commercial sector 4-foot T5 MiniBP SO and HO shipment growth based on a migration from other product classes. DOE’s research indicates that shipment growth of 4-foot T5 MiniBP SO ballasts is primarily driven by a migration from the 4-foot MBP market. As this mig ration requires the purchase of a new fixture, to establish 4-foot MiniBP T5 SO shipments, DOE allotted a portion of wh at would otherwise be

the 4-foot MBP fixture new constr uction/renovation market to 4-foot T5 MiniBP systems. In the proposed lamps rulemaking, DOE first calculated the size of this potential market for new 4-foot T5 MiniBP SO systems in each year. DOE then determined the portion of this market that would be serviced by 4-foot T5 MiniBP SO systems by calculating the share that resulted in T5 shipments consistent with 2006 and 2007 data. For the ballasts sh ipments model, DOE holds the resulting percentage—approximately 12.5 percen t of the new construction/renovation market— constant throughout the analysis period.

In the industrial sector, confidential histori cal shipments show a declining number of 8

- foot RDC HO lamps. Therefore, DOE assumes all system purchases due to new construction in the industrial sector are 4-foot T5 MiniBP HO sy stems (another rapidly growing market). In the proposed lamps rulemaking, DOE developed 4 -foot T5 MiniBP HO ballast shipments by modeling a migration from two different lighting markets. Similar to 8-foot RDC HO systems, marketing literature indicates a large portion of 4-foot MiniBP T5 HO systems serve high-bay applications due to their highly concentrated li ght output. Historical ship ment data for 8-foot RDC HO lamps shows substantia l declines in 2006 and 2007, indicating T5 HO systems may be rapidly displacing 8-foot RDC HO systems. In addition, DOE’s research indicated that a significant portion of 4-foot T5 MiniBP HO growth can be attributed to their penetration into the high intensity discharge (HID) lamp high- and low-bay markets. Therefore, to calculate the growth in 4-foot MiniBP T5 HO ballast ship ments, DOE assumed that these systems were

9-5

### penetrating both the 8-foot RDC HO and HID markets. Similar to its analysis for T5 SO systems,

DOE established that the new c onstruction/renovation market segm ent represents the available

market for 4-foot MiniBP T5 HO systems. DOE obtained HID shipment data from the HID determination, from which DOE calculated the to tal lumens servicing low bay and high bay applications. Consistent with historical 4-foot T5 MiniBP HO and 8-foot RDC HO shipments, DOE assumed 4-foot T5 MiniBP HO system s fully penetrate the 8-foot RDC HO new

construction/renovation market se gment as well as the HID new construction/renovation market segment. These same assumptions are app lied in the proposed ballast rulemaking.

For the residential sector, manufacturer interviews indicate that the majority of new residential 4-foot MBP fixtures use T8 MBP sy stems. Consequently, DOE models only 4-foot T8 MBP lamp-and-ballast systems for new constr uction in the residentia l sector and, based on the proposed lamps rulemaking analysis, assumes a 1 percent annual growth rate in floorspace intensity for these shipments.

9.3 BASE-CASE INPUTS AND FORECASTS

This section describes the two base-case scen arios DOE employs in its analysis and the base-case input market-share apportioning for ballasts and presents the base-case forecasts for each ballast type along with historical ballast shipments data.

9.3.1 Base-Case Scenarios Analyzed

DOE recognizes that rapidly emerging new lighting technologies could penetrate the fluorescent lighting market and significantly affect ballast shipment forecasts. These technologies, such as ceramic metal halide (C MH) and light-emitting diodes (LEDs) already are or eventually will be significantly more efficacious and longer lasting than the sources they replace. If these emerging technologies achieve th eir potential, they may significantly affect the benefit calculations from efficiency standards. However, to calculate NES and NPV change due to emerging technologies, DOE would need to accurately forecast the anticipated price and performance points of each emerging technolog y—a difficult and highly speculative task. Because of this high degree of uncertainly, DOE considered two base-case scenarios for ballasts: existing technologies and emerging technolog ies. DOE believes eval uating two base-case scenarios will more completely and transparently characterize the uncertainty in estimating emerging technologies’ market penetration and the consequent impact on NPV and NES. Incorporating emerging technologies in the base ca se does not affect the relative benefits of each CSL and prevents uncertain proj ections of market share, price, or performance from obscuring

the benefits derived from more e fficient ballast designs alone.

The assumptions and methodology that drive th ese scenarios and the details specific to each are described in sections 9.3.2 and 9.3.3, respectively. In general, DOE calculated the market penetration of each of the an alyzed emerging technologies annually 2006–2045, assessing each sector separately . DOE determined the market penetration of the technology option that achieved the highest level of penetration in each year in each sector. DOE then decreased the analyzed market size in each year in each sector by the amount that corresponded to the highest level of market pe netration achieved by a technology.

9-6

### For its base-case analysis, DOE estimated the market penetration of two specific technologies into the projected installed stock: LED systems and CMH systems. In general, the Existing Technologies scenario considers only the market penetration of technologies that have reached maturation in terms of price and efficiency. Because LED and CMH systems are assumed to have not yet reached maturation, no technologies outside t hose covered by this rulemaking were analyzed in the existing technologies scenario.

In the emerging technologies scenario, DOE a ttempts to forecast the market penetration of both mature technologies and those technologies that are still undergoing significant changes in price and efficiency. Specifically, DOE consid ered the market penetration of LED systems and CMH systems in the emerging technologies scenario.

DOE generally followed a five-step process for each scenario to estimate the market penetration of the analyzed emerging technologies and account for their impact on NES and NPV. First, DOE developed price, performance, and efficiency forecasts for each of the analyzed emerging technologies. Second, using those estimates, DOE calculated the PBP of each technology in the relevant sector using the difference between its purchase price, annual electricity cost, and annual replacement cost rela tive to the fluorescent lamp-and-ballast system it replaces. Specifically, DOE uses the following formula to calculate simple PBP:

− Δ Purchase Price ($/klm) Simple Payback = Δ Annual Electricity Cost ($/klm/yr) + Δ Annual Replacement Cost ($/klm/yr)



### Where:

Δ = the difference between the two technology options compared,

Purchase Price = includes the la mp price and fixture price, Annual Electricity Cost = a function of the mean annual ope rating hours and efficiency for each technology option, the electricity price, and the lumen demand, and Annual Replacement Cost = a function of the mean ballast life, annual operating hours, ballast price, and labor charge.

Third, DOE used the relationship between PB P and market penetration to predict the market penetration of each technology in the relevant sector annually 2006–2044. The relationship, which was used to estimate the penetration of solid-state lighting in a DOE report, predicts the market penetr ation based on the PBP of a technology. DOE assumed this relationship is valid for other emerging lighting technologies ( i.e. , given a PBP duration, a technology will achieve a certain market penetr ation; the greater the PBP, the greater the expected market penetration). DOE used a 5-year average of the market penetrations predicted by the relationship as its final market penetra tion. The 5-year average represents the time DOE assumed it takes pr oducts with lower PBPs to penetrate the market.

Fourth, when necessary, DOE applied a scaling factor to the predicte d market penetration to account for observed market trends. Fifth, as stated above, DOE reduced the projected

9-7

### installed stock of covere d products in each year by the value that corresponded to the highest level of market penetration achieved in each year by one of the analyzed technologies. Thus, emerging technologies have the effect of lo wering the energy savings of a potential new

standard. For those covered ballast s remaining, the cost effectiv eness of LCC savings (and thus the relative cost effectiveness of each CSL) is not impacted.

9.3.2 Base-Case Scenarios

For the existing technologies scenario, DOE analyzes only the fluorescent ballast technologies covered by the rulemaking because it believes that no matu re technologies in the current market show the potential to penetrate the fluorescent ballast market significantly. (A rapidly growing market, T5 systems are consid ered in the analysis as covered products). In the emerging technologies scenario, however, DOE separately considered the potential market penetration of two technologies: LED (into the commercial, residential, and industrial sectors) and CMH (into the commercial and industrial sectors).

This rulemaking references DOE’s previ ous analysis of LED market penetration, performed as part of the proposed lamps rulemaking. In its analysis, DOE found a commercially available retrofit kit that included a LED repla cement for a 4-foot MBP lamp-and-ballast system.

DOE used the retrofit kit as a current baseline fro m which to project future cost, efficiency and price points. DOE interviewed an integrated circuit manufacturer to develop cost estimates for

LED driver circuits. For cost estimates of othe r components, DOE used prices of existing LED products already on the market, which it modified in accordance with cost data and efficiency projections from DOE’s Solid State Lighting Multi-Year Program Plan. 3 

### After applying a markup based on currently available LED lamps, DOE arrived at price and efficiency projections for the LED luminaire in the retrofit kit. Because they are based on an existing LED retrofit kit, DOE’s projections did not consider innovations in form factor or OLED technology that could improve the possible PBP for solid-state lighting technologies. For further detail on DOE’s price and efficiency forecasts of potential LED repl acements, see appendix 10C of the GSFL/IRL

NOPR TSD. 4 

### Following the five-step process descri bed above, DOE calculated a 41 percent market penetration rate of LED lamps into the 4-foot fluorescent system commercial sector by 2044. In the residential sector, the LED option did not have a low enough PBP to result in any market penetration. DOE assumed LED systems penetrated only the new construction/renovation market because these systems would re quire their own specific fixtures.

In this rulemaking, DOE also analyzed the potential penetration of CMH into the fluorescent lighting market. DOE first estimate d current CMH prices using a methodology similar to the methodology it used to estimate GS FL and IRL prices. Industry experts informed DOE that CMH efficiencies and lifetimes would increase over the next several years while prices would remain constant. Applying these lifetime and efficiency projections, DOE compared CMH replacements to GSFL systems. As a result, DOE assumed no market penetration of CMH into T5 systems because it found that T5 lamp sy stems (standard output and high output) would always be less costly and more efficacious than projected CMH replacements. Given this information, DOE believes that it is likely that migration to CMH (from the GSFL market) will be instead dominated by the migration to standard and high output T5 lamps.

9-8

### 9.3.2.1 Historical Shipments

DOE used U.S. Census Bureau Current Indus trial Reports (CIR) fo r ballasts to estimate historical shipments for affected ballast designs. 5,6 

### The census data contain NEMA shipments for individual ballast designs ( e.g ., 2-lamp F96T8) as well as aggregated shipments for multiple designs to keep manufacturer information confidential. For some ballast designs, all shipments are withheld to prevent disclosing data for individual companies.

DOE estimated historical ballast shipments for 1990–2005. This time period encompasses the longest ballast service life considered in the shipments analysis ( i.e. , 15 years for ballasts in the residential sector) and ends with the last full year of shipments data from Current Industrial Reports for fl uorescent ballasts (CIRs for balla sts were discontinued in 2006). For those reporting years for which specific shipments data were not available, DOE extrapolated historical shipments based on trends within the availa ble data, and/or market trends identified in ballast manufacturer interviews, the proposed lamps rulemaking, and the Fluorescent Ballasts Energy Conservation St andards Final Rule pub lished on September 19, 2000 (hereafter “the 2000 Ballast Rule”). 65 FR 56740; 10 CFR 430.23(m)(4). Where shipments data were aggregated and not available for speci fic ballast designs, DO E estimated historical shipments based on apportionment estimates and market trends identified in ballast manufacturer interviews, the proposed lamps rulemaking and the 2000 Ballast Rule. To validate these estimation methods, DOE requested historical ba llast and residential fixture shipments from

NEMA but was unable to obtain this data.

Recognizing that shipment estimates based on CIR data reflect only the shipments of NEMA members, DOE increases these estimates to account for the volume of ballasts that nonNEMA companies import or manufacture. Based on ballast manufactur er interviews and conservative estimates, NEMA sh ipments were assumed to account for 50–90 percent of total ballast shipments, depending on the ballast design. Table 9.3.1 provides historical fluorescent ballast shipments estimates for the entire U.S. market.

Table 9.3.1. Total Historical Fluorescent Ballast Shipments (millions)

Year 4-Foot

T8

MBP 4-Foot

T12

MBP 8-Foot

T8

Slimline 8-Foot

T12

Slimline 8-Foot T8

RDC HO 8-Foot T12

RDC HO 4-Foot T5

MiniBP SO 4-Foot T5

MiniBP HO Total

1990 11.3 7.6 0.1 1.0 0.1 3.1 0.0 0.0 23.2

1991 24.6 8.7 0.2 1.0 0.1 3.1 0.0 0.0 37.8

1992 36.3 9.3 0.4 1.0 0.1 3.5 0.0 0.0 50.5

1993 58.4 9.3 0.7 0.9 0.1 3.6 0.0 0.0 73.0

1994 51.9 7.9 0.6 0.9 0.1 3.7 0.0 0.0 65.0

1995 70.5 6.7 1.0 0.9 0.1 3.8 0.0 0.0 83.1

1996 67.2 6.1 0.9 0.9 0.1 3.5 0.0 0.0 78.7

1997 79.3 6.3 1.1 0.7 0.1 3.2 0.0 0.0 90.7

1998 85.8 6.1 1.1 0.7 0.1 2.8 0.0 0.0 96.4

1999 88.6 6.1 1.1 0.6 0.1 3.7 0.0 0.0 100.2

2000 99.8 5.8 1.3 0.6 0.1 3.2 0.0 0.0 110.9

2001 116.1 5.4 1.7 0.6 0.1 3.1 0.0 0.0 127.1

2002 118.8 5.2 1.7 0.6 0.1 3.2 0.9 0.9 131.5

2003 116.4 3.9 1.4 0.5 0.1 3.2 1.9 1.9 129.3

2004 118.6 2.7 1.3 0.5 0.1 3.2 3.2 3.2 133.0

2005 114.4 1.3 1.4 0.5 0.1 3.3 3.4 3.4 127.8

9-9

### 9.3.2.2 Calculation of Installed Stock in 2006

Based on historical ballast shipments estimated from U.S. Census Bureau CIR data, DOE calculates the 2006 ballast stock. In a mature market, DOE typically estimates the installed stock at the beginning of an analysis period by summing the historical shipments for the years that correspond to the service lifetime ( i.e. , the lifetime in hours divided by operating hours per year) of each ballast type for every sector.

However, the historical ballasts shipment data Table 9.3.1 reflect a remarkable 450 percent growth over 15 years, from 23.2 milli on ballasts in 1990 to 127.8 million ballasts in

2005. In the absence of clear data on historical ba llasts stock, DOE judged that this very strong growth in ballasts shipments was unlikely to re flect equivalent growth in ballasts stock, and would likely not persist through 2044. Rather, DO E assumed that some portion of this very strong growth in shipment was likely due to early retirement of ballasts, consistent with the development of several improved ballasts technolog ies in the 1990–2005 period.

DOE conservatively assumed that the historical stock of ballasts actually grew by only 2 percent over the period 1990–2005 (Table 9.3.2) and th at the remainder of the strong growth in fluorescent lamp ballasts shipment s was due to technology-induced retrofits. Accordingly, DOE

calculates the installed stock in 2006 as the estimate d share of historical shipments that are not due to technology-induced retrofits. DOE then extr apolated an adjusted shipments estimate by taking the difference between the 1990–2005 shipment s growth rates and th e assumed 2 percent growth rate of historical stock.

Table 9.3.2. Historical Fluorescent Ballast Shipments by Estimated Life Event (millions)

Year Total

Historical
Shipments Historical
Shipments

Growth Rate Assumed

Historical Stock

Growth Rate Estimated Number of
Early Retirement
Shipments Adjusted
Shipments

Estimate

1990 23.2 (unknown) (unknown) (unknown) 23.2

1991 37.8 63% 2% 14.1 23.7

1992 50.5 34% 2% 12.0 38.5

1993 73.0 45% 2% 33.7 39.3

1994 65.0 -11% 2% 24.9 40.1

1995 83.1 28% 2% 42.2 40.9

1996 78.7 -5% 2% 37.0 41.7

1997 90.7 15% 2% 48.1 42.5

1998 96.4 6% 2% 53.0 43.4

1999 100.2 4% 2% 56.0 44.3

2000 110.9 11% 2% 65.7 45.1

2001 127.1 15% 2% 81.0 46.0

2002 131.5 3% 2% 84.5 47.0

2003 129.3 -2% 2% 81.4 47.9

2004 133.0 3% 2% 84.1 48.9

2005 127.8 -4% 2% 78.0 49.8

9-10

### DOE then produced stock estimates by summing backwards from 2005 and applying ballast product lif etimes to this adjusted shipments es timate. To accurately forecast ballast shipments, DOE assumed a ballast age distribution fo r the installed ballast stocks using trends in ballast shipments, calibrated to the available shipment data. Tabl e 9.3.3 provides ballast stocks in 2006 for all analyzed ballast types.

Table 9.3.3. 2006 Ballast Stocks (millions)

System Type 4-Foot

T8

MBP 4-Foot

T12

MBP 8-Foot

T8

Slimline 8-Foot

T12

Slimline 8-Foot T8

RDC HO 8-Foot

T12 RDC

HO 4-Foot

T5

MiniBP

SO 4-Foot

T5

MiniBP

HO

Stock 1,131 73 15 9 1 38 12 10 First year of service 46 2 1 0 0 3 2 1 Halfway through

service lifetime 82 6 1 1 0 3 0 0

Last year of service 0 0 0 0 0 2 0 0



### 9.3.2.3 Base-Case Market-Share Apportionment

As discussed in the engineering analysis (preliminary TSD chapter 5) and the LCC and PBP analyses (preliminary TSD chapter 8), consumers have a variety of choices in replacement ballasts and lamp-and-ballast syst ems. When choosing lighting systems, consumers often make their choices considering attributes such as lifetime, efficiency, price, lumen output, rated wattage, and total system power. DOE captures these considerations by designing product classes which account for these consumer prefer ences. As discussed earlier, the shipments for ballasts depend on such input assumptions as ballast lifetime and system lumen output. In addition, other ballast or lamp-and-ballast sy stem properties such as price and energy consumption are key inputs to the NES and NP V calculations. Therefore, within each product class, DOE believes it is necessary to directly ac count for the mix of technologies that consumers

select in the base and standards case. To acc ount for the range of po ssible consumer choices, DOE develops technology market-s hare apportionments. These ma rket-share apportionments are used to estimate historical shipments and installed stock for each ballast design in the base andstandards case. As discussed in the NIA (preliminary TSD chapter 10), the base- and standardscase efficiency forecasts also depend on the market-share apportionments.

DOE was not able to obtain de tailed historical ballast shipment data from NEMA to develop percentage market shares for the an alyzed ballast designs. However, based on manufacturer interviews, DOE was able to develop a general a ssumed market-share apportionment based on shipments of 4-foot T8 MBP electronic ballasts. Interviewed manufacturers provided estimated percentages of standard-efficiency and high-efficiency T8 ballasts sold through OEM fixture and electrical wholesaler distribution channels. As presented in Table 9.3.4, DOE developed weighted apporti onments for the two efficiency levels. Specifically, DOE assumes that 69 percent of sh ipped 4-foot T8 MBP electronic ballasts are standard-efficiency designs, and 31 perc ent are high-efficiency designs.

9-11

### Table 9.3.4. Weighted Apportionments for Standard- and High-Efficiency 4-Foot T8 MBP

Ballasts

Ballast Efficiency Shipments through Distribution Channel

%

Fixture OEM Electrical Whol esaler Weighted Average

Standard 80 50 69 High20 50 31 Overall volume through

distribution channel * 63 37 100

* Pecentages from the 2000 Ballast Rule.



### DOE believes that this apportionment is a reasonable estimate for the other ballast product classes analyzed in the base-case shipment s model, as it reflects the assumed tendency of

most consumers to minimize their first cost a nd select standard-effici ency designs if not otherwise required. Consequently, for each produ ct class in the base case, DOE apportions 69 percent of shipments to the baseline ballast de sign, and divides the remaining 31 percent of shipments ( i.e. , the high-efficiency apportionment) evenly among the CSL designs. Error!

Reference source not found. through Table 9.3.18 illustrate the base-case market-share apportionments for ballast desi gns in each product class.

Table 9.3.5. Base-Case Initial Market-Share Ap portionments for Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-F oot U-Shaped Lamps (F34T8 Baseline)

CSL For Operation Of Ballast Efficacy Factor (BEF) Stock in 2015

%

Baseline* 2 F32T8 Lamps 1.450 69

1 2 F32T8 Lamps 1.528 16

2 2 F32T8 Lamps 1.548 16

* Baseline meets CSL1 efficacy requirements in this product category.



### Table 9.3.6. Base-Case Initial Market-Share Ap portionments for Two-Lamp PS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps

CSL For Operation Of BEF Stock in 2015

%

Baseline 2 F32T8 Lamps 1.424 69

1 2 F32T8 Lamps 1.515 31



### Table 9.3.7. Base-Case Initial Market-Share Ap portionments for Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps (F34T12 Baseline)

CSL For Operation Of BEF Stock in 2015

%

Baseline 2 F34T12 Lamps 1.359 69

1 2 F32T8 Lamps 1.450 10

2 2 F32T8 Lamps 1.528 10

3 2 F32T8 Lamps 1.548 10

9-12

### Table 9.3.8. Base-Case Initial Market-Share Ap portionments for Four-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps

CSL For Operation Of BEF Stock in 2015

%

Baseline 4 F32T8 Lamps 0.751 69

1 4 F32T8 Lamps 0.757 31



### Table 9.3.9. Base-Case Initial Market-Share Ap portionments for Four-Lamp PS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps

CSL For Operation Of BEF Stock in 2015

%

Baseline 4 F32T8 Lamps 0.719 69

1 4 F32T8 Lamps 0.758 31



### Table 9.3.10. Base-Case Initial Market-Share A pportionments for Two-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps (F96T12HO/ES Baseline)

CSL For Operation Of BEF Stock in 2015

%

Baseline 2 F96T12ES/HO Lamps 0.422 69

1 2 F96T12ES/HO Lamps 0.500 10

2 2 F96T8HO Lamps 0.550 10

3 2 F96T8HO Lamps 0.563 10



### Table 9.3.11. Base-Case Initial Market-Share A pportionments for Two-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps (F96T8HO Baseline)

CSL For Operation Of BEF Stock in 2015

%

Baseline * 2 F96T8HO Lamps 0.550 69

1 2 F96T8HO Lamps 0.563 31

* Baseline meets CSL1 efficacy requirements in this product category.



### Table 9.3.12. Base-Case Initial Market-Share A pportionments for Two-Lamp IS Ballasts Operating 8-Foot Slimline Lamps (F96T12/ES Baseline)

CSL For Operation Of BEF Stock in 2015

%

Baseline 2 F96T12ES Lamps 0.797 69

1 2 F96T12ES Lamps 0.807 31



### Table 9.3.13. Base-Case Initial Market-Share A pportionments for Two-Lamp IS Ballasts Operating 8-Foot Slimline Lamps (F96T8 Baseline)

CSL For Operation Of BEF Stock in 2015

%

Baseline 2 F96T8 Lamps 0.789 69

1 2 F96T8 Lamps 0.810 31

9-13

### Table 9.3.14. Base-Case Initial Market-Share A pportionments for Two-Lamp PS Ballasts Operating 4-Foot T5 MiniBP SO Lamps

CSL For Operation Of BEF Stock in 2015

%

Baseline 2 F28T5 Lamps 1.309 69

1 2 F28T5 Lamps 1.570 16

2 2 F28T5 Lamps 1.624 16



### Table 9.3.15. Base-Case Initial Market-Share A pportionments for Two-Lamp PS Ballasts Operating 4-Foot T5 MiniBP HO Lamps

CSL For Operation Of BEF Stock in 2015

%

Baseline 2 F54T5HO Lamps 0.688 69

1 2 F54T5HO Lamps 0.791 16

2 2 F54T5HO Lamps 0.829 16



### Table 9.3.16. Base-Case Initial Market-Share A pportionments for Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps (Low Power Factor, F34T12 Baseline)

CSL For Operation Of BEF Stock in 2015

%

Baseline 2 F34T12 Lamps 1.277 69

1 2 F32T8 Lamps 1.470 16

2 2 F32T8 Lamps 1.505 16



### Table 9.3.17. Base-Case Initial Market-Share A pportionments for Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps (Low Power Factor, F34T8 Baseline)

CSL For Operation Of BEF Stock in 2015

%

Baseline* 2 F32T8 Lamps 1.470 69

1 2 F32T8 Lamps 1.505 31

* Baseline meets CSL1 efficacy requirements in this product category.



### Table 9.3.18. Base-Case Initial Market-Share A pportionments for Four-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps (Cold Temperature/Sign Ballasts)

CSL For Operation Of BEF Stock in 2015

%

Baseline 4 F96T12HO Lamps 0.167 69

1 4 F96T12HO Lamps 0.250 31



### 9.3.2.4 Base-Case Forecast Results

Figure 9.3.1 through Figure 9.3.48 present the ba se-case ballast shipments forecasts from
2014–2044, modeled from the 2006 installed stock (based on 1990–2005 historical shipments) and growth rates as explained in section 9.2.1.2.

9-14

### Because DOE forecasts lower future growth rates in the ballast marketplace than are evidenced in historical shipments, replacements of initial stock make up a relatively large share
of the total number of ballasts shipments in DOE’s forecast. Therefore as the initial stock of

ballasts reach the end of thei r lifetime and are replaced, a surge in replacement shipments emerges that mimics the shape of the initial growth in the industry. This pattern is repeated throughout the analysis period as subsequent generations of replacement ballasts also reach the
ends of their lifetimes and are in turn replaced. This would be even more dramatic if DOE did not adjust for technology-induced re trofits as explained in section Error! Reference source not

found. 9.3.2.2. This cyclical pattern in shipments also reflects DOE assumptions about the

distribution of ballast lifetime s (section 9.2.1.1). Also note that shipments of T12 ballasts are near zero during the analysis period because th ey are being substituted by T8 ballasts.

For categories of ballasts expected to ex perience penetration by LED lamps and other emerging technologies (4-foot MBP category, a nd the combined 4-foot T5 MiniBP SO and HO categories), separate shipments forecasts are presented in this section for the existing and emerging technologies scenarios. For other ba llast categories, only one forecast is provided which corresponds to the existing and emerging technologies base cases.Shipments 100,000,000

90,000,000

80,000,000

70,000,000

60,000,000

50,000,000

40,000,000

30,000,000

20,000,000

10,000,000

0

2014 2019 2024 2029 2034 2039 2044

Year

4-foot T8 MBP Base-Case Existing Tech Forecast

4-foot T12 MBP Base-Case Existing Tech Forecast

4-foot T8 MBP Base-Case Emerging Tech Forecast

4-foot T12 MBP Base-Case Emerging Tech Forecast



### Figure 9.3.1. 4-Foot MBP Base-Case Forecasted Ballast Shipments (Existing and Emerging
Technologies Scenarios)

9-15

### 0 50,000 100,000 150,000 200,000 250,000 300,000 350,000Shipments



### 2014 2019 2024 2029 2034 2039 2044

Year

8-foot T8 RDC HO Base-Case Forecast 8-foot T12 RDC HO Base-Case Forecast



### Figure 9.3.2 8-Foot RDC HO Base-Case Foreca sted Ballast Shipments (Existing and
Emerging Technologies Scenario s, Excluding Sign Ballasts)

2,500,000

2,000,000Shipments



### 0

2014 2019 2024 2029 2034 2039 2044 1,500,000

1,000,000

500,000

Year

8-foot T8 Slimline Base-Case Forecast 8-foot T12 Slimline Base-Case Forecast



### Figure 9.3.3. 8-Foot Slimline Base-Case Foreca sted Ballast Shipments (Existing and
Emerging Technology Scenarios)

9-160 5,000,000 10,000,000 15,000,000 20,000,000 25,000,000 30,000,000 35,000,000 40,000,000 45,000,000Shipments

2014 2019 2024 2029 2034 2039 2044

Year

4-foot T5 MiniBP SO Base-Case Existing Tech Forecast

4-foot T5 MiniBP SO Base-Case Emerging Tech Forecast

4-foot T5 MiniBP HO Base-Case Existing Tech Forecast



### Figure 9.3.4. 4-Foot MiniBP SO and HO Base-Cas e Forecasted Ballast Shipments (Existing
and Emerging Technologies Scenarios)

35,000,000

30,000,000Shipments 

### 25,000,000

20,000,000

15,000,000

10,000,000

5,000,000

Year 0

2014 2019 2024 2029 2034 2039 2044

4-foot T8 MBP Base-Case Forecast 4-foot T12 MBP Base-Case Forecast



### Figure 9.3.5. Base-Case Forecasted Shipments for Ballasts Operating 4-Foot MBP Lamps

in the Residential Sector (Existing and Emerging T echnologies Scenarios)

9-17Shipments



### 0 1,000,000 2,000,000 3,000,000 4,000,000 5,000,000 6,000,000

2014 2019 2024 2029 2034 2039 2044

Year

8-foot T12 HO Base-Case Forecast



### Figure 9.3.6. Base-Case Forecasted Shipments fo r Sign Ballasts Operating 8-Foot RDC HO
Lamps

9.3.2.5 Base-Case Forecast by Market Segment

Figure 9.3.7 through Figure 9.3.10 present the base-case ballast shipments forecast by market segment ( i.e. , ballast failure/replacement, or new construction/renovation) for 4-foot MBP systems, 8-foot RDC HO systems, 8-foot slimline systems, and 4-foot T5 MiniBP systems, respectively. For all four of these categories, shipments of replacements dominate shipments

related to new constr uction/renovation over the analysis period. As noted in section 9.3.2.4, shipments driven by ballast failure/replacement exhibit a cyclical pattern that is not present in shipments driven by new cons truction/renovation. Note that 8-foot slimline ballasts are only shipped for replacement (Figure 9.3.9). They ar e substituted in the new construction by T5 ballast systems. The figures below are for the existing technologies scenario.

9-180.00 0.02 0.04 0.06 0.08 0.10 0.12 0.14Shipments (billions) New Construction Ballast Replacement

Year



### Figure 9.3.7. 4-Foot MBP Base-Case Ballast Shipments Forecast by Market Segment

0.0000 0.0010 0.0020 0.0030 0.0040 0.0050 0.0060Shipments (billions) New Construction Ballast Replacement

Year



### Figure 9.3.8. 8-Foot RDC HO Base-Case Ballast Shipments Forecast by Market Segment

9-190.0000 0.0005 0.0010 0.0015 0.0020 0.0025Shipments (billions) New Construction Ballast Replacement

Year



### Figure 9.3.9. 8-Foot Slimline Base-Case Ballast Shipments Forecast by Market Segment

0.0000 0.0050 0.0100 0.0150 0.0200 0.0250Shipments (billions) New Construction Ballast Replacement

Year



### Figure 9.3.10. 4-Foot MiniBP SO and HO Ballast Shipments Forecast by Market Segment

9-20

### 9.4 STANDARDS-CASE INPUTS

9.4.1 Shipments Scenarios

To characterize consumer behavior in the standards case, DOE considers many

characteristics that consumers ta ke into account when purchasing their lamp-and-ballast systems. Specifically, DOE regards system price, system energy consumption, and system lumen output as three key drivers of consumer purchases.

DOE develops two sets of two shipments scen arios to characterize consumers that may weigh these factors differently. To evaluate a standards case, DOE models a standards-case scenario and compares it to the base case.

The first set of standards-case scenarios for ballasts includes the roll-up and shift scenarios. The roll-up scenario represents a standa rds case in which all product efficiencies in the

base case that do not meet the standard would ro ll up to meet the new standard level. Consumers in the base-case purchase ballasts above the standard level are not affected as they are assumed to continue to purchase the same base-case ba llast or lamp-and-ballast system in the roll-up scenario. The roll-up scenario characterizes consum ers primarily driven by the first-cost of theanalyzed equipment. In a roll-up scenario, DOE assumes consumers will buy the first standardcompliant lamp-and-ballast system available. In contrast, in a shift scenario, DOE assumes consumers seek to shift to an efficiency level that keeps their purchase the same number of efficiency levels above the baseline as in the base case. The shift scenario models a standardscase in which all base-case consumer purchases are affected by the standard (whether their basecase efficiency is below the standard). In this scenario, any consumer may purchase a more efficient ballast. As the standard level increases, market share incrementally accumulates at the highest CSL because it represents “max tech” ( i.e. , moving beyond it is impossible given available technology options). The shift scenario characterizes consumer s primarily concerned with system energy consumption, and reflects an upper bound scenario.

In either the roll-up or shift scenario consumers will attempt to buy a ballast from the same product class as their pr eviously demanded system except where additional replacement trends are modeled (as given in Table 9.2.2). The stru cture of these product classes is such that at each CSL level lumen output is within 10 percent of the baseline system’s lumen output.

Each of these pairs of scenarios (roll-up and shift) occurs in combination with the existing and emerging technologies scenarios from the base case, for a total of four standardscase scenarios.

Many tables for the shipments analysis and the NIA (preliminary TSD chapter 10) present only two of the four possible shipme nts scenarios: existing technology/shift and emerging technology/roll-up. These scenarios are presented because they represent the upper and lower bound scenarios for the energy impacts of this rulemaking, respectively.

For its analysis, DOE evaluated the principa l events that prompt ballast purchases: (1) ballast failure/replacemen t; and (2) new construction/re novation. DOE assumed that all replacement ballast shipments were due to ballast failure, and all new ballast shipments were

considered renovation or new construction.

9-21

### 9.5 RESULTS

The following sections show the shipments fo recasts for the various efficiency levels over time and by shipments scenario. DOE’s forecasts of the resultant stock forecasts for the various efficiency levels over time and by scen ario are presented in preliminary TSD chapter 10.

Figure 9.5.1 through Figure 9.5.8 present the ship ments forecasts for the base case and standards-cases for ballasts in the existing tec hnologies/shift and the emerging technologies/roll

up scenarios scenario. As noted, these reflect the upper- and lower-bound scenarios for energy use. For the standards case, shipments are show n at what they are modeled as in the CSL 3

scenario. Please note that if the line does not s how up on the graph, it means that the values for this CSL are zeros or very close to zeros during the entire analysis period.

Quantities of ballast shipments depend on the occurrence of the ballast purchasing events: ballast failure/replacement, a nd new construction/renovation. As discussed earlier, instead of using each particular ballast design’s individua l lifetime to time ballast replacements, DOE uses the same ballast lifetime assumptions for all ballast designs within a given sector. For this reason, the rate of ballast replacement does not ch ange between different shipments scenarios.Shipments (billions) 0.06

0.05

0.04

0.03

0.02

0.01

0.00

-0.01 2014 2018 2022 2026 2030 2034 2038 2042

Year

4-foot T8 MBP CSL0 4-foot T8 MBP CSL1 4-foot T8 MBP CSL2

4-foot T8 MBP CSL3 4-foot T12 MBP CSL0



### Figure 9.5.1. 4-Foot MBP Base Case and Standards-Case Ballast Shipments Forecasts
(Emerging Technologies, Roll-Up Scenario)

9-220.06

0.05

0.04

0.03

0.02

0.01

0.00

2014 2018 2022 2026 2030 2034 2038 2042

YearShipments (billions)

-0.01

4-foot T8 MBP CSL0 4-foot T8 MBP CSL1 4-foot T8 MBP CSL2

4-foot T8 MBP CSL3 4-foot T12 MBP CSL0



### Figure 9.5.2. 4-Foot MBP Base Case and Standards-Case Ballast Shipments Forecasts
(Existing Technologi es, Shift Scenario)

0.01

0.01

2014 2018 2022 2026 2030 2034 2038 2042Shipments (billions)

0.00

0.00

0.00

0.00

0.00

Year

8-foot T8 MBP CSL0 8-foot T8 MBP CSL1 8-f oot T8 MBP CSL2

8-foot T8 MBP CSL3 8-foot T12 MBP CSL0 4-f oot T12 MBP CSL1



### Figure 9.5.3. 8-Foot RDC HO (including Cold Temperature/Sign) Base Case and
Standards-Case Ballast Shipments Forecasts (Existing Technologies, Shift Scenario)

9-230.01

0.01

0.00

0.00

0.00

0.00

0.00

Year 2014 2018 2022 2026 2030 2034 2038 2042Shipments (billions)

8-foot T8 MBP CSL0 8-foot T8 MBP CSL1 8-foot T8 MBP CSL2

8-foot T8 MBP CSL3 8-foot T12 MBP CSL0 4-foot T12 MBP CSL1



### Figure 9.5.4. 8-Foot RDC HO (including Cold Temperature/Sign) Base Case and
Standards-Case Ballast Shipments Forecasts (Emerging Technologies, Roll-Up Scenario)

0.00

0.00

2014 2018 2022 2026 2030 2034 2038 2042

YearShipments (billions)

0.00

0.00

0.00

0.00

0.00

8-foot T8 Slimline CSL0 8-foot T8 Slimline CSL1

8-foot T12 Slimline CSL0 4-foot T12 Slimline CSL1



### Figure 9.5.5. 8-Foot Slimline Base Case and St andards-Case Ballast Shipments Forecasts
(Existing Technologi es, Shift Scenario)

9-240.00

0.00

0.00

0.00

0.00

0.00

2014 2018 2022 2026 2030 2034 2038 2042

YearShipments (billions)

0.00

8-foot T8 Slimline CSL0 8-foot T8 Slimline CSL1

8-foot T12 Slimline CSL0 4-foot T12 Slimline CSL1



### Figure 9.5.6. 8-Foot Slimline Base Case and St andards-Case Ballast Shipments Forecasts
(Emerging Technologies, Roll-Up Scenario)

0.02

0.01

0.01

0.01

0.01

0.01

0.00

0.00

0.00

0.00 2014 2018 2022 2026 2030 2034 2038 2042Shipments (billions)

Year

4-foot T5 Mini-Bipin SO CSL0 4-foot T5 Mini-Bipin SO CSL1

4-foot T5 Mini-Bipin HO CSL0 4-foot T5 Mini-Bipin HO CSL1

4-foot T5 Mini-Bipin HO CSL2 4-foot T5 Mini-Bipin SO CSL2



### Figure 9.5.7. 4-Foot MiniBP SO and HO Base Ca se and Standards-Case Ballast Shipments
Forecasts (Existing Techno logies, Shift Scenario)

9-25Shipments (billions) 0.02

0.01

0.01

0.01

0.01

0.01

0.00

0.00

0.00

0.00 2014 2018 2022 2026 2030 2034 2038 2042

Year

4-foot T5 Mini-Bipin SO CSL0 4-foot T5 Mini-Bipin SO CSL1

4-foot T5 Mini-Bipin HO CSL0 4-foot T5 Mini-Bipin HO CSL1

4-foot T5 Mini-Bipin HO CSL2 4-foot T5 Mini-Bipin SO CSL2



### Figure 9.5.8. 4-Foot MiniBP SO and HO Base Ca se and Standards-Case Ballast Shipments
Forecasts (Emerging Technologies, Roll-Up Scenario)

Cumulative Shipments Impacts (2014–2044)

Table 9.5.1 and Table 9.5.2 show the cumulative shipments impacts caused by each of
the three standards-cases out to 2044 for each of the four shipments scenarios. As discussed earlier, quantities of ballast ship ments in the standards-case are based on ballast replacement rates and shipments due to new construction/renovation. However, because all ballasts within a particular product class are assumed to have the same lifetime, ballast replacement rates in the base case and standards-case are equal. In addition, because the ballast lifetime never varies within a particular market sector, ballast replacement rates are equal in the base case and standards case. The only aspects that do vary are th e distribution of ballasts by efficiency levels.

Note that cumulative shipments impacts are different from impacts on the stock, because of ballast replacements over time. Impacts on the efficiency distributions in the ballast stock are addressed in the preliminary TSD chapter 10.

Table 9.5.1. Cumulative Ballast Shipments Impacts by Standard Level, 2014–2044
(Existing Technologi es, Shift Scenario)

CSL Ballast Product Class Standard Shipment Impacts

CSL

1 2 3

0 Two-Lamp Normal BF 4-Foot MBP PS -217,105,127 -217,105,127 -217,105,127 Two-Lamp Normal BF 4-Foot MBP IS & RS 0 0 0 Four-Lamp Normal BF 4-Foot MBP IS & RS -423,063,218 -423,063,218 -423,063,218

9-26Four-Lamp Normal BF 4-Foot MBP PS -116,902,758 -116,902,758 -116,902,758 Two-Lamp Normal BF 8-Foot RDC HO IS & RS -318,775 -318,775 -318,775 Two-Lamp Normal BF 8-Foot SP Slimline -342,825 -342,825 -342,825 Two-Lamp Normal BF 8-Foot SP Slimline (T8 Baseline) -36,304,615 -36,304,615 -36,304,615 Two-Lamp Normal BF 4-Foot T5 MiniBP SO -538,125,468 -538,125,468 -538,125,468 Two-Lamp 4-Foot T5 MiniBP HO -92,905,672 -92,905,672 -92,905,672 Two-Lamp Low BF 4-Foot MBP IS & RS Residential -3,437,714 -3,437,714 -3,437,714 Four-Lamp Sign Ballasts -117,590,619 -117,590,619 -117,590,619

TOTAL -1,546,096,790 -1,546,096,790 -1,546,096,790

1 Two-Lamp Normal BF 4-Foot MBP PS 217,105,127 217,105,127 217,105,127 Two-Lamp Normal BF 4-Foot MBP IS & RS -1,013,693,094 -1,013,693,094 -1,013,693,094 Four-Lamp Normal BF 4-Foot MBP IS & RS 423,063,217 423,063,218 423,063,218 Four-Lamp Normal BF 4-Foot MBP PS 116,902,765 116,902,762 116,902,762 Two-Lamp Normal BF 8-Foot RDC HO IS & RS 271,036 -47,739 -47,739 Two-Lamp Normal BF 8-Foot SP Slimline 342,825 342,825 342,825 Two-Lamp Normal BF 8-Foot SP Slimline (T8 Baseline) 36,304,615 36,304,615 36,304,615 Two-Lamp Normal BF 4-Foot T5 MiniBP SO 136,570,912 -120,883,258 -120,883,258 Two-Lamp 4-Foot T5 MiniBP HO 202,223 -20,870,114 -20,870,114 Two-Lamp Low BF 4-Foot MBP IS & RS Residential -827,525,945 -830,634,822 -830,634,822 Four-Lamp Sign Ballasts 117,590,620 117,590,620 117,590,620

TOTAL -792,865,698 -1,074,819,861 -1,074,819,861

2 Two-Lamp Normal BF 4-Foot MBP IS & RS 204,349,502 -216,731,594 -216,731,594 Two-Lamp Normal BF 8-Foot RDC HO IS & RS -1,012,509 -741,473 -741,473 Two-Lamp Normal BF 4-Foot T5 MiniBP SO 401,554,558 659,008,720 659,008,720 Two-Lamp 4-Foot T5 MiniBP HO 92,703,449 113,775,784 113,775,784 Two-Lamp Low BF 4-Foot MBP IS & RS Residential 831,935,314 835,044,191 835,044,191

TOTAL 1,529,530,314 1,390,355,627 1,390,355,627

3 Four-Lamp Normal BF 4-Foot MBP IS & RS 809,343,605 1,230,424,702 1,230,424,702 Two-Lamp Normal BF 8-Foot RDC HO IS & RS 1,060,249 1,107,988 1,426,763

TOTAL 810,403,853 1,231,532,689 1,231,851,465



### Table 9.5.2. Cumulative Ballast Shipments Impacts by Standard Level, 2014–2044
(Emerging Technologies, Roll-up Scenario)

CSL Ballast Product Class Standard Shipment Impacts

CSL

1 2 3

0 Two-Lamp Normal BF 4-Foot MBP PS -97,938,297 -97,938,297 -97,938,297 Two-Lamp Normal BF 4-Foot MBP IS & RS 0 0 0 Four-Lamp Normal BF 4-Foot MBP IS & RS -236,307,640 -236,307,640 -236,307,640 Four-Lamp Normal BF 4-Foot MBP PS -52,736,006 -52,736,006 -52,736,006 Two-Lamp Normal BF 8-Foot RDC HO IS & RS -318,775 -318,775 -318,775 Two-Lamp Normal BF 8-Foot SP Slimline -342,825 -342,825 -342,825 Two-Lamp Normal BF 8-Foot SP Slimline (T8 Baseline) -36,304,615 -36,304,615 -36,304,615 Two-Lamp Normal BF 4- Foot T5 MiniBP SO -252,219,545 -252,219,545 -252,219,544 Two-Lamp 4-Foot T5 MiniBP HO -92,905,672 -92,905,672 -92,905,672 Two-Lamp Low BF 4-Foot MBP IS & RS Residential -3,437,714 -3,437,714 -3,437,714 Four-Lamp Sign Ballasts -117,590,619 -117,590,619 -117,590,619

TOTAL -890,101,708 -890,101,708 -890,101,707

1 Two-Lamp Normal BF 4-Foot MBP PS 97,938,298 97,938,297 97,938,297 Two-Lamp Normal BF 4-Foot MBP IS & RS 0 -564,983,181 -564,983,181 Four-Lamp Normal BF 4-Foot MBP IS & RS 236,307,634 236,307,634 236,307,634 Four-Lamp Normal BF 4-Foot MBP PS 52,736,005 52,736,005 52,736,005 Two-Lamp Normal BF 8-Foot RDC HO IS & RS 159,388 -47,739 -47,739 Two-Lamp Normal BF 8-Foot SP Slimline 342,825 342,825 342,825

9-27Two-Lamp Normal BF 8-Foot SP Slimline (T8 Baseline) 36,304,615 36,304,615 36,304,615 Two-Lamp Normal BF 4- Foot T5 MiniBP SO 252,219,540 -56,658,014 -56,658,014 Two-Lamp 4-Foot T5 MiniBP HO 92,905,669 -20,870,114 -20,870,114 Two-Lamp Low BF 4-Foot MBP IS & RS Residential 4,409,369 -830,634,822 -830,634,822 Four-Lamp Sign Ballasts 117,590,620 117,590,620 117,590,620

TOTAL 890,913,963 -931,973,874 -931,973,874

2 Two-Lamp Normal BF 4-Foot MBP IS & RS 0 564,983,175 -121,014,844 Two-Lamp Normal BF 8-Foot RDC HO IS & RS 159,388 -1,060,248 -1,060,248 Two-Lamp Normal BF 4- Foot T5 MiniBP SO 0 308,877,552 308,877,552 Two-Lamp 4-Foot T5 MiniBP HO 0 113,775,784 113,775,784 Two-Lamp Low BF 4-Foot MBP IS & RS Residential 0 835,044,191 835,044,191

TOTAL 159,388 1,821,620,453 1,135,622,434

3 Four-Lamp Normal BF 4-Foot MBP IS & RS 0 0 685,998,015 Two-Lamp Normal BF 8-Foot RDC HO IS & RS 0 1,426,763 1,426,763

TOTAL 0 1,426,763 687,424,778

9-28

### REFERENCES

1. U.S. Department of Energy–E nergy Information Administration. Annual Energy Outlook 2009 with Projections to 2030 . March 2009.

< http://www.eia.doe.gov/oiaf/aeo/aeoref_tab.html >.

2. U.S. Department of Energy, Energy Information Administration. Annual Energy Outlook 2009 with Projections to 2030 . Updated Reference case. April 2009. Washington, D.C.

< http://www.eia.doe.gov/oiaf/se rvicerpt/stimulus/aeostim.html >.

3. U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Multi-Year Program Plan FY’09 to FY’14: Solid-State Lighting Research and Development. Washington, D.C.

< http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/ssl_mypp2008_web.pdf >.

4. U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Building Technologies Program: Notice of Proposed Rulemaking (NOPR) Technical Support Document (TSD): Energy Conservation Sta ndards for General Service Fluorescent Lamps and Incandescent Reflector Lamps. January, 2009. Washington, D.C.

< http://www1.eere.energy.gov/buildings/applianc e_standards/residen tial/incandescent_lamps _nopr_tsd.html >

5. U.S. Census Bureau. Current Industrial Reports, Fluorescent Lamp Ballasts: 2005. July 2006. Washington, D.C. < http://www.census.gov/industry/1/mq335c055.pdf >.

6. U.S. Census Bureau. Current Industrial Reports, Fluorescent Lamp Ballasts (individual annual reports for 1990-1996). MQ36C(90)-5 through MQ36C(96)-5. Washington, D.C.

9-29

### CHAPTER 10. NATIONAL IMPACTS ANALYSIS

TABLE OF CONTENTS

10.1 INTRODUCTION

............................................................................................................. 10-1

10.2 BASE-CASE AND STANDARDS-CASE FORECASTED EFFICIENCY DISTRIBUTIONS, BALLAST STOCKS, AND AVERAGE EFFICIENCY

.................. 10-1

10.2.1 Base and Standards Case E fficiency Distributions

............................................ 10-2

10.2.2 Installed Ballast Stock

..................................................................................... 10-13

10.2.3 Average Ballast Efficien cy in the Stock

.......................................................... 10-16

10.3 NATIONAL ENERGY SAVINGS

................................................................................. 10-27

10.3.1 National Energy Savings Definition

................................................................ 10-27

10.3.2 National Energy Savings Inputs

...................................................................... 10-28

10.3.2.1 Unit Energy Consumption (UEC)

..................................................... 10-28

10.3.2.2 Ballast Stock

..................................................................................... 10-28

10.3.2.3 Site-to-Source Conversion Factors

................................................... 10-28

10.3.2.4 Interactions with Heating, Ve ntilation, and Air-Conditioning (HVAC) Systems

.............................................................................. 10-29

10.3.2.5 Rebound Rate

.................................................................................... 10-29

10.4 NET PRESENT VALUE

................................................................................................ 10-30

10.4.1 Net Present Value Definition

........................................................................... 10-30

10.4.2 Net Present Value Inputs

................................................................................. 10-31

10.4.2.1 Total Annual Installed Cost Increases

.............................................. 10-31

10.4.2.2 Total Annual Operating Cost Savings

.............................................. 10-31

10.4.2.3 Discount Factor

................................................................................. 10-32

10.5 NATIONAL ENERGY SAVINGS AND NET PRESENT VALUE RESULTS

........... 10-32

10.5.1 National Energy Savings and Net Present Value Input Summary

.................. 10-32

10.5.2 National Energy Savings Results

.................................................................... 10-33

10.5.3 Net Present Value Analysis

............................................................................. 10-35

10.5.4 Net Present Value Results

............................................................................... 10-41

LIST OF TABLES

Table 10.2.1. Ballasts Operating 4- Foot Medium Bipin (MBP) Lamps (Residential), Base Case and Standards Case Efficiency Dist ributions (Existing Technologies, Shift Scenario)

...................................................................................................................... .. 10-3 Table 10.2.2. Ballasts Operating 4-Foot MBP Lamps (Residential) , Base Case and Standards Case Efficiency Distributi ons (Existing Technologies, Roll-Up Scenario)

...................................................................................................................... .. 10-4 Table 10.2.3. Ballasts Operating 4-Foot MBP Lamps (Residential) , Base Case and Standards Case Efficiency Distributions (E merging Technologies, Shift Scenario)

..... 10-4 Table 10.2.4. Ballasts Operating 4-Foot MBP Lamps (Residential) , Base Case and Standards Case Efficiency Distributi ons (Emerging Technologies, Roll-Up Scenario)

...................................................................................................................... .. 10-5

10-i

### Table 10.2.5. Ballasts Operating 4-Foot MBP Lamps (Commercial) , Base Case and Standards Case Efficiency Distributions (E xisting Technologies, Shift Scenario)

....... 10-5 Table 10.2.6. Ballasts Operating 4-Foot MBP Lamps (Commercial) , Base Case and Standards Case Efficiency Distributi ons (Existing Technologies, Roll-Up Scenario)

...................................................................................................................... .. 10-6 Table 10.2.7. Ballasts Operating 4-Foot MBP Lamps (Commercial) , Base Case and Standards Case Efficiency Distributions (E merging Technologies, Shift Scenario)

..... 10-6 Table 10.2.8. Ballasts Operating 4-Foot MBP Lamps (Commercial) , Base Case and Standards Case Efficiency Distributi ons (Emerging Technologies, Roll-Up Scenario)

...................................................................................................................... .. 10-7 Table 10.2.9. Ballasts Operating 8-Foot Single Pin (Slimline) Lamps, Base Case and Standards Case Efficiency Distributions (E xisting Technologies, Shift Scenario)

....... 10-7 Table 10.2.10. Ballasts Operating 8-Foot Slimline Lamps, Base Case and Standards Case Efficiency Distributions (Existing T echnologies, Roll-Up Scenario)

........................... 10-8 Table 10.2.11. Ballasts Operating 8-Foot Slimline Lamps. Base Case and Standards Case Efficiency Distributions (Emerging Technologies, Shift Scenario)

.............................. 10-8 Table 10.2.12. Ballasts Operating 8-Foot Slimline Lamps, Base Case and Standards Case Efficiency Distributions (Emerging T echnologies, Roll-Up Scenario)

......................... 10-9 Table 10.2.13. Ballasts Operating 8-Foot Recessed Double Cont act (RDC) High Output (HO) Lamps, Base Case a nd Standards Case Efficiency Distributions (Existing Technologies, Shift Scenario)

........................................................................................ 10-9 Table 10.2.14. Ballasts Operating 8-Foot RDC HO Lamps, Base Case and Standards Case Efficiency Distributions (Existin g Technologies, Roll-Up Scenario)

................. 10-10 Table 10.2.15. Ballasts Operating 8-Foot RDC HO Lamps, Base Case and Standards Case Efficiency Distributions (Emergin g Technologies, Shift Scenario)

................... 10-10 Table 10.2.16. Ballasts Operating 8-Foot RDC HO Lamps, Base Case and Standards Case Efficiency Distributions (Emerging Technologies, Roll-Up Scenario)

.............. 10-11 Table 10.2.17. Ballasts Operating 4-Foot T5 Mini ature Bipin (MiniBP) Standard Output (SO) and HO Lamps, Base Case and Sta ndards Case Efficiency Distributions (Existing Technologies, Shift Scenario)

...................................................................... 10-11 Table 10.2.18. Ballasts Operating 4-Foot T5 Mi niBP SO and HO Lamps, Base Case and Standards Case Efficiency Distributi ons (Existing Technologies, Roll-Up Scenario)

...................................................................................................................... 10-12 Table 10.2.19. Ballasts Operating 4-Foot T5 Mi niBP SO and HO Lamps, Base Case and Standards Case Efficiency Distributions (E merging Technologies, Shift Scenario)

... 10-12 Table 10.2.20. Ballasts Operating 4-Foot T5 Mi niBP SO and HO Lamps, Base Case and Standards Case Efficiency Distributi ons (Emerging Technologies, Roll-Up Scenario)

...................................................................................................................... 10-13 Table 10.3.1 National Energy Saving Inputs

.......................................................................... 10-28

Table 10.3.2 Site-to-Source Conversion Factors

.................................................................... 10-29 Table 10.4.1 Net Present Value Inputs

................................................................................... 10-31 Table 10.5.1. National Energy Saving a nd Net Present Value Inputs

..................................... 10-33 Table 10.5.2. Cumulative National Energy Saving s for Ballasts under the Existing, Shift Scenario (2014-2044)

................................................................................................... 10-34 Table 10.5.3. Cumulative National Energy Sa vings for Ballasts under the Emerging, Roll-Up Scenario (2014-2044)

.................................................................................... 10-35

10-ii

### Table 10.5.4. Cumulative NPV Results for Balla sts Under the Existing Technologies, Shift Scenario (2014-2044)

.......................................................................................... 10-42

Table 10.5.5. Cumulative NPV Results for Balla sts Under the Emerging Technologies, Roll-Up Scenario (2014-2044)

.................................................................................... 10-42

LIST OF FIGURES

Figure 10.2.1. 4-Foot MBP (Residential) In stalled Ballast Stock (CSL 3)

............................. 10-14 Figure 10.2.2. 4-Foot MBP (Commercial) In stalled Ballast Stock (CSL 3)

............................ 10-14 Figure 10.2.3. 8-Foot Slimline Installe d Ballast Stock (CSL 3)

.............................................. 10-15 Figure 10.2.4. 8-Foot RDC HO Installe d Ballast Stock (CSL 3)

............................................ 10-15 Figure 10.2.5. 4-Foot T5 MiniBP SO and HO Installed Ballast Stock (CSL 3)

...................... 10-16 Figure 10.2.6. Average Efficiency of Stoc k, Ballasts Operating 4-Foot MBP Lamps (Residential, Existing Technologies, Shift Scenario)*

................................................ 10-17 Figure 10.2.7. Average Efficiency of Stoc k, Ballasts Operating 4-Foot MBP Lamps

Figure 10.2.8. Average Efficiency of Stoc k, Ballasts Operating 4-Foot MBP Lamps

Figure 10.2.9. Average Efficiency of Stoc k, Ballasts Operating 4-Foot MBP Lamps

Figure 10.2.10. Average Efficiency of Stoc k, Ballasts Operating 4-Foot MBP Lamps

Figure 10.2.11. Average Efficiency of Stoc k, Ballasts Operating 4-Foot MBP Lamps

Figure 10.2.12. Average Efficiency of Stoc k, Ballasts Operating 4-Foot MBP Lamps

Figure 10.2.13. Average Efficiency of Stoc k, Ballasts Operating 4-Foot MBP Lamps

Figure 10.2.14. Average Efficiency of Stock, Ballasts Operating 8-Foot Slimline Lamps

Figure 10.2.15. Average Efficiency of Stock, Ballasts Operating 8-Foot Slimline Lamps

Figure 10.2.16. Average Efficiency of Stock, Ballasts Operating 8-Foot Slimline Lamps

Figure 10.2.17. Average Efficiency of Stock, Ballasts Operating 8-Foot Slimline Lamps

Figure 10.2.18. Average Efficiency of Stock, Ballasts Operating 8-Foot RDC HO Lamps

Figure 10.2.19. Average Efficiency of Stock, Ballasts Operating 8-Foot RDC HO Lamps

Figure 10.2.20. Average Efficiency of Stock, Ballasts Operating 8-Foot RDC HO Lamps

Figure 10.2.21. Average Efficiency of Stock, Ballasts Operating 8-Foot RDC HO Lamps

Figure 10.2.22. Average Efficiency of Stock, Ba llasts Operating 4-Foot T5 MiniBP SO (Residential, Existing Technolog ies, Roll-Up Scenario)*

........................................... 10-17

(Residential, Emerging Technologies, Roll-Up Scenario)*

........................................ 10-18

(Residential, Emerging Technologies, Shift Scenario)*

.............................................. 10-18

(Commercial, Existing Technologies, Shift Scenario)*

.............................................. 10-19

(Commercial, Existing Technolog ies, Roll-Up Scenario)

........................................... 10-19

(Commercial, Emerging Technolog ies, Roll-Up Scenario)

......................................... 10-20

(Commercial, Emerging Technol ogies, Shift Scenario)*

............................................ 10-20

(Existing Technologies, Shift Scenario)*

.................................................................... 10-21

(Existing Technologies, Roll-Up Scenario)*

............................................................... 10-21

(Emerging Technologies, Roll-Up Scenario)*

............................................................ 10-22

(Emerging Technologies, Shift Scenario)*

.................................................................. 10-22

(Existing Technologies, Shift Scenario)*

.................................................................... 10-23

(Existing Technologies, Roll-Up Scenario)*

............................................................... 10-23

(Emerging Technologies, Roll-Up Scenario)*

............................................................ 10-24

(Emerging Technologies, Shift Scenario)*

.................................................................. 10-24

and HO Lamps (Existing Technolog ies, Shift Scenario)*

........................................... 10-25

10-iii

### Figure 10.2.23. Average Efficiency of Stock, Ba llasts Operating 4-Foot T5 MiniBP SO and HO Lamps (Existing Technologies, Roll-Up Scenario)*

..................................... 10-25 Figure 10.2.24. Average Efficiency of Stock, Ba llasts Operating 4-Foot T5 MiniBP SO and HO Lamps (Emerging Technologies, Roll-Up Scenario)*

................................... 10-26 Figure 10.2.25. Average Efficiency of Stock, Ba llasts Operating 4-Foot T5 MiniBP SO and HO Lamps (Emerging Technologies, Shift Scenario)*

........................................ 10-26 Figure 10.5.1. National Annual To tal Installed Equipment and Operating Cost Savings for 4-Foot MBP (Residential) at CSL3 (Existing Technologies, Shift Scenario)

Discounted at 7 Perc ent per Year

................................................................................. 10-36 Figure 10.5.2. National Annual To tal Installed Equipment and Operating Cost Savings for 4-Foot MBP (Residential) at CS L3 (Emerging Technologies, Roll-Up Scenario) Discounted at 7 Percent per Year

................................................................ 10-36 Figure 10.5.3. National Annual To tal Installed Equipment and Operating Cost Savings for 4-Foot MBP (Commercial) at CSL3 (Existing Technologies, Shift Scenario)

Discounted at 7 Perc ent per Year

................................................................................. 10-37 Figure 10.5.4. National Annual To tal Installed Equipment and Operating Cost Savings for 4-Foot MBP (Commercial) at CSL3 (Existing Technologies, Shift Scenario)

Discounted at 7 Perc ent per Year

................................................................................. 10-37 Figure 10.5.5. National Annual To tal Installed Equipment and Operating Cost Savings for 8-Foot Slimline at CSL3 (Existing Technologies, Shift Scenario) Discounted at 7 Percent per Year

.................................................................................................... 10-38 Figure 10.5.6. National Annual To tal Installed Equipment and Operating Cost Savings for 8-Foot Slimline at CSL3 (Emerging Technologies, Roll-Up Scenario)

Discounted at 7 Perc ent per Year

................................................................................. 10-38 Figure 10.5.7. National Annual To tal Installed Equipment and Operating Cost Savings for 8-Foot RDC HO at CSL3 (Existing Technologies, Shift Scenario) Discounted at 7 Percent per Year

.................................................................................................... 10-39 Figure 10.5.8. National Annual To tal Installed Equipment and Operating Cost Savings for 8-Foot RDC HO at CSL3 (Emerging Technologies, Roll-Up Scenario)

Discounted at 7 Perc ent per Year

................................................................................. 10-39 Figure 10.5.9. National Annual To tal Installed Equipment and Operating Cost Savings for 4-Foot Miniature Bipin T5 Standard Output and High Output at CSL3 (Existing Technologies, Shift Scenario) Discounted at 7 Percent per Year

................ 10-40 Figure 10.5.10. National Annual To tal Installed Equipment a nd Operating Cost Savings for 4-Foot Miniature Bipin T5 Standard Output and High Output at CSL3 (Emerging Technologies, Roll-Up Scenario) Discounted at 7 Percent per Year

........ 10-40

10-iv

### CHAPTER 10. NATIONAL IMPACTS ANALYSIS

10.1 INTRODUCTION

This chapter describes the method for estimating the national impacts of candidate standard levels (CSLs) for analyzed fluorescent lamp ballasts (hereafter “ballasts”). Because ballasts are designed to operate fluorescent lamps, DOE chooses the most common fluorescent lamp used with each ballast to develop representative lamp-and-ballast systems. Fluorescent lamps will not be regulated under the proposed amended energy conservation standards for ballasts; however, the characteristics of complete lamp-and-ballast systems ( e.g. , energy consumption, installed cost, etc.) must be considered for estimating national impacts of ballast CSLs.

In the national impact analysis (NIA), the U.S. Department of Energy (DOE) assesses the cumulative national energy savings (NES) and the cumulative national economic impacts of CSLs. DOE measures energy savings as the cumulative quads of energy a CSL is expected to save the Nation. DOE measures economic impacts as the net present value (NPV) in dollars of total customer costs and savings expected to re sult from a CSL. The analysis period over which

DOE calculates the NPV and NES is from 2014 to 2044. Results of the NIA described in this chapter include (1) national energy consumption and savings; (2) monetary value of energy savings to the Nation as a result of standards; (3) increased total installed costs to the Nation as a result of standards; and (4) the NPV of energy savings (the difference between the present monetary values of energy savings a nd increased total installed costs).

DOE determines both the NPV and NES for each CSL and each representative product class it selects in the engineering analysis (preliminary TSD chapter 5). In this rulemaking, DOE considers up to three CSLs for each of th e representative ballast product classes.

DOE performs all NIA calculations using a Microsoft Excel spreadsheet, available at www.eere.energy.gov/buildings/appliance_standa rds/residential/fluores cent_lamp_ballasts.html

. Appendix 10A provides instructions for using the spreadsheet.

The following sections describe in deta il the methodology and inputs for the NIA. Several NIA inputs, including per-unit costs, per-unit energy consumption, and national shipments, are discussed in other analyses. In describing the inputs to the NIA, this chapter references those analyses and presents new in formation on installed stock. Section 10.2 discusses DOE’s ballast shipment forecasts by CSL, the installed stock of ballasts, and the mix of

efficiencies of that stock. Section 10.3 discusses DOE’s calculation of national energy consumption in the base and standards cases, and the resulting difference in NES between these

cases. Section 10.4 discusses th e NPV calculation. Section 10.5 presents the NES and NPV results by representative product class.

10.2 BASE-CASE AND STANDARDS-CASE FORECASTED EFFICIENCY DISTRIBUTIONS, BALLAST STOCKS, AND AVERAGE EFFICIENCY

The characteristics of DOE’s shipment forecas ts (such as equipment costs and operating costs) and projected ballast stoc ks (such as average efficiency and energy consumption) are key

10-1

### aspects of DOE’s NES and NPV estimates. This section describes these key characteristics of stock and shipments as they re late to the NES and NPV. Note that the representative product

classes addressed indivi dually in the NES and NPV results ar e aggregated in broader groupings for describing stock and sh ipment characteristics ( e.g. , ballasts operating T 12 and T8 lamps are grouped together by lamp length and lamp base).

For example, the projected distribution of ballast efficiencies shipped and ballast efficiencies in stock are key factors in determining the NPV. Two inputs to the NPV are the perunit total installed cost and per- unit annual operating cost. The per- unit total installed cost often varies with the efficiency of ballasts shipped. Therefore, when higher efficiency ballasts are shipped, higher installed costs are often incurr ed. Section 8.2.2 of the preliminary TSD chapter 8 describes how per-unit total installed costs vary as a function of efficiency for each lamp ballast.

Per-unit annual energy consumption is a key input to the NPV (as an input to the per-unit operating cost) and NES. The per-unit annual en ergy consumption is a function of lamp-and

ballast system characteristics in the installed stock. The total installed stock of lamp-and-ballast systems is used to determine total annual ener gy consumption, a key input into the NES and

NPV calculations.

Also important to determining NES and NPV is the average efficiency of the lamp ballast stock. The engineering analysis (preliminary TSD chapter 5) discusses the relationship between lamp-and-ballast system design, system input power and ba llast efficiency. The energy use characterization (preliminary TSD chapter 6) describes how the per-unit energy consumption varies as a function of system input power and market sector application for each lamp-and

ballast system design.

Sections 10.3.2 and 10.4.2 discuss inputs to calcu lation of the NES and NPV in further

detail.

The following sections detail the forecasted di stribution of efficienci es, installed ballast stocks, and average efficiency of those stocks in the base and standards cases.

10.2.1 Base and Standards Case Efficiency Distributions

Because the end-user price of ballasts varies w ith efficiency level, the base and standards case forecasted efficiency distributions of shipments affect the average total installed cost per unit. Generally, as the efficiency of a lamp-and-ballast system design increases, the total installed cost increases as well. In addition, the base-cas e and standards-case e fficiency distributions affect the average ballast efficiency in the installed stock, an indication of annual energy consumption. For ballasts, DOE first presented the market share apportionments in the base case in chapter 9. These market share apportionments ch aracterize the shipments of ballasts for each analyzed product class. The forecasted efficiency distributions of ship ments for ballasts depend directly on these apportionments and the total shipme nts of a particular ballast type in each year of the analysis period.

Table 10.2.1 through Table 10.2.20 show the percen tage market share of shipments of ballasts of different CSLs, where the efficiencies correspond to particular CSLs. The table also illustrates how this mix of efficiencies changes over time, from 2014 to 2044.

10-2

### There are two tables per representative ballast product class: one depi cting the efficiency mixes in the existing technologies shift scenar io and one depicting those in the emerging technologies roll-up scenario. Emerging technol ogies scenarios addre ss the penetration of particular ballast markets by light-emitting diode (LED) produc ts; chapter 9 discusses these

scenarios in further detail. Because consumers in the shift scenario ma ke purchase decisions based more on the energy savings of a particular ballast design, the shift scenario often presents a more aggressive forecasted effi ciency distribution. For the roll-up scenario, DOE assumed that when possible, consumers will purchase the lowest first-cost ballast option which, in many cases, is often at the minimum allowed efficiency level.

The existing and emerging technologies scen arios affect the number of shipments by product class, without regard to efficiency level. Mostly, these scenarios do not affect the efficiency distributions within a given product class. In a few cases, these scenarios contribute to incidental changes in efficiency distributions through a complex interaction with the substitution trends shown in chapter 9, table 9.2. Specifically , because in the emerging technologies case shipments of some produc t classes are smaller than they are in existing technologies, any

substitution trends based on these product classes are smaller as we ll. To the extent that these

substitution trends affect the effici ency distributions of particular product classes, this effect is smaller in the emerging technologies case than in the existing technologies case.

Table 10.2.1. Ballasts Operating 4-Foot Medium Bipin (MBP) Lamps (Residential), Base
Case and Standards Case Efficiency Distributions (Existing Technologies, Shift Scenario)

Year CSL Proportions of All 4-Foot MBP (Residential) Ballasts Shipped

%

Base Case Standards Case CSLs

1 2 3

2014 Baseline 5 5 5 5

1 68 57 57 57

2 26 38 38 38

3 0 0 0 0

Total 100 100 100 100

2029 Baseline 0 0 0 0

1 73 0 0 0

2 27 100 100 100

3 0 0 0 0

Total 100 100 100 100

2044 Baseline 0 0 0 0

1 73 0 0 0

2 27 100 100 100

3 0 0 0 0

Total 100 100 100 100

10-3

### Table 10.2.2. Ballasts Operating 4-Foot MBP Lamps (Residential), Base Case and
Standards Case Efficiency Distributions (Existing Technologies , Roll-Up Scenario)

Year CSL Proportions of All 4-Foot MBP (Residential) Ballasts Shipped

%

Base Case Standards Case CSLs

1 2 3

2014 Baseline 5 5 5 5

1 68 68 57 57

2 26 26 38 38

3 0 0 0 0

Total 100 100 100 100

2029 Baseline 0 0 0 0

1 73 73 0 0

2 27 27 100 100

3 0 0 0 0

Total 100 100 100 100

2044 Baseline 0 0 0 0

1 73 73 0 0

2 27 27 100 100

3 0 0 0 0

Total 100 100 100 100



### Table 10.2.3. Ballasts Operating 4-Foot MBP Lamps (Residential), Base Case and
Standards Case Efficiency Distributions (Emerging Technologies, Shift Scenario)

Year CSL Proportions of All 4-Foot MBP (Residential) Ballasts Shipped

%

Base Case Standards Case CSLs

1 2 3

2014 Baseline 5 5 5 5

1 68 57 57 57

2 26 38 38 38

3 0 0 0 0

Total 100 100 100 100

2029 Baseline 0 0 0 0

1 73 0 0 0

2 27 100 100 100

3 0 0 0 0

Total 100 100 100 100

2044 Baseline 0 0 0 0

1 73 0 0 0

2 27 100 100 100

3 0 0 0 0

Total 100 100 100 100

10-4

### Table 10.2.4. Ballasts Operating 4-Foot MBP Lamps (Residential), Base Case and
Standards Case Efficiency Distributions (Emerging Technologies, Roll-Up Scenario)

Year CSL Proportions of All 4-Foot MBP (Residential) Ballasts Shipped

%

Base Case Standards Case CSLs

1 2 3

2014 Baseline 5 5 5 5

1 68 68 57 57

2 26 26 38 38

3 0 0 0 0

Total 100 100 100 100

2029 Baseline 0 0 0 0

1 73 73 0 0

2 27 27 100 100

3 0 0 0 0

Total 100 100 100 100

2044 Baseline 0 0 0 0

1 73 73 0 0

2 27 27 100 100

3 0 0 0 0

Total 100 100 100 100



### Table 10.2.5. Ballasts Operating 4-Foot MBP Lamps (Commercial), Base Case and Standards Case Efficiency Distributions (Existing Technologi es, Shift Scenario)

Year CSL Proportions of All 4-Foot MB P (Commercial) Ballasts Shipped

%

Base Case Standards Case CSLs

1 2 3

2014 Baseline 26 22 22 22

1 55 52 52 52

2 9 15 8 8

3 9 11 19 19

Total 100 100 100 100

2029 Baseline 28 0 0 0

1 54 40 40 40

2 9 29 0 0

3 9 31 60 60

Total 100 100 100 100

2044 Baseline 33 0 0 0

1 52 47 47 47

2 8 0 0 0

3 8 53 53 53

Total 100 100 100 100

10-5

### Table 10.2.6. Ballasts Operating 4-Foot MBP Lamps (Commercial), Base Case and
Standards Case Efficiency Distributions (Existing Technologies , Roll-Up Scenario)

Year CSL Proportions of All 4-Foot MB P (Commercial) Ballasts Shipped

%

Base Case Standards Case CSLs

1 2 3

2014 Baseline 26 22 22 22

1 55 60 52 52

2 9 9 17 8

3 9 9 9 19

Total 100 100 100 100

2029 Baseline 28 0 0 0

1 54 82 40 40

2 9 9 51 0

3 9 9 9 60

Total 100 100 100 100

2044 Baseline 33 0 0 0

1 52 84 47 47

2 8 8 45 0

3 8 8 8 53

Total 100 100 100 100



### Table 10.2.7. Ballasts Operating 4-Foot MBP Lamps (Commercial), Base Case and
Standards Case Efficiency Distributions (Emerging Technologies, Shift Scenario)

Year CSL Proportions of All 4-Foot MB P (Commercial) Ballasts Shipped

%

Base Case Standards Case CSLs

1 2 3

2014 Baseline 26 22 22 22

1 55 52 52 52

2 9 15 8 8

3 9 11 18 18

Total 100 100 100 100

2029 Baseline 27 0 0 0

1 55 40 40 40

2 9 31 0 0

3 9 29 60 60

Total 100 100 100 100

2044 Baseline 31 0 0 0

1 52 45 45 45

2 8 0 0 0

3 8 55 55 55

Total 100 100 100 100

10-6

### Table 10.2.8. Ballasts Operating 4-Foot MBP Lamps (Commercial), Base Case and
Standards Case Efficiency Distributions (Emerging Technologies, Roll-Up Scenario)

Year CSL Proportions of All 4-Foot MB P (Commercial) Ballasts Shipped

%

Base Case Standards Case CSLs

1 2 3

2014 Baseline 26 22 22 22

1 55 60 52 52

2 9 9 17 8

3 9 9 9 18

Total 100 100 100 100

2029 Baseline 27 0 0 0

1 55 82 40 40

2 9 9 51 0

3 9 9 9 60

Total 100 100 100 100

2044 Baseline 31 0 0 0

1 52 84 45 45

2 8 8 47 0

3 8 8 8 55

Total 100 100 100 100



### Table 10.2.9. Ballasts Operating 8-Foot Single Pin (Slimline) Lamps, Base Case and
Standards Case Efficiency Distributions (Existing Technologi es, Shift Scenario)

Year CSL Proportions of All 8-Foot Slimline Ballasts Shipped

%

Base Case Standards Case CSLs

1 2 3

2014 Baseline 70 59 59 59

1 30 41 41 41

2 0 0 0 0

3 0 0 0 0

Total 100 100 100 100

2029 Baseline 74 0 0 0

1 26 100 100 100

2 0 0 0 0

3 0 0 0 0

Total 100 100 100 100

2044 Baseline 76 0 0 0

1 24 100 100 100

2 0 0 0 0

3 0 0 0 0

Total 100 100 100 100

10-7

### Table 10.2.10. Ballasts Operating 8-Foot Slimline Lamps, Base Case and Standards Case
Efficiency Distributions (Existing Technologies, Roll-Up Scenario)

Year CSL Proportions of All 8-Foot Slimline Ballasts Shipped

%

Base Case Standards Case CSLs

1 2 3

2014 Baseline 70 59 59 59

1 30 41 41 41

2 0 0 0 0

3 0 0 0 0

Total 100 100 100 100

2029 Baseline 74 0 0 0

1 26 100 100 100

2 0 0 0 0

3 0 0 0 0

Total 100 100 100 100

2044 Baseline 76 0 0 0

1 24 100 100 100

2 0 0 0 0

3 0 0 0 0

Total 100 100 100 100



### Table 10.2.11. Ballasts Operating 8-Foot Slimline Lamps. Base Case and Standards Case
Efficiency Distributions (Emerging Technologies, Shift Scenario)

Year CSL Proportions of All 8-Foot Slimline Ballasts Shipped

%

Base Case Standards Case CSLs

1 2 3

2014 Baseline 70 59 59 59

1 30 41 41 41

2 0 0 0 0

3 0 0 0 0

Total 100 100 100 100

2029 Baseline 74 0 0 0

1 26 100 100 100

2 0 0 0 0

3 0 0 0 0

Total 100 100 100 100

2044 Baseline 76 0 0 0

1 24 100 100 100

2 0 0 0 0

3 0 0 0 0

Total 100 100 100 100

10-8

### Table 10.2.12. Ballasts Operating 8-Foot Slimline Lamps, Base Case and Standards Case
Efficiency Distributions (Emerging Technologies, Roll-Up Scenario)

Year CSL Proportions of All 8-Foot Slimline Ballasts Shipped

%

Base Case Standards Case CSLs

1 2 3

2014 Baseline 70 59 59 59

1 30 41 41 41

2 0 0 0 0

3 0 0 0 0

Total 100 100 100 100

2029 Baseline 74 0 0 0

1 26 100 100 100

2 0 0 0 0

3 0 0 0 0

Total 100 100 100 100

2044 Baseline 76 0 0 0

1 24 100 100 100

2 0 0 0 0

3 0 0 0 0

Total 100 100 100 100



### Table 10.2.13. Ballasts Operating 8-Foot Reces sed Double Contact (RDC) High Output
(HO) Lamps, Base Case and Standards Ca se Efficiency Distributions (Existing
Technologies, Shift Scenario)

Year CSL Proportions of All 8-Foot RDC HO Ballasts Shipped

%

Base Case Standards Case CSLs

1 2 3

2014 Baseline 78 65 65 65

1 19 33 32 32

2 1 1 2 1

3 1 2 2 2

Total 100 100 100 100

2029 Baseline 79 0 0 0

1 20 99 99 99

2 1 0 0 0

3 0 1 1 1

Total 100 100 100 100

2044 Baseline 80 0 0 0

1 20 100 100 100

2 0 0 0 0

3 0 0 0 0

Total 100 100 100 100

10-9

### Table 10.2.14. Ballasts Operating 8-Foot RDC HO La mps, Base Case and Standards Case
Efficiency Distributions (Existing Technologies, Roll-Up Scenario)

Year CSL Proportions of All 8-Foot RDC HO Ballasts Shipped

%

Base Case Standards Case CSLs

1 2 3

2014 Baseline 78 65 65 65

1 19 33 32 32

2 1 2 1 1

3 1 1 2 2

Total 100 100 100 100

2029 Baseline 79 0 0 0

1 20 99 99 99

2 1 1 0 0

3 0 0 1 1

Total 100 100 100 100

2044 Baseline 80 0 0 0

1 20 100 100 100

2 0 0 0 0

3 0 0 0 0

Total 100 100 100 100



### Table 10.2.15. Ballasts Operating 8-Foot RDC HO La mps, Base Case and Standards Case
Efficiency Distributions (Emerging Technologies, Shift Scenario)

Year CSL Proportions of All 8-Foot RDC HO Ballasts Shipped

%

Base Case Standards Case CSLs

1 2 3

2014 Baseline 78 65 65 65

1 19 33 32 32

2 1 1 2 1

3 1 2 2 2

Total 100 100 100 100

2029 Baseline 79 0 0 0

1 20 99 99 99

2 1 0 0 0

3 0 1 1 1

Total 100 100 100 100

2044 Baseline 80 0 0 0

1 20 100 100 100

2 0 0 0 0

3 0 0 0 0

Total 100 100 100 100

10-10

### Table 10.2.16. Ballasts Operating 8-Foot RDC HO La mps, Base Case and Standards Case
Efficiency Distributions (Emerging Technologies, Roll-Up Scenario)

Year CSL Proportions of All 8-Foot RDC HO Ballasts Shipped

%

Base Case Standards Case CSLs

1 2 3

2014 Baseline 78 65 65 65

1 19 33 32 32

2 1 2 1 1

3 1 1 2 2

Total 100 100 100 100

2029 Baseline 79 0 0 0

1 20 99 99 99

2 1 1 0 0

3 0 0 1 1

Total 100 100 100 100

2044 Baseline 80 0 0 0

1 20 100 100 100

2 0 0 0 0

3 0 0 0 0

Total 100 100 100 100



### Table 10.2.17. Ballasts Operating 4-Foot T5 Mini ature Bipin (MiniBP) Standard Output
(SO) and HO Lamps, Base Case and Standard s Case Efficiency Distributions (Existing
Technologies, Shift Scenario)

Year CSL Proportions of All 4-Foot MiniBP SO and HO Ballasts Shipped

%

Base Case Standards Case CSLs

1 2 3

2014 Baseline 69 49 49 49

1 16 31 11 11

2 16 20 40 40

3 0 0 0 0

Total 100 100 100 100

2029 Baseline 69 0 0 0

1 16 47 0 0

2 16 53 100 100

3 0 0 0 0

Total 100 100 100 100

2044 Baseline 69 0 0 0

1 16 18 0 0

2 16 82 100 100

3 0 0 0 0

Total 100 100 100 100

10-11

### Table 10.2.18. Ballasts Operating 4-Foot T5 Mi niBP SO and HO Lamps, Base Case and
Standards Case Efficiency Distributions (Existing Technologies , Roll-Up Scenario)

Year CSL Proportions of All 4-Foot MiniBP SO and HO Ballasts Shipped

%

Base Case Standards Case CSLs

1 2 3

2014 Baseline 69 49 49 49

1 16 35 11 11

2 16 16 40 40

3 0 0 0 0

Total 100 100 100 100

2029 Baseline 69 0 0 0

1 16 85 0 0

2 16 16 100 100

3 0 0 0 0

Total 100 100 100 100

2044 Baseline 69 0 0 0

1 16 85 0 0

2 16 16 100 100

3 0 0 0 0

Total 100 100 100 100



### Table 10.2.19. Ballasts Operating 4-Foot T5 Mi niBP SO and HO Lamps, Base Case and
Standards Case Efficiency Distributions (Emerging Technologies, Shift Scenario)

Year CSL Proportions of All 4-Foot MiniBP SO and HO Ballasts Shipped

%

Base Case Standards Case CSLs

1 2 3

2014 Baseline 69 50 50 50

1 16 30 11 11

2 16 20 39 39

3 0 0 0 0

Total 100 100 100 100

2029 Baseline 69 0 0 0

1 16 47 0 0

2 16 53 100 100

3 0 0 0 0

Total 100 100 100 100

2044 Baseline 69 0 0 0

1 16 16 0 0

2 16 84 100 100

3 0 0 0 0

Total 100 100 100 100

10-12

### Table 10.2.20. Ballasts Operating 4-Foot T5 Mi niBP SO and HO Lamps, Base Case and Standards Case Efficiency Distributions (Emerging Technologies, Roll-Up Scenario)

Year CSL Proportions of All 4-Foot MiniBP SO and HO Ballasts Shipped

%

Base Case Standards Case CSLs

1 2 3

2014 Baseline 69 50 50 50

1 16 35 11 11

2 16 16 39 39

3 0 0 0 0

Total 100 100 100 100

2029 Baseline 69 0 0 0

1 16 85 0 0

2 16 16 100 100

3 0 0 0 0

Total 100 100 100 100

2044 Baseline 69 0 0 0

1 16 85 0 0

2 16 16 100 100

3 0 0 0 0

Total 100 100 100 100



### 10.2.2 Installed Ballast Stock

The installed ballast stock in a given year is the total number of ballasts shipped that year and in prior years that are still operating. The NES model tracks the ballasts shipped each year, and ballasts are retired when they reach the end of their lifetime. From this information and the shipments forecasts presented in chapter 9, DOE established the installed ballast stock profile for all analyzed ballast product classes. Figure 10.2.1 through Figure 10.2.5 show these ballast stocks in the base case and standards case for CSL3 under the same pair of scenarios analyzed throughout this chapter: the existing technologie s shift scenario and the emerging technologies roll-up scenario. At CSL 3, the roll-up and shift scenarios are the same: both scenarios assume that the entire market moves to CSL 3, or the highest efficiency level available for product

classes that do not have an ava ilable CSL 3 efficiency level option. The difference between the emerging technologies and existing technologies scenar ios, as noted earlier, is that shipments are smaller in the emerging technologies case for affe cted product classes. In the following figures, where the existing technologies shift scenario differs from the emerging technologies roll-up scenario it is because of this smaller number of shipments. However, not all product classes are assumed to experience penetration by LED products in the emerging technologies scenario,

which results in identical stocks and overlapping curves in some figures ( e.g. , Figure 10.2.3).

For most types of ballasts, installed stock increases over time, particularly in the Existing Technologies scenario. However, some ballast types experience a decline in stocks over the analysis period due to growing substitution for other ballast types as shown in chapter 9, table 9.2. For example, the market for 8-foot RD C HO ballasts for general lighting applications is assumed to decline over the analysis period; however, T12 RDC HO cold temperature/sign

ballasts included in the same product grouping dominate the overa ll stock, and drive its growth (Figure 10.2.4).

10-13

### Figure 10.2.1. 4-Foot MBP (Res idential) Installed Ba llast Stock (CSL 3)

Figure 10.2.2. 4-Foot MBP (Commercial) In stalled Ballast Stock (CSL 3)

10-14

### Figure 10.2.3. 8-Foot Slimline Insta lled Ballast St ock (CSL 3)

Figure 10.2.4. 8-Foot RDC HO Insta lled Ballast St ock (CSL 3)

10-15

### Figure 10.2.5. 4-Foot T5 MiniBP SO and HO Installed Ballast Stock (CSL 3)

10.2.3 Average Ballast Efficiency in the Stock

As discussed earlier, the average efficiency of ballast stocks can be an indication of the energy consumption, and is an important input to both the NPV and NES calculations. Figure

10.2.6 through Figure 10.2.25 present the average e fficiency forecasts of ballast stocks (as represented by ballast efficacy factor, BEF) in the base case and standards case for both the existing technologies/shift, existing technolog ies/roll-up, emerging technologies/roll-up, and emerging technologies/shift scenarios for each product class. Each figure presents the efficiencies at multiple CSLs. While CSLs vary from zero (the base case) to three, some representative product classes have fewer than all four possible CSLs. As a result, in some cases two or more CSLs may yield the same average ba llast efficiency, which results in overlapping curves in the figures. These figures’ titles are noted with a “*”.

10-16

## 1.44 1.45 1.46 1.47 1.48 1.49

1.5 1.512014201620182020202220242026202820302032203420362038204020422044AverageBEF



### Base Case

CSL 1

CSL 2

CSL 3



### Figure 10.2.6. Average Efficiency of Stock, Ballasts Operating 4-Foot MBP Lamps
(Residential, Existing Tec hnologies, Shift Scenario)*



### 1.44 1.45 1.46 1.47 1.48 1.49

1.5 1.512014201620182020202220242026202820302032203420362038204020422044AverageBEF



### Base Case

CSL 1

CSL 2

CSL 3



### Figure 10.2.7. Average Efficiency of Stock, Ballasts Operating 4-Foot MBP Lamps
(Residential, Existing Techno logies, Roll-Up Scenario)*

10-17

### 1.44 1.45 1.46 1.47 1.48 1.49

1.5 1.512014201620182020202220242026202820302032203420362038204020422044AverageBEF



### Base Case

CSL 1

CSL 2

CSL 3



### Figure 10.2.8. Average Efficiency of Stock, Ballasts Operating 4-Foot MBP Lamps
(Residential, Emerging Techno logies, Roll-Up Scenario)*

1.44 1.45 1.46 1.47 1.48 1.49

1.5 1.512014201620182020202220242026202820302032203420362038204020422044AverageBEF



### Base Case

CSL 1

CSL 2

CSL 3



### Figure 10.2.9. Average Efficiency of Stock, Ballasts Operating 4-Foot MBP Lamps
(Residential, Emerging Techno logies, Shift Scenario)*

10-18

### 1.21 1.22 1.23 1.24 1.25 1.26 1.27 1.28 1.29

1.3 1.312014201620182020202220242026202820302032203420362038204020422044AverageBEF



### Base Case

CSL 1

CSL 2

CSL 3



### Figure 10.2.10. Average Efficiency of Stock, Ballasts Operating 4-Foot MBP Lamps
(Commercial, Existing Technologies, Shift Scenario)*



### 1.21 1.22 1.23 1.24 1.25 1.26 1.27 1.28 1.29

1.3 1.312014201620182020202220242026202820302032203420362038204020422044AverageBEF



### Base Case

CSL 1

CSL 2

CSL 3



### Figure 10.2.11. Average Efficiency of Stock, Ballasts Operating 4-Foot MBP Lamps
(Commercial, Existing Technologies, Roll-Up Scenario)

10-19

### 1.22 1.23 1.24 1.25 1.26 1.27 1.28 1.29

1.3 1.312014201620182020202220242026202820302032203420362038204020422044AverageBEF



### Base Case

CSL 1

CSL 2

CSL 3



### Figure 10.2.12. Average Efficiency of Stock, Ballasts Operating 4-Foot MBP Lamps
(Commercial, Emerging Technologies, Roll-Up Scenario)



### 1.22 1.23 1.24 1.25 1.26 1.27 1.28 1.29

1.3 1.312014201620182020202220242026202820302032203420362038204020422044AverageBEF



### Base Case

CSL 1

CSL 2

CSL 3



### Figure 10.2.13. Average Efficiency of Stock, Ballasts Operating 4-Foot MBP Lamps
(Commercial, Emerging Technologies, Shift Scenario)*

10-20

### 0.785 0.79 0.795 0.8 0.805

0.81 0.8152014201620182020202220242026202820302032203420362038204020422044AverageBEF



### Base Case

CSL 1

CSL 2

CSL 3



### Figure 10.2.14. Average Efficiency of Stock, Ba llasts Operating 8-Foot Slimline Lamps
(Existing Technologies , Shift Scenario)*



### 0.785

0.79 0.795 0.8 0.805

0.81 0.8152014201620182020202220242026202820302032203420362038204020422044AverageBEF



### Base Case

CSL 1

CSL 2

CSL 3



### Figure 10.2.15. Average Efficiency of Stock, Ba llasts Operating 8-Foot Slimline Lamps
(Existing Technologies , Roll-Up Scenario)*

10-21

### 0.785 0.79 0.795 0.8 0.805

0.81 0.8152014201620182020202220242026202820302032203420362038204020422044AverageBEF



### Base Case

CSL 1

CSL 2

CSL 3



### Figure 10.2.16. Average Efficiency of Stock, Ba llasts Operating 8-Foot Slimline Lamps
(Emerging Technologies , Roll-Up Scenario)*

0.785

0.79 0.795 0.8 0.805

0.81 0.8152014201620182020202220242026202820302032203420362038204020422044AverageBEF



### Base Case

CSL 1

CSL 2

CSL 3



### Figure 10.2.17. Average Efficiency of Stock, Ba llasts Operating 8-Foot Slimline Lamps
(Emerging Technologies , Shift Scenario)*

10-22

### 0 0.05

0.1 0.15

0.2 0.25

0.32014201620182020202220242026202820302032203420362038204020422044AverageBEF

Base Case

CSL 1

CSL 2

CSL 3



### Figure 10.2.18. Average Efficiency of Stock, Ballasts Operating 8-Foot RDC HO Lamps
(Existing Technologies , Shift Scenario)*

0 0.05

0.1 0.15

0.2 0.25

0.32014201620182020202220242026202820302032203420362038204020422044AverageBEF



### Base Case

CSL 1

CSL 2

CSL 3



### Figure 10.2.19. Average Efficiency of Stock, Ballasts Operating 8-Foot RDC HO Lamps
(Existing Technologies , Roll-Up Scenario)*

10-23

### 0 0.05

0.1 0.15

0.2 0.25

0.32014201620182020202220242026202820302032203420362038204020422044AverageBEF



### Base Case

CSL 1

CSL 2

CSL 3



### Figure 10.2.20. Average Efficiency of Stock, Ballasts Operating 8-Foot RDC HO Lamps
(Emerging Technologies , Roll-Up Scenario)*

0 0.05

0.1 0.15

0.2 0.25

0.32014201620182020202220242026202820302032203420362038204020422044AverageBEF



### Base Case

CSL 1

CSL 2

CSL 3



### Figure 10.2.21. Average Efficiency of Stock, Ballasts Operating 8-Foot RDC HO Lamps
(Emerging Technologies , Shift Scenario)*

10-24

### 0 0.2 0.4 0.6 0.8

1 1.2 1.4 1.6 1.82014201620182020202220242026202820302032203420362038204020422044AverageBEF

Base Case

CSL 1

CSL 2

CSL 3



### Figure 10.2.22. Average Efficiency of Stock, Ball asts Operating 4-Foot T5 MiniBP SO and
HO Lamps (Existing Technologies, Shift Scenario)*

0 0.2 0.4 0.6 0.8

1 1.2 1.4 1.6 1.82014201620182020202220242026202820302032203420362038204020422044AverageBEF



### Base Case

CSL 1

CSL 2

CSL 3



### Figure 10.2.23. Average Efficiency of Stock, Ball asts Operating 4-Foot T5 MiniBP SO and
HO Lamps (Existing Technol ogies, Roll-Up Scenario)*

10-25

### 1.1 1.15

1.2 1.25

1.3 1.35

1.4 1.45

1.52014201620182020202220242026202820302032203420362038204020422044AverageBEF



### Base Case

CSL 1

CSL 2

CSL 3



### Figure 10.2.24. Average Efficiency of Stock, Ball asts Operating 4-Foot T5 MiniBP SO and
HO Lamps (Emerging Technologies, Roll-Up Scenario)*

1.1 1.15

1.2 1.25

1.3 1.35

1.4 1.45

1.52014201620182020202220242026202820302032203420362038204020422044AverageBEF



### Base Case

CSL 1

CSL 2

CSL 3



### Figure 10.2.25. Average Efficiency of Stock, Ball asts Operating 4-Foot T5 MiniBP SO and
HO Lamps (Emerging Technologies, Shift Scenario)*

10-26

### 10.3 NATIONAL ENERGY SAVINGS

10.3.1 National Energy S avings Definition

DOE calculates annual national energy saving s as the difference between the base case (without new standards) and the standards case (with new standards). Positive values of NES correspond to net energy savings fo llowing standards implementation; i.e. , national annual energy consumption (AEC) with standard s is less than AEC in the base case.

NES

t 

### = ( AEC

t

, base 

### − AEC

t

, std 

### ) × HVAC × RR 

### Eq. 10.1

Where:

NES t 

### = national energy savings in year t

, AEC = annual national energy consumption each year (at the source) in quadrillion British thermal units (quads),

HVAC= heating, ventilation, air conditioning (HVAC) factor,

RR = rebound factor, equal to one plus the rebound rate,

t = year in the forecast ( e.g. , 2014 to 2044),

base = base case, and

std = standards case.

Cumulative energy savings are the sum over a defined time period from the implementation of a standard forward (from 2014 to 2044) of the annu al national energy savings multiplied by the

HVAC interaction factor and rebound rate.

NES

cum 

### = 

# ∑ NES

t 

### Eq. 10.2

t



### Where:

NES

cum 

### = cumulative national energy savings.

DOE calculated the AEC (in any year) by multiplying the number or stock of ballasts by the product of the annual unit energy consumpti on and the site-to-source conversion factor, shown by the following equation:

AEC = 

# ∑ STOCK bd 

### × UEC bd 

### × src

_ conv t 

### Eq. 10.3

bd



### Where:

bd = ballast ID number,

STOCK bd 

### = stock of ballasts for a given design surviving in the year for which DOE calculated AEC,

UEC bd



### = unit energy consumption (kWh per year), and

src_conv t 

### = time-dependent conversion factor to convert from site energy (kWh) to source energy (quads, Btu/kWh).

10-27

### 10.3.2 National Energy Savings Inputs

Table 10.3.1 lists the inputs for the determination of NES.

Table 10.3.1 National Energy Saving Inputs

Input

Unit Energy Consumption, UEC Ballast Stock by Design ( STOCKld ) Site-to-Source Conversion Factor ( src_conv ) Heating, Ventilation, Air Conditioning Factor ( HVAC ) Rebound Rate ( RR )



### 10.3.2.1 Unit Energy Consumption (UEC)

DOE presented the per-unit UEC for each lamp-and-ballast system design in the energy use characterization (preliminary TSD chapter 6). For the NES and NPV calculations, DOE used an average number of annual operating hours for each sector and ballast type in calculating the UEC of each lamp-and-ballast system design.

10.3.2.2 Ballast Stock

The ballast stock in a given year is the total number of ballast shipped in prior years that survive. The NES spreadsheet model keeps track of the ballasts shipped each year. DOE discusses forecasted shipments for the base case a nd all standards cases in chapter 9. To generate the shipments that eventually compose the ballast stock, the shipments analysis incorporates one

set of base-case scenarios and one set of standards case scenarios that can affect shipments. The base-case scenarios, existing and emerging technol ogies, dictate the penetration of other lighting technologies, and therefore affect the total volum e of ballast shipments and installed stock. The standards-case scenarios are comprised of the roll-up and shift scenarios. These scenarios dictate the inputs to the market-share apportionments , and therefore affect the breakdown of the installed stock by ballast design from 2014 to 2044.

These standards case scenarios are compared to two separate base case scenarios (existing and emerging technologies) resulting in four possible sets of results. The shift scenario generally results in higher energy savings than the roll-up scenario. The market share apportionments as presented in chapter 9 provide for the breakdown of the stock by ballast design.

10.3.2.3 Site-to-Source Conversion Factors

The site-to-source conversion factor is the multiplier DOE uses for converting site-energy consumption into primary or source energy cons umption. For electricity, the conversion factors vary over time due to projected changes in generation sources ( i.e. , the power plant types projected to provide el ectricity to the country). For this rulemaking, DOE calculated annual average site-to-source conversion factors based on the version of the National Energy Modeling Systems (NEMS) that corresponds to the Energy Information Administration’s Annual Energy

Outlook (

AEO ). Table 10.3.2 presents site-to-source fact ors used in the NES spreadsheet model. The average conversion factors vary over time, due to projected changes in electricity generation sources. For the preliminary analysis, DOE used the site-to-source conversion factors from the

10-28

### 2008 version of the AEO ( AEO2008 ), and will update to the late st available version of the AEO during the next phase of the analysis. 1



### Table 10.3.2 Site-to-Source Conversion Factors

Year Site-to-Source

Conversion Factor

Btu/kWh Year Site-to-Source

Conversion Factor

Btu/kWh

2012 8,700 2028 10,400

2013 8,800 2029 10,400

2014 8,900 2030 10,400

2015 8,900 2031 10,400

2016 9,200 2032 10,400

2017 9,500 2033 10,400

2018 9,500 2034 10,400

2019 9,700 2035 10,400

2020 9,900 2036 10,400

2021 9,900 2037 10,400

2022 9,900 2038 10,400

2023 10,100 2039 10,400

2024 10,200 2040 10,400

2025 10,200 2041 10,400

2026 10,200 2042 10,400

2027 10,400

Source: AEO2008 . Conversion factors beyond 2030 are extrapolated.



### 10.3.2.4 Interactions with Heating, Ventilation, and Air-Conditioning (HVAC) Systems

Interactions with heating, ventilating, and air-conditioning systems in the commercial and industrial sectors are represented by an HVAC factor, as given in Eq. 10.3. The HVAC factor reflects the extent to which the energy savings from more efficient equipment are offset by increased demands placed on heating and cooling equipment in the presence of more efficient equipment. Typically this takes the form of increased efficiency being achieved through less energy wasted as heat, increasing the burden on HVAC equipment in wint er months. Consistent with the Lamps rule, DOE assumed an HVAC fa ctor of 1.06 in the co mmercial and industrial

sectors and assumed an HVAC factor of 1 for the residential sector.

10.3.2.5 Rebound Rate

In its analysis, DOE considers the rebound effect that occurs after installation of energyefficient lighting equipment. Under economic theo ry, “rebound effect” refers to the tendency of a consumer to respond to the cost savings associat ed with more efficient equipment in a manner that actually leads to marginally greater pr oduct usage, thereby diminishing some portion of anticipated benefits related to improved efficiency. DOE examined a summary of the literature regarding the rebound effect in relation to lighting equipment. 2 

### Based on four studies, the summary estimated that for a 100-percent increase in energy efficiency, “take-back” or rebound values for residential lighting are between 5 and 12 percent of energy consumption savings. The summary estimated zero to 2-pe rcent rebound values for commerc ial and industrial lighting.

10-29

### Therefore, in the calculation of national energy savings due to energy conservation standards on lighting, DOE calculated a rebound rate of 8.5 percen t in the residential s ector and 1 percent in

the commercial and i ndustrial sectors.

However, the take-back in energy consum ption associated with the rebound effect provides consumers with increased value ( e.g. , increased lighting hours, since the increased efficiency enables consumers to use their lighting equipment for longer periods of time). The impact on consumers is therefore the sum of the change in the cost of owning the lighting equipment ( i.e. , life-cycle cost [LCC]) and the increased value of more lighting hours. DOE has not been able to monetize this increase in consumer value in the LCC analysis. If it were able to monetize the increased value to consumers of the rebound effect, this value would be equal to or greater than the value of the foregone energy savings. For this analysis, DOE estimates that this value is equal to the monetary value of the ener gy savings that would have occurred without the rebound effect. Therefore, while the assumed rebound rate affects the calculated energy savings from amended standards, it does not affect the calculated monetary value of those savings.

10.4 NET PRESENT VALUE

10.4.1 Net Present Value Definition

The NPV is the value in the present of a time series of costs and savings. The NPV is

calculated as follows:

NPV = PVS

− PVC 

### Eq. 10.4

Where:

PVS = present value of operating cost savings, and

PVC = present value of increased total installed costs.

The PVS and PVC are determined according to the following expressions:



### PVS = 

# ∑ OCS

t 

### × DF

t 

### Eq. 10.5



### PVC = 

# ∑ TIC

t 

### × DF

t 

### Eq. 10.6

Where:



### OCS = total annual operating cost savings,



### TIC = total annual installed cost increases,



### DF = discount factor, and



### t = year ( 

### PVS and 

### PVC are summed over 2014-2044).

DOE determined the contributions to PVC and PVS for each year from the effective date of the standard, 2014 to 2044, discounted for th e preliminary analysis to 2008. DOE calculated costs and savings as the difference between a standards case ( 

### i.e. , with amended standards) and a base case ( 

### i.e. , without amended standards). DOE calcula ted a discount factor from the discount

10-30

### rate and the number of years between the “present” ( 

### i.e. , year to which the sum is being discounted) and the year in which the costs and savings occur. DOE calculated the net present

value as the sum over time of the discounted net savings (which is equivalent to the approach shown in Eqs. 10.4 through 10.6).

10.4.2 Net Present Value Inputs

Table 10.4.1 summarizes the inputs to the NPV calculation.

Table 10.4.1 Net Present Value Inputs

Input

Total Annual Installed Cost Increases ( TICt ) Total Annual Operating Cost Savings ( OCSt )

Discount Factor



### 10.4.2.1 Total Annual Installed Cost Increases

DOE calculated the increase in total annual in stalled costs as the difference between the

total annual installed cost s in the standards case minus those in the base case. For each case, the

total annual installed costs e qual the product of the shipments and per unit installed cost (summed over each ballast design). Although ballast designs often have slightly varying lifetimes, as discussed in chapter 9, DOE used an average lifetime of each ballast type for each product class. Therefore, to ensure the accurate calculation of NPV, DOE scaled the per unit installed costs of each lamp to account fo r this modification of ballast lifetime.

10.4.2.2 Total Annual Operating Cost Savings

As the LCC and payback period (PBP) analysis (preliminary TSD chapter 8) describes, DOE calculates total annual operating costs based on national average electricity prices. DOE calculates total annual operatin g cost savings as the differenc e between total annual operating

costs in the base case minus those in the st andards case. (The only component of annual operating cost for lamp-and-ballast systems that is different between the base case and the

standards case is the cost of electricity consumption.)



### OCS = 

# ∑ STOCK bd 

### × UEC bd 

### × electricity price Eq. 10.7

bd



### DOE uses an average number of annual opera ting hours for each sector and ballast type in calculating the UEC of each lamp-and-ballast design.

DOE uses national average commercial electricity prices for commercial sector 4-foot MBP, 8-foot slimline, and 4-foot T5 MiniBP SO systems. DOE uses national average industrial prices for the 8-foot RDC HO and 4-foot T5 Mi niBP HO systems. For 4-foot MBP systems in the residential sector, DOE uses national-average residential electricity prices for its analysis.

DOE uses 

### AEO2009 to establish all electricity prices. 3,4 

### Chapter 8 provides the electricity price

forecasts DOE uses to calculate the NPV.

10-31

### 10.4.2.3 Discount Factor

DOE multiplies monetary values in future year s by the discount factor (DF) to calculate the present value. The following equation desc ribes how to calculate the discount factor:

t

− t p 

### ) 

### DF = 

### 1 

# ( 1 + r 

# ) ( 

### Eq. 10.8

Where:



### r = discount rate,



### t = year of the monetary value, and



### t p 

### = year in which the present value is being determined.

DOE estimates national impacts with both a 3-pe rcent and a 7-percent real discount rate as the average real rate of return on private i nvestment in the U.S. economy. These discount rates are used in accordance with the Office of Management and Budget (OMB)’s guidance to Federal agencies on the development of regulatory an alysis (OMB Circular A-4, September 17, 2003), and section E, “Identifying and Measuring Benefits and Costs,” therein. 5 

### DOE defined the present year as 2014 (the first year of th e standard) for this preliminary analysis.

10.5 NATIONAL ENERGY SAVINGS AND NET PRESENT VALUE RESULTS

The NES spreadsheet model provides estimates of the NES and NPV due to various CSLs. The inputs to the NES spreadsheet are discussed in sections 10.3.2 and section 10.4.2. DOE generated the NES and NPV results using Microsoft Excel spreadsheets, accessible at http://www.eere.energy.gov/buildings/appliance_st andards/residential/fl uorescent_lamp_ballasts

. html . Appendix 10A provides instructions for using the spreadsheets.

10.5.1 National Energy Savings and Net Present Value Input Summary

Table 10.5.1 summarizes the inputs to the NES sp readsheet model. A brief description of the data is given for each input.

10-32

### Table 10.5.1. National Energy Saving and Net Present Value Inputs

Input Data Data Description

Shipments Annual shipments from the ballast shipment model (preliminary TSD chapter 9).

Stock of Ballasts Established based on the calculated 2014 ballast stock, the service life of ballasts, penetration of emerging technologies, and annual shipments. The 2014 initial stock is based on estimated historical shipments based on U.S.Census Bureau Current Industrial Reports data, estimated ballast service lifetimes, and the assumed growth rate of the historical stock from 1990–2013 (preliminary TSD chapter 9).

Effective Date of Standard 2014

Analysis Period 2014 to 2044

Unit Energy Consumption (kWh/yr) Established in the Energy-Use Characterization (preliminary TSD chapter 6) by lamp-and-ballast design and sector.

Total Installed Cost Established in the Markups Analysis (preliminary TSD chapter 7) and the LCC Analysis (preliminary TSD chapter 8) by lamp-and-ballast designs.

Electricity Price Forecast EIA forecasts (to 2030) from the AEO2009 (original, or March, version*) and extrapolation for beyond 2030 (preliminary TSD chapter 8).

Electricity Site-to-Source Conversion Conver sion varies yearly and was generated by AEO2008 forecasts (to 2030) of electricity generation and electricity-related losses. Conversion factors beyond 2030 are extrapolated.

HVAC Interaction Savings Negligible.

Rebound Effect 1% of total energy savings in the commercial sector 8.5% of total energy savings in the residential sector

Discount Rate 3 and 7 percent real.

Present Year Future costs and savings are discounted to 2014.

*While this analysis relied on the most recent (April 2009) version of the AEO where possible, that version was only a partial update and did not include sufficient information to extrapolate high- and low-price scenario. Accordingly, DOE used the March 2009 version for electricity price scenarios.



### 10.5.2 National Energy Savings Results

The following section provides NES results for each CSL that DOE considers for ballasts. Results are cumulative to 2044 and are shown as primary energy savings measured in quads

. As discussed earlier, DOE analyzes several sh ipment scenarios for ballasts. In this section DOE presents only upper and lower bound energy savi ngs and net present value results (from the existing/shift and emerging/roll-up scenarios, respectively).

Table 10.5.2 and Table 10.5.3 show the NES resu lts under the existing technologies, shift scenario, which reflects the upper bound of energy savings, and the emerging, roll-up scenario, which reflects the lower bound, respectively. Due to a larger reduction in th e installed stock of ballasts affected by standards, the emerging technologies base-case forecast results in lower energy savings than the existing technologies base -case forecast. Finally, because in the shift scenario more consumers move to higher-efficiency lamp-and-ballast systems than in the roll-up scenario, the shift scenario results in higher energy savings than the roll-up scenario.

Table 10.5.2 and Table 10.5.3 present total national energy savings for each CSL by ballast type and in total. However, it is importa nt to note that the numbers presented in these

10-33

### tables are calculated assuming that all ballast types face the same trial standard level. This matters because in some cases the regulation of certain ballast types affects the savings from regulating others. If different ballasts are regulated at different standard levels, savings will vary somewhat from the values given here. Nevertheless, these savings illustrate the expected relative energy savings of each ballast type under a given CSL.

Table 10.5.2. Cumulative National Energy Savings for Ballasts under the Existing, Shift
Scenario (2014-2044)

CSL Ballast Product Class NES Discount *
quads

None Percentage

7 3

1 Two-Lamp Normal BF 4-Foot MBP IS & RS 1.632 0.359 0.813 Two-Lamp Normal BF 4-Foot MBP PS 0.251 0.050 0.120 Four-Lamp Normal BF 4-Foot MBP IS & RS -0.395 -0.088 -0.197 Four-Lamp Normal BF 4-Foot MBP PS 0.133 0.025 0.062 Two-Lamp Normal BF 8-Foot RDC HO IS & RS 0.013 0.005 0.009 Two-Lamp Normal BF 8-Foot SP Slimline (T12 Baseline) 0.000 0.000 0.000 Two-Lamp Normal BF 8-Foot SP Slimline (T8 Baseline) 0.022 0.005 0.011 Two-Lamp Normal BF 4-Foot T5 Minibp SO 1.923 0.345 0.877 Two-Lamp 4-Foot T5 MiniBP HO 0.710 0.149 0.346 Two-Lamp Low BF 4-Foot MBP IS & RS Residential -0.135 -0.029 -0.066 Four-Lamp Sign Ballasts 4.986 1.069 2.453

Total 9.140 1.891 4.427

2 Two-Lamp Normal BF 4-Foot MBP IS & RS 1.725 0.388 0.868 Two-Lamp Normal BF 8-Foot RDC HO IS & RS 0.014 0.006 0.010 Two-Lamp Normal BF 4-Foot T5 MiniBP SO 2.264 0.422 1.050 Two-Lamp 4-Foot T5 MiniBP HO 0.744 0.161 0.368 Two-Lamp Low BF 4-Foot MBP IS & RS Residential -0.136 -0.029 -0.067

Total 4.382 0.949 2.228

3 Two-Lamp Normal BF 4-Foot MBP IS & RS 1.725 0.388 0.868

Total 1.727 0.388 0.868

* Note that energy savings for individual ballast product classes (due to separate regulation) do not sum to equal total energy savings achieved at the CSLs due to standards-induced substitution effects among ballast types.

10-34

### Table 10.5.3. Cumulative National Energy Savings for Ballasts under the Emerging, RollUp Scenario (2014-2044)

CSL Ballast Product Class NES Discount *
quads

None Percentage

7 3

1 Two-Lamp Normal BF 4-Foot MBP IS & RS 0.000 0.000 0.000 Two-Lamp Normal BF 4-Foot MBP PS 0.135 0.032 0.069 Four-Lamp Normal BF 4-Foot MBP IS & RS -0.242 -0.062 -0.129 Four-Lamp Normal BF 4-Foot MBP PS 0.067 0.015 0.034 Two-Lamp Normal BF 8-Foot RDC HO IS & RS 0.006 0.003 0.005 Two-Lamp Normal BF 8-Foot SP Slimline (T12 Baseline) 0.000 0.000 0.000 Two-Lamp Normal BF 8-Foot SP Slimline (T8 Baseline) 0.022 0.005 0.011 Two-Lamp Normal BF 4-Foot T5 Minibp SO 0.825 0.178 0.407 Two-Lamp 4-Foot T5 MiniBP HO 0.582 0.126 0.288 Two-Lamp Low BF 4-Foot MBP IS & RS Residential -0.006 -0.002 -0.003 Four-Lamp Sign Ballasts 4.986 1.069 2.453

Total 6.375 1.365 3.136

2 Two-Lamp Normal BF 4-Foot MBP IS & RS 0.913 0.235 0.488 Two-Lamp Normal BF 8-Foot RDC HO IS & RS 0.016 0.007 0.011 Two-Lamp Normal BF 4-Foot T5 MiniBP SO 1.209 0.261 0.597 Two-Lamp 4-Foot T5 MiniBP HO 0.744 0.161 0.368 Two-Lamp Low BF 4-Foot MBP IS & RS Residential -0.136 -0.029 -0.067

Total 2.746 0.635 1.397

3 Two-Lamp Normal BF 4-Foot MBP IS & RS 1.050 0.270 0.562

Total 1.050 0.270 0.562

* Note that energy savings for individual ballast product classes (due to separate regulation) do not sum to equal total energy savings achieved at the CSLs due to standards-induced substitution effects among ballast types.



### 10.5.3 Net Present Value Analysis

The NPV calculation attempts to calculate the total monetary costs and benefits of the

standard for all consumers of ballasts. This calculation relies primarily on two inputs: the NES calculations described in the previous section, whic h are translated into a decrease (or in some cases increase) in operating costs; and the increase (or in some cases decrease) in installed costs.

This section graphs both elements of NPV over time. Figure 10.5.1 through Figure

10.5.10 present the discounted annua l total installed cost increa ses and annual operating cost savings at the national level using a 7-percent discount rate. Both annua l total installed cost increases and annual operating costs saving s accumulate from 2014 to 2044. The figures also present the NPV, which is the difference betw een cumulative annual disc ounted operating cost savings and the cumulative annual discounted total in stalled cost increases.

10-35

### 30

20

10 Discounted Operating

Cost Savings

Discounted Installed Cost 

### 0 Increase20142017202020232026202920322035203820412044Millions



### Total NPV



### ‐ 10

‐ 20

‐ 30

Figure 10.5.1. National Annual Total Installed E quipment and Operating Cost Savings for
4-Foot MBP (Residential) at CS L3 (Existing Technologies, Shif t Scenario) Discounted at 7
Percent per Year

30

20

10 Discounted Operating20142017202020232026202920322035203820412044Millions 

### Cost Savings

Discounted Installed Cost 

### 0 Increase

Total NPV



### ‐ 10

‐ 20

‐ 30



### Figure 10.5.2. National Annual Total Installed E quipment and Operating Cost Savings for
4-Foot MBP (Residential) at CSL3 (Emerging Technologies, Roll-Up Scenario) Discounted
at 7 Percent per Year

10-36

### ‐ 1,000 ‐ 800 ‐ 600 ‐ 400 ‐ 200 0 200 400 600 800 1,00020142017202020232026202920322035203820412044Millions 

### Discounted Operating

Cost Savings

Discounted Installed Cost

Increase

Total NPV



### Figure 10.5.3. National Annual Total Installed E quipment and Operating Cost Savings for
4-Foot MBP (Commercial) at CSL3 (Existing T echnologies, Shift Scenario) Discounted at 7
Percent per Year

‐ 1,000

‐ 800 ‐ 600 ‐ 400 ‐ 200 0 200 400 600 800 1,00020142017202020232026202920322035203820412044Millions Discounted Operating

Cost Savings

Discounted Installed Cost

Increase

Total NPV



### Figure 10.5.4. National Annual Total Installed Equipment and Operating Cost Savings for
4-Foot MBP (Commercial) at CSL3 (Existing Te chnologies, Shift Scenario) Discounted at 7
Percent per Year

10-37

### ‐ 4 ‐ 3 ‐ 2 ‐ 1 0 1 2 3 4 520142017202020232026202920322035203820412044Millions 

### Discounted Operating

Cost Savings

Discounted Installed Cost

Increase

Total NPV



### Figure 10.5.5. National Annual Total Installed E quipment and Operating Cost Savings for
8-Foot Slimline at CSL3 (Exist ing Technologies, Shift Scenar io) Discounted at 7 Percent
per Year

‐ 4 ‐ 3 ‐ 2 ‐ 1 0 1 2 3 4 520142017202020232026202920322035203820412044Millions 

### Discounted Operating

Cost Savings

Discounted Installed Cost

Increase

Total NPV



### Figure 10.5.6. National Annual Total Installed E quipment and Operating Cost Savings for
8-Foot Slimline at CSL3 (Emerging Technol ogies, Roll-Up Scenario ) Discounted at 7
Percent per Year

10-38

### 0 100 200 300 400 500 600 700 800 900 1,00020142017202020232026202920322035203820412044Millions 

### Discounted Operating

Cost Savings

Discounted Installed Cost

Increase

Total NPV



### Figure 10.5.7. National Annual Total Installed E quipment and Operating Cost Savings for
8-Foot RDC HO at CSL3 (Existing Technologies, Shift Scenario) Discounted at 7 Percent
per Year

0 100 200 300 400 500 600 700 800 900 1,00020142017202020232026202920322035203820412044Millions 

### Discounted Operating

Cost Savings

Discounted Installed Cost

Increase

Total NPV



### Figure 10.5.8. National Annual Total Installed E quipment and Operating Cost Savings for
8-Foot RDC HO at CSL3 (Emerging Technologies, Roll-Up Scenario) Discounted at 7
Percent per Year

10-39

### 0 50 100 150 200 25020142017202020232026202920322035203820412044Millions Discounted Operating

Cost Savings

Discounted Installed Cost

Increase

Total NPV



### Figure 10.5.9. National Annual Total Installed E quipment and Operating Cost Savings for
4-Foot Miniature Bipin T5 Standard Output and High Output at CSL3 (Existing
Technologies, Shift Scenario) Disc ounted at 7 Percent per Year

0 20 40 60 80 100 120 140 160 180 20020142017202020232026202920322035203820412044Millions Discounted Operating

Cost Savings

Discounted Installed Cost

Increase

Total NPV



### Figure 10.5.10. National Annual Total Installed E quipment and Operating Cost Savings for
4-Foot Miniature Bipin T5 Standard Output and High Output at CSL3 (Emerging
Technologies, Roll-Up S cenario) Discounted at 7 Percent per Year

In most cases the operating cost savings, installed costs increases, and NPV all trend towards zero over time, reflecting the impacts of discounting.

10-40

### NPV results are cumulative and shown as the discounted value of these savings in dollar terms. DOE uses national averages for key inputs such as electricity pricing and sector-specific point values for operating hours in calculating opera ting cost savings and inst alled cost increases. Thus, the NPV results are discrete point values rath er than a distribution of values as in the LCC and PBP analyses.

The present value of increased total installed costs is the total installed cost increase ( 

### i.e.

, the difference between the standards case and base case in given year), discounted to the present, and summed over the time period in which DOE evaluates the impact of standards ( 

### i.e. , from the effective date of standards, 2014 to 2044).

Savings are decreases in operating costs associated with higher efficiency ballasts purchased in the standards case compared to the base case. DOE calculated total annual operating cost savings as the difference betwee n total annual operating costs in the base case minus those in the standards case. Eq. 10.7 gives the total annual operating costs in each case.

In general, the NPV results at each candidate? standard level largely reflect the LCC savings at the corresponding efficiency leve ls. As discussed in chapter 8 (LCC and PBP analyses), for most ballast purchasing events and most baseline ballast designs, increasingefficiency levels generally result in increased LCC savings. Due to this general costeffectiveness of higher efficiency ballasts, th e existing technologies base-case forecast (which increases the affected stock and shipments) and the shift scenario (which results in the shipment of more high-efficiency ballasts) represent the high-range scenario for NPV.

10.5.4 Net Present Value Results

Table 10.5.4 and Table 10.5.5 show the NPV resu lts in tabular format, including the existing technologies/shift scenario and the emerging technologies/roll-up scenario, as in section

Error! Reference source not found. . In these tables, NPV is presented at both 7- and 3-percent

discount rates.

10-41

### Table 10.5.4. Cumulative NPV Results for Ballasts Under the Existing Technologies, Shift
Scenario (2014-2044)

CSL Ballast Product Class Percent NPV Discount *

billion 2008$

7 3

1 Two-Lamp Normal BF 4-Foot MBP IS & RS 9.046 18.490 Two-Lamp Normal BF 4-Foot MBP PS 0.276 0.872 Four-Lamp Normal BF 4-Foot MBP IS & RS -1.536 -3.062 Four-Lamp Normal BF 4-Foot MBP PS 0.143 0.459 Two-Lamp Normal BF 8-Foot RDC HO IS & RS 0.060 0.089 Two-Lamp Normal BF 8-Foot SP Slimline (T12 Baseline) 0.000 0.000 Two-Lamp Normal BF 8-Foot SP Slimline (T8 Baseline) 0.007 0.049 Two-Lamp Normal BF 4-Foot T5 Minibp SO 3.408 9.204 Two-Lamp 4-Foot T5 MiniBP HO 1.049 2.570 Two-Lamp Low BF 4-Foot MBP IS & RS Residential 0.000 -0.268 Four-Lamp Sign Ballasts 9.900 23.364

Total 22.353 51.770

2 Two-Lamp Normal BF 4-Foot MBP IS & RS 14.931 25.847 Two-Lamp Normal BF 8-Foot RDC HO IS & RS 0.091 0.134 Two-Lamp Normal BF 4-Foot T5 MiniBP SO 4.366 11.284 Two-Lamp 4-Foot T5 MiniBP HO 1.169 2.762 Two-Lamp Low BF 4-Foot MBP IS & RS Residential 0.000 -0.270

Total 20.557 39.757

3 Two-Lamp Normal BF 4-Foot MBP IS & RS 14.931 25.847

Total 14.945 25.877



### Table 10.5.5. Cumulative NPV Results for Ballas ts Under the Emerging Technologies, RollUp Scenario (2014-2044)

CSL Ballast Product Class Percent NPV Discount
billion 2008$

7 3

1 Two-Lamp Normal BF 4-Foot MBP IS & RS 0.000 0.000 Two-Lamp Normal BF 4-Foot MBP PS 0.181 0.520 Four-Lamp Normal BF 4-Foot MBP IS & RS -1.060 -1.945 Four-Lamp Normal BF 4-Foot MBP PS 0.088 0.256 Two-Lamp Normal BF 8-Foot RDC HO IS & RS 0.035 0.051 Two-Lamp Normal BF 8-Foot SP Slimline (T12 Baseline) 0.000 0.000 Two-Lamp Normal BF 8-Foot SP Slimline (T8 Baseline) 0.007 0.049 Two-Lamp Normal BF 4-Foot T5 MiniBP SO 1.633 4.035 Two-Lamp 4-Foot T5 MiniBP HO 0.822 2.010 Two-Lamp Low BF 4-Foot MBP IS & RS Residential -0.012 -0.042 Four-Lamp Sign Ballasts 9.900 23.364

Total 11.594 28.299

2 Two-Lamp Normal BF 4-Foot MBP IS & RS 2.830 5.736 Two-Lamp Normal BF 8-Foot RDC HO IS & RS 0.106 0.153 Two-Lamp Normal BF 4-Foot T5 MiniBP SO 2.667 6.345 Two-Lamp 4-Foot T5 MiniBP HO 1.169 2.762 Two-Lamp Low BF 4-Foot MBP IS & RS Residential (T12 Baseline) 0.000 -0.270

Total 6.773 14.725

3 Two-Lamp Normal BF 4-Foot MBP IS & RS 10.189 16.086

Total 10.189 16.086

10-42

### REFERENCES

1. U.S. Department of Energy–E nergy Information Administration. 

### Annual Energy Outlook 2008 with Projections to 2030

. June 2008. Washington, D.C.

< http://www.eia.doe.gov/oiaf/archive/aeo08/index.html >.

2. Greening, L.A., D.L. Greene, and C. Difiglio. 2000. Energy Efficiency and Consumption–The Rebound Effect: A Survey. 

### Energy Policy . 28: pp. 389–401.

3. U.S. Department of Energy–E nergy Information Administration. 

### Annual Energy Outlook 2009 with Projections to 2030

. March 2009. Washington, D.C.

< http://www.eia.doe.gov/oiaf/aeo/aeoref_tab.html >.

4. U.S. Department of Energy–E nergy Information Administration. 

### Annual Energy Outlook 2009 with Projections to 2030 . Updated reference case. April 2009. Washington, D.C.

< http://www.eia.doe.gov/oiaf/aeo/index.html >.

5. Office of Management and Budget. Circ ular A-4. September 2003. Washington, D.C.

< http://www.whitehouse.gov/omb/circulars/a004/a-4.pdf >.

10-43

### CHAPTER 11. LIFE-CYCLE COST SUBGROUP ANALYSIS

TABLE OF CONTENTS

11.1 INTRODUCTION

............................................................................................................ 11 -1

11.2 GENERAL APPROACH

.................................................................................................. 11-1

11-i

### CHAPTER 11. LIFE-CYCLE COST SUBGROUP ANALYSIS

11.1 INTRODUCTION

The life-cycle cost (LCC) subgroup analysis evaluates impacts of standards on identifiable groups, such as different consumer populations or business types that may be disproportionately affected by any national energy conservation standard level. In the notice of proposed rulemaking, the U.S Depa rtment of Energy (DOE) will analyze the LCCs and payback periods (PBPs) for consumers that fall into such groups. The analysis will determine whether any particular group of consumers would be adversely affected by any of the trial standard levels (TSLs).

Using the LCC spreadsheet model, DOE plans to examine variations in energy prices and energy use that might affect the net present valu e of a standard for consumer sub-populations. As described in chapter 8 of the preliminary t echnical support document, the preliminary LCC analysis includes various consumer types who use fluorescent lamp-and-ballast systems. This analysis includes consumers purchasing systems in different sectors, purchasing systems for different building types, replacing differen t baseline systems, and undergoing different purchasing events.

11.2 GENERAL APPROACH

For fluorescent lamp-and-ballast systems, DOE estimates LCC savings and PBPs for consumers in the residential, commercial, and industrial sectors. Fluorescent lamps will not be regulated under the proposed ballast rulemaking but are considered in the energy use analysis (chapter 6) to determine energy consumption of ballasts. DOE also analyzes the LCC impacts on consumers living in or operating different buildings in the residential, co mmercial, and industrial sectors. For example, DOE analyzes the impact of standards for people running educational facilities and for those who live in a mobile home. DOE also analyzes impacts on consumers in different regions of the country.

In addition, DOE evaluates the LCC impact s on consumers who purchase different baseline lamp-and-ballast systems. For example, the economic impacts of a standard will be

different for a consumer who ow ns a typical 4-foot T8 versus a 4-foot T12 lamp-and-ballast

system.

DOE also analyzes the LCC impact of a standard on consumers faced with a variety of different lamp-and-ballast purch asing events. The LCC impacts on a consumer who must replace a ballast in an existing system versus the purchas e of a lamp-and-ballast system for new building

construction are different.

In the LCC subgroup analysis, DOE will exa mine a variety of consumer sub-populations. This analysis will determine whether any par ticular group of consumers would be adversely affected by any of the TSLs.

11-1

### CHAPTER 12 PRELIMINARY MANUFACTURER IMPACT ANALYSIS

TABLE OF CONTENTS

12.1 INTRODUCTION

......................................................................................................... 12-1

12.2 METHODOLOGY

........................................................................................................ 12-1

12.2.1 Phase I: Industry Profile

..................................................................................... 12-2

12.2.2 Phase II: Industry Cash-Flow Analysis and Interview Guide

............................ 12-2

12.2.2.1 Industry Cash-Flow Analysis

........................................................... 12-2

12.2.2.2 Interview Guide

............................................................................... 12-2

12.2.3 Phase III: Subgroup Analysis

............................................................................. 12-3

12.2.3.1 Manufacturer Interviews

.................................................................. 12-3

12.2.3.2 Revised Industry Cash-Flow Analysis

............................................. 12-3

12.2.3.3 Manufacturer Subgroup Analysis

.................................................... 12-3

12.2.3.4 Competitive Impact Assessment

...................................................... 12-4

12.2.3.5 Manufacturing Capacity Impact

...................................................... 12-4

12.2.3.6 Employment Impact

......................................................................... 12-4

12.2.3.7 Cumulative Regulatory Burden

....................................................... 12-4

12.3 INDUSTRY OVERVIEW

............................................................................................. 12-4

12.3.1 Industry Cost Structure

...................................................................................... 12-5

12.3.2 Inventory Levels and Cap acity Utilization Rates

.............................................. 12-5

12.4 INTERVIEW TOPICS AND PRELIMINARY FINDINGS

......................................... 12-6

12.4.1 Market Shares and Industry Consolidation

........................................................ 12-6

12.4.1.1 Market Assessment

.......................................................................... 12-7

12.4.1.2 Impact on Small Manufacturers

....................................................... 12-7

12.4.2 Production and Pr oduct Mix

.............................................................................. 12-7

12.4.2.1 Impact on Product Mix

.................................................................... 12-7

12.4.2.2 Product Utility

.................................................................................. 12-8

12.4.3 Conversion Costs

............................................................................................... 12-8

12.4.4 Cumulative Regulatory Burden

......................................................................... 12-8

12.5 OVERALL KEY ISSUES

............................................................................................. 12-9

12.5.1 Impacts on Profitability

...................................................................................... 12-9

12.5.2 Product Conversion Costs/Diminishi ng Returns to Consumers

........................ 12-9

12.5.3 Product Innovation

............................................................................................. 12-9

LIST OF TABLES

Table 12.3.1 Fluorescent Lamp Ballast Industry Employment and Earnings

.................... 12-5

Table 12.3.2 Fluorescent Lamp Ballast Industry Material and Payroll Costs

.................... 12-5

Table 12.3.3 Fluorescent Lamp Ballast Industry End-of-Year Inventory

.......................... 12-6

Table 12.3.4 Full Production Capacity Utilization Rates

................................................... 12-6

12-i

### CHAPTER 12 PRELIMINARY MANUFACTURER IMPACT ANALYSIS

12.1 INTRODUCTION

The purpose of the manufacturer impact analysis (MIA) is to identify and quantify the likely impacts of amended energy conservation standards on manufacturers. The Process Rule a 

### provides guidance for conducting this analysis with input from manufacturers and other interested parties. The U.S. Department of Energy (DOE) a pplies this methodology to its evaluation of amended energy conservation standard s for fluorescent lamp ballasts to the extent that it is appropriate for this rulemaking. The Process Rule gives guidelines for considering financial impacts and a wide ra nge of quantitative and qualitative industry impacts that might occur due to an amended energy conservation stan dard. For example, a particular standard level could require changes in manufact uring practices for fluorescent lamp ballasts. DOE identifies and analyzes these impacts through interviews with manufacturers and other interested parties during the notice of proposed rulemaking (NOPR) stage of analysis.

DOE announced changes to the MIA format through a report issued to Congress on January 31, 2006 (as required by section 141 of the Energy Policy Act of 2005 (EPACT 2005)), entitled “Energy Conservation Standards Activities.” b 

### Previously, DOE did not report any MIA results before the NOPR phase; however, under this new format, DOE collects, evaluates, and reports preliminary information and data in the Preliminary Analysis. Such information includes market data, key issues, produc t mixes, conversion costs, foreign competition, market shares, industry consolidation, and cumulative regulatory burden information. DOE solicits this information during the preliminary manufacturer interviews and reports the results in this chapter. Appendix 12A includes a copy of th e interview guide that DOE distributed to

manufacturers.

12.2 METHODOLOGY

DOE conducts the MIA in three phases. In Phase I, DOE creates an industry profile to characterize the industry and conducts preliminary MIA interviews to identify important issues that require consideration. Sec tion 12.3 of this chapter presents initial findings of the Phase I analysis. In Phase II, DOE prepares an industr y cash flow model and an interview questionnaire to guide subsequent discussions with manufactur ers. In Phase III, DOE interviews manufacturers and assesses the impacts of amended energy conservation standards both quantitatively and qualitatively. DOE assesses industry and subgroup cash flow impacts and the industry net present value (INPV) using the Government Regulatory Impact Model (GRIM). DOE then

a On July 15, 1996, the Department published a Process Improvement Rule establishing procedures, interpretations and policies to guide the Department in the consideration of new or revised appliance efficiency standards (Procedures for Consideration of New or Revised Energy Conservation Standards for Consumer Products). 61 FR

36974.

b This report is available on the DOE website at www.eere.energy.gov/buildings/appliance_standards/2006_schedule_setting.html

.



### 12-1

### assesses impacts on competition, ma nufacturing capacity, employment, and regulatory burden

based on manufacturer interv iews and discussions. The Federal Register NOPR and technical support document (TSD) will both present results of the Phase II and III analyses.

12.2.1 Phase I: Industry Profile

In Phase I of the MIA, DOE collects pertinent qualitative and quantitative financial and market information. This includes wages, empl oyment, and industry costs for fluorescent lamp

ballasts. Sources of information include reports published by indus try groups, trade journals, the

U.S. Census Bureau, and Securities Exchange Commission (SEC) 10-K filings. In addition, DOE

relies on information from its mark et and technology assessment, engineering analysis, life-cycle cost analysis, and consumer price analysis to characterize the fluorescent lamp ballast manufacturing industry.

12.2.2 Phase II: Industry Cash-Flow Analysis and Interview Guide

In Phase II, DOE performs a preliminary industry cash-flow analysis and prepares a questionnaire, or interview guide, for interviewing manufacturers.

12.2.2.1 Industry Cash-Flow Analysis

DOE uses the GRIM to analyze the financia l impacts of amended energy conservation standards. Amended energy conservation standa rds may require additi onal investment, raise production costs, and/or affect re venue through higher prices and possibly lower shipments. The

GRIM uses several factors to determine a series of annual cash flows for the year that amended energy conservation standards become effectiv e and for several years after implementation. These factors include annual expected revenues, costs of sales, selling and general administration costs, taxes, and capital expenditures. Inputs to the GRIM include financial information, manufacturing costs, shipment forecasts, and price forecasts developed in other analyses. Financial information is developed based on publicly available data and confidentially submitted manufacturer information. DOE compares the GRIM results for standards case at each trial standard level against the results for the base case in which no amended energy conservation standards are in place. The financial impact of amended energy conservation standards is the

difference between the two sets of discounted annual cash flows.

12.2.2.2 Interview Guide

DOE conducts interviews with manufacturers to gather in formation on the effects of amended energy conservation standards on revenu es and finances, direct employment, capital assets, and industry competitiveness. These interv iews take place during Phase III of the MIA. Before the interviews, DOE distributes an interview guide that will help identify the impacts of amended energy conservation standards on individual manufacturers or subgroups of manufacturers. The interview guide covers produc tion costs; shipment projections and market share; product mix; conversion co sts; markups and profitability; assessment of the impact on competition, manufacturing capacity; and other topics that are relevant to assessing the impacts of amended energy conservation standards on the fluorescent lamp ballast industry.

12-2

### 12.2.3 Phase III: Subgroup Analysis

Phase III activities occur after publication of the preliminary analysis. These activities

include manufacturer interviews ; revision of the industry cash-flow analysis; a manufacturer subgroup analysis; an assessment of the impacts on industry competition, manufacturing capacity, direct employment, and the cumulative regulatory burden; and other qualitative impacts.

12.2.3.1 Manufacturer Interviews

DOE supplements the information gathered in Phase I and the cash-flow analysis performed in Phase II with information gather ed through interviews with manufacturers during Phase III. The interview process has a key role in the MIA because it provides an opportunity for interested parties to express their views privately on important issues.

DOE conducts detailed interviews with manufacturers to gain insight into the potential impacts of amended energy conservation standard s on sales, direct empl oyment, capital assets, and industry competitiveness. Interviews are scheduled well in advance to provide every opportunity for key individuals to be availabl e for comment. Although a written response to the questionnaire is acceptable, DOE prefers interactiv e interviews, which help clarify responses and provide the opportunity to identify additional issues.

A non-disclosure agreement allows DOE to consider confidential or sensitive information in the decision-making process. Ho wever, confidential information is not made available in the public record. At most, sensitive or confidential information may be aggregated and presented in industry-wide representations.

12.2.3.2 Revised Industry Cash-Flow Analysis

During the interviews, DOE requests inform ation about profitabilit y impacts, necessary plant changes, and other manufacturing impacts. Following the interviews, DOE revises the preliminary GRIM prepared in Phase II based on the feedback it receives.

12.2.3.3 Manufacturer Subgroup Analysis

Using average cost assumptions to devel op an industry cash-flow estimate does not adequately assess differential impacts among ma nufacturer subgroups. Smaller manufacturers, niche players, and manufacturers exhibiting a cost structure that differs largely from the industry average could be more negatively affected. Id eally, DOE would consider the impact on every firm individually; however, it typically uses the results of the industry characterization to group manufacturers with similar characteristics. During the interviews, DOE discusses the potential subgroups that have been identified for th e analysis. DOE asks manufacturers and other interested parties to suggest what subgroups or characteristics are most appropriate for the analysis.

12-3

### 12.2.3.4 Competitive Impact Assessment

Section 342 (6)(B)(i)(V) of the Energy Policy Act of 1992 (EPCA) directs DOE to consider any lessening of competition likely to result from imposition of standards. EPCA further directs the U.S. Attorney General to determine the impacts, if any, of any decrease in competition. DOE makes a determined effort to gather firm-speci fic financial information and impacts and report the results in the competitive impact assessment. The competitive impact

assessment is based on manufacturer cost data and information collected from the manufacturer interviews. The interviews focus on assessing asymmetrical cost increases to some manufacturers, the potential increase in busine ss risks from an increased proportion of fixed costs, and potential barriers to market entry ( e.g ., proprietary technolog ies). The competitive impact analysis also focuses on assessing any differential impacts to smaller manufacturers.

12.2.3.5 Manufacturing Capacity Impact

One of the significant outcomes of amended energy conservation standards can be the obsolescence of existing manufacturing assets, in cluding tooling and other investments. The manufacturer interview guide has a series of que stions to help identify impacts on manufacturing capacity, specifically capacity utilization and plant location decisions in North America with and without an amended energy conservation standard; the ability of manufacturers to upgrade or remodel existing facilities to acco mmodate the new requirements; the nature and value of stranded assets, if any; and estimates for any one-time restructuring or other charges, where applicable.

12.2.3.6 Employment Impact

The impact of amended energy conservation standards on employment is an important consideration in the rulemaking process. To as sess how domestic employ ment patterns might be affected, the manufacturer interviews explore curre nt employment trends in the fluorescent lamp ballast industry and solicits manuf acturer views on changes in employment patterns that may result from increased standard levels. The employment impacts section of the interview guide focuses on current employment levels at production facilities, expected future employment levels with and without an amended energy conservati on standard, differences in workforce skills, and employee retraining.

12.2.3.7 Cumulative Regu latory Burden

DOE seeks to mitigate the overlapping effects on manufacturers of energy conservation standards and other regulatory actions affecting the same products or companies. DOE analyzes and considers the impact on manufacturers of multiple, product-specific regulatory actions.

12.3 INDUSTRY OVERVIEW

The following section summarizes publicly available industry data.

12-4

### 12.3.1 Industry Cost Structure DOE developed the fluorescent lamp ballast i ndustry cost structure from the U.S. Census
Bureau, Annual Survey of Manufacturers

, Statistics for Industry Groups and Industries from 2003 to 2006. Fluorescent lamp ballast manufacturin g is classified under the North American Industry Classification System (NAICS) code 335311 ( Power, Distribution, and Specialty Transformer Manufacturing ).

Table 12.3.1 presents the fluorescent lamp balla st employment levels and earnings from 2003 to 2006. The statistics illustrate a 3-percen t increase in the number of production workers from 2003 to 2006; however, there was no major cha nge in the overall number of employees in the industry.

Table 12.3.1 Fluorescent Lamp Ballast Industry Employment and Earnings

Year Production Workers All Employees Payroll for All Employees thousand

2006 dollars

2003 14,966 20,546 755,635

2004 13,635 18,692 720,767

2005 14,471 19,427 779,246

2006 15,438 20,642 863,266

U.S. Census Bureau. 2006 Annual Survey of Manufacturers: 2006 and Earlier Years . December 2006.



### Table 12.3.2 presents the costs of materials and industry payroll as a percentage of shipment value from 2003 to 2006. The cost of materials has increased slightly from 2003 to 2006. The cost of payroll for production workers a nd the cost of total payroll declined by 5.4 percent and 8.5, percent respectively.

Table 12.3.2 Fluorescent Lamp Ballast Industry Material and Payroll Costs

Year Cost of Materials percent of shipment value Cost of Payroll

for Production Workers percent of shipment value Cost of Total Payroll:

Production + Administration

percent of shipment value

2003 49.5 11.0 18.8

2004 51.1 11.8 19.4

2005 51.7 11.1 18.2

2006 51.8 10.4 17.2

U.S. Census Bureau. 2006 Annual Survey of Manufacturers: 2006 and Earlier Years . December 2006.



### 12.3.2 Inventory Levels and Capacity Utilization Rates

Table 12.3.3 shows the year-end inventory fo r the fluorescent lamp ballast industry obtained from the U.S. Census Bureau, Annual Survey of Manufacturers

, Statistics for Industry Groups and Industries from 2003 to 2006. The industry’s end-of-year inventory from 2002 to 2005 experienced an overall increase when expre ssed both in dollars and as a percentage of shipment value.

12-5

### Table 12.3.3 Fluorescent Lamp Ballast Industry End-of-Year Inventory

Year End-of-Year Inventory

million 2006 dollars End-of-Year Inventory percent of shipment value

2003 502,089 12.5

2004 427,802 11.5

2005 511,504 12.0

2006 637,235 12.7

U.S. Census Bureau. 2006 Annual Survey of Manufacturers: 2006 and Earlier Years . December 2006.



### DOE obtained full production capacity utilization rates from the U.S. Census Bureau, “Current Industrial Reports,” Survey of Plant Capacity from 2002 to 2006. Table 12.3.4 presents production capacity utilization rates for NAICS code 335311. Full production capacity is defined as the maximum level of produc tion an establishment could attain under normal operating

conditions. In the Survey of Plant Capacity report, the full production utiliz ation rate is a ratio of the actual level of operations to the full production level.

Table 12.3.4 Full Production Ca pacity Utilization Rates

Year Power, Distribution, and Specialty Transformer Manufacturing

Percent

2002 63

2003 61

2004 63

2005 66

2006 69

U.S. Census Bureau. 2007 Current Industrial Reports: Table 1a – Full Production Capacity Utilization Rates by Industry: Fourth Quarters 2002 through 2006 . November 2007.



### 12.4 INTERVIEW TOPICS AND PRELIMINARY FINDINGS

The following section summarizes information gathered during interviews held during the last quarter of 2008 for the preliminary MIA.

12.4.1 Market Shares and Industry Consolidation

Amended energy conservation standards can alter the competitive dynamics of the marketplace, prompting companies to enter the market, exit the market, or merge with other companies. The preliminary MIA interview questions asked manufacturers to share their perspectives on industry consolidation both in the absence of amended energy conservation standards and assuming amended st andards at various efficiency levels. The interview questions focused on gathering info rmation that assessed:

 disproportionate cost increases to some manufacturers;

 increased proportion of fixed costs potentially increasing business risks; and

 potential barriers to market entry ( e.g ., proprietary technologies).

The need to assess anti-competitive effects of proposed amended energy conservation standards comes from the need to protect cons umer interests. During the interviews, DOE

solicited information to determine whether amen ded energy conservation standards could result in disproportionate economic or performance penalties for par ticular consumer or user

12-6

### subgroups. Manufacturers were also asked if amended energy conservation standards could result in products that will be more or less desirable to consumers due to changes in product functionality, utility, or other features.

12.4.1.1 Market Assessment
As described in preliminary TSD chapter 3, four manufacturers hold the majority of the domestic market share of fluorescent lamp ballasts:

• GE Consumer and Industrial of General Electric, Inc.

• OSRAM Sylvania of Siemens AG

• Advance Transformer of Philips Lighting

• Universal Lighting Technologies

The lighting divisions of some of thes e companies manufacture products other than fluorescent lamp ballasts, such as fluorescent lamps, high intensity discharge lamps, light emitting diode (LED) lighting, and compact fluorescent lamps (CFL). During interviews, manufacturers stated that the vast majority of ballast production takes place abroad.

12.4.1.2 Impact on Small Manufacturers
The Small Business Administration (SBA) defines small business manufacturing enterprises for fluorescent lamp ballast as havi ng 750 employees or fewer. SBA lists small business size standards that are matched to industries as they are described in the NAICS. A size standard is the largest that a for-profit entity can be and still qualify as a small business for Federal programs. These size standards are gene rally the average annual receipts or the average employment of a firm. For fluorescent lamp ballasts, the size standard is matched to NAICS code

33511 , Power, Distribution, and Specialty Transformer Manufacturing , which has a size standard of 750 employees. DOE will study th e potential impacts on these small businesses in detail as part of the NOPR analysis.

12.4.2 Production and Product Mix

DOE requested manufacturers’ feedback on wh at they perceived to be the possible impact of amended energy conservation standards on cash flow and profitability. For instance, the capital and product conversion outlays needed to upgrade or redesign products before they have reached the end of their useful life may cr eate significant conversion costs, resulting in reduced cash flow and stranded investments. Higher energy conservation standards could also result in higher per-unit costs that could cause consumers to shift to less expensive products.

12.4.2.1 Impact on Product Mix
Manufacturers believed that amended energy conservation standards would affect the product mix of fluorescent lamp ballasts. Some manufacturers commented that changes in energy conservation standards could consolidate product offerings and lower profits by eradicating up-selling opportunities. Certain manufacturers commented that if the rulemaking increases efficiency levels significantly, they might exit the fluorescent lamp ballast market, citing an unwillingness to put resources into fixed output ballasts. Additionally, because

12-7

### residential ballasts are extremely price sensitive, an amended energy conservation standard could encourage consumers to switch to low-efficien cy products such as incandescent lighting.

12.4.2.2 Product Utility
Certain manufacturers expressed concern th at amended energy conservation standards might require changes in product functionality, utility, and othe r features that would make products less desirable to consumer s. The major area of concern related to ballasts used in harsh environments and in applications where complete reliability is required. For example, specialty applications, like critical healthcare areas and airport runways, may be better served by magnetic

ballasts.

12.4.3 Conversion Costs

In some instances, manufacturers may be able to meet proposed standard levels by modifying existing products. In other cases, the necessary changes may entail a complete product-line redesign. In these situations, a high er amended energy conservation standard would cause manufacturers to incur one-time capital an d product conversion cost s. Capital conversion

costs are one-time investments in property, plant and equipm ent. Product conversion costs include one-time investments in research, product development, testing and marketing. DOE will study the potential impact of conversion costs in more detail as part of the NOPR analysis.

12.4.4 Cumulative Regu latory Burden

While any one regulation may not impose a significant burden on manufacturers, the combined effects of several impending regulations may have serious consequences for individual manufacturers, groups of manufacturers, or entire industries. Assessing the impact of a single regulation may overlook this cumulative regulatory burden.

Expenditures associated with meeting other re gulations are an important aspect of DOE’s consideration of the cumulative regulatory bur den the industry faces. The interviews helped DOE identify the level and timing of investments manufacturers are expecting to incur because of these regulations. Manufacturers were also asked under what circumstances they might be able to make expenditures related to regula tions and energy conservation standards.

Several Federal and international regulatory programs may affect the markets for fluorescent lamp ballasts. The market and technol ogy assessment discusses some of the notable initiatives that characterize recent developments in the lighting market. See chapter 3 for a list and description of the regulat ory requirements DOE identified.

Specifically, certain ma nufacturers expressed concern about regulations on 4- and 8-foot residential fluorescent lamps because those standards may drive price-sensitive consumers to other, less-efficient technologies, which would affect ballast sales. At the same time, manufacturers also expressed concer n that failure to regulate residential ballasts would create a loophole for inefficient ballasts to enter the mark et from offshore. Manufacturers noted that they would prefer that DOE set a final date for ballast produc tion rather than one for final sell because it would mitigate the negative effect of obsolescent inventory. Manufacturers are also concerned about system interconnect issues , implementation of hazardous material regulations, and how

12-8

### these issues may lead to ballast requirements th at could lower ballast efficiency and affect payback calculations. Manufacturers also mentio ned the impact of international standards on ballast redesign.

12.5 OVERALL KEY ISSUES

Perhaps the most important aspect of the pr eliminary MIA is the opportunity it creates for DOE to identify key manufacturer issues early in the development of amended energy conservation standards. During preliminary interviews manufacturers identified three major areas of concern: (1) impacts on profitability, (2 ) conversion costs, and (3) product innovation.

12.5.1 Impacts on Profitability Some manufacturers commented that pr ofit margins would decrease with the implementation of amended energy conservation standards, especial ly for the original equipment manufacturer (OEM) distribution channels. For example, a higher standard could cause consumers to switch from residential ballasts, which are more price sensitive, to less efficient products. According to the manufacturers interv iewed, consistent profita bility is not common across all types of fluorescent lamp ballasts. Manufacturers also ex pressed concern th at pricing is extremely variable depending on the applica tion (commodities, old products, new products, niche, etc). Some products are sold at a loss, some are sold at cost, and some are sold for a profit.

12.5.2 Product Conversion Costs/Diminishing Returns to Consumers

Certain manufacturers commented that am ended energy conservation standards would force them to invest in more expensive and energy efficient components, improve existing product lines, and design new pr oduct lines. The majority of these product conversion costs would be attributed to engineering and consumer education. Those manufacturers that expected significant product conversion costs commented th at the large investment could result in more expensive products for consumers. However, ot her manufacturers did not expect substantial product conversion costs.

12.5.3 Product Innovation

Manufacturers also expressed concern over the impact of amended energy conservation standards on product innovation. Because employees may need to spend more time redesigning products to comply with standards, the resource s available for the development of new products would significantly decrease.

12-9

### CHAPTER 13. UTILITY IMPACT ANALYSIS

TABLE OF CONTENTS

13.1 INTRODUCTION

............................................................................................................ 13-1

13.2 METHODOLOGY

........................................................................................................... 13 -1

13.3 RESULTS

.................................................................................................................. ....... 13-2

REFERENCES

.................................................................................................................... ...... 13-3

13-i

### CHAPTER 13. UTILITY IMPACT ANALYSIS

13.1 INTRODUCTION

The U.S. Department of Energy (DOE) will analyze the effects on the electric utility industry of proposed fluorescent lamp ballast ener gy conservation standards as part of the notice of proposed rulemaking. This analysis will be conducted using the Energy Information Administration’s (EIA’s) National Energy Modeling System (NEMS), 1 

### a large, multi-sectoral, partial-equilibrium model of the U.S. energy sector. EIA uses NEMS to produce the Annual Energy Outlook 2009 ( AEO2009 ). 2 

### NEMS produces a widely recognized publicly available baseline energy forecast for the United States through 2030.

13.2 METHODOLOGY

To estimate the effects of the proposed sta ndards on the electric utility industry, DOE

will use a variant of the EIA’s NEMS known as NEMS-Building Technologies (BT) to provide key inputs to the analysis. EIA approves the use of the name NEMS only to describe an official version of the model without modifying the modelin g code or data. Because this analysis entails

some minor code modifications and the model is run under multiple policy scenarios that are variations on EIA assumptions, DOE refers to it as NEMS-BT.

For fluorescent lamp ballasts, the analysis will consist of forecasted differences between the base and standards cases for electricity gene ration, installed capacity, sales, and prices. The NEMS-BT model provides reference case load shap es for several end uses, including lighting applications.

For electrical end uses, NEMS-BT uses predic ted growth in demand for each end use to project the total electric system load growth fo r each region, which in turn predicts the necessary additions to electrical generation capacity. NEMS-BT also accounts for the implementation of energy conservation standards by decrementing th e appropriate reference case load shape. DOE will determine the size of the decrement using data for the per-unit energy savings developed in the life-cycle cost (LCC) and payback period (PBP) analyses (chapter 8 of the preliminary technical support document) and the forecast of shipments developed for the national impact analysis (chapter 9).

The use of NEMS-BT for the utility impact analysis offers several advantages. As the official DOE energy forecasting model, NEMS-BT relies on a set of transparent assumptions that have received wide exposure and commentary. NEMS-BT allows an estimate of the interactions between the various energy supply and demand sectors and the economy as a whole. The utility impact analysis will determine the changes for electric utilities in installed electrical generation capacity and in generation by fuel type produced for each trial standard level (TSL) as well as changes in electricity sales.

DOE plans to conduct the utility impact analysis as a variant of the AEO2009 , applying the same basic set of assumptions. For example, the utility analysis uses the operating characteristics ( e.g. , energy conversion efficacy, emissions ra tes) of future electricity generating plants.

13-1

### The model uses predicted growth in demand for each end use to project total electric system load growth for each region, which in tu rn is used to predict necessary additions to electrical generation capacity. Two alternative sc enarios use the high- and low-economic growth

cases of AEO2009 . (The reference case corresponds to medium growth.) The high-economic growth case assumes higher projected growth rates for population, labor force, and labor productivity, resulting in lower pr edicted inflation and interest rates relative to the reference case. The opposite is true for the low-growth case. The NEMS-BT model accounts for the implementation of energy conser vation standards by decrementing the appropriate reference-case load shape. DOE determines the size of the decrement using data for the per-unit energy savings developed in the LCC and PBP analyses (chapter 8) and the shipments analysis (chapter 9) developed for the NIA (chapter 10).

The predicted reduction in electrical generation capacity additions is sensitive to the peak load impacts of the standard. DOE will investigate the need to adjust the hourly load profiles that include fluorescent lamp ballast use in NEMS-BT.

The terminal year of the NEMS-BT model is 2030, impacts beyond which are typically extrapolated based on the pattern of electrici ty savings (in kilowatt hours) expected for a particular standard. The extrapolation will be based on a comparison of the change in the NEMS

BT variable ( e.g. , coal-fired generation) to the chan ge in electricity savings over 2025–2030. As

with the AEO reference case in general, the implicit premise is that the regulatory environment

does not deviate from the current known situation during the extrapolation period. Only changes

that have been announced w ith date-certain in troduction are included in NEMS-BT.

13.3 RESULTS

Results of the utility impact analysis will include changes in electricity sales, installed capacity, and generation for each TSL in five-yea r forecasted increments extrapolated to 2044.

13-2

### REFERENCES

1. U.S. Department of Energy–E nergy Information Administration. The National Energy Modeling System: An Overview 2000 . March 2000. Report No. DOE/EIA-0581 (2000). (Last accessed June 30, 2009.) < http://tonto.eia.doe.gov/ftproot/forecasting/05812000.pdf >

2. U.S. Department of Energy–E nergy Information Administration. Annual Energy Outlook 2009: With Projections to 2030 . March 2009. Report No. DOE/EIA-0383 (2009). (Last accessed March 11, 2010.) < http://www.eia.doe.gov/oiaf/a rchive/aeo09/pdf/0383(2009).pdf >

13-3

### CHAPTER 14. EMPLOYMENT IMPACT ANALYSIS

TABLE OF CONTENTS

14.1 INTRODUCTION

............................................................................................................ 14-1

14.2 ASSUMPTIONS

............................................................................................................... 14- 1

14.3 METHODOLOGY

........................................................................................................... 14-1

REFERENCES

.................................................................................................................... ...... 14-3

14-i

### CHAPTER 14. EMPLOYMENT IMPACT ANALYSIS

14.1 INTRODUCTION

The employment impact analysis is intended to estimate national job creation or job elimination resulting from proposed standards due to reallocation of associated commercial expenditures for purchasing and operating equipm ent. The U.S. Department of Energy (DOE) will conduct this analysis as part of th e notice of proposed rulemaking (NOPR).

DOE estimates the impacts of standards on employment for equipment manufacturers, relevant service industries, energy suppliers, and the economy in general. Both indirect and direct employment impacts are covered. Direct employment impacts would result if energy conservation standards led to a change in the number of employees at manufacturing plants and related supply and service firms. Direct impact estimates are addressed in the manufacturer impact analysis (chapter 12 of the preliminary t echnical support document). Indirect employment impacts affect the national economy in areas othe r than in the regulated manufacturing sector. Indirect impacts may result both from expenditures shifting among goods (substitution effect) and changes in income that lead to an adjustme nt in overall expenditure levels (income effect). DOE defines indirect employment impacts from energy conservation standards as net jobs eliminated or created in the general economy as a result of increased spending driven by the increased prices for regulated equipm ent and reduced spending on energy.

14.2 ASSUMPTIONS

DOE expects new standards to increase the tota l installed cost of equipment (including manufacturer sales price, sales taxes, distribution channel mar kups, and installation cost). DOE also expects the new standards to decrease en ergy consumption (and thus expenditures) on energy. Over time, increased total installed cost is paid back through energy savings. The savings in energy expenditures may be spent on new commercial investment and other items. Conversely, amended energy conservation standards may raise the sales price ( i.e. , equipment price plus sales tax) of fluorescent lamp ballasts and increase installation costs.

Using an input-output (I-O) model of the U.S. economy, this analysis seeks to estimate the effects on different sectors and the net impact on jobs. DOE will estimate national employment impacts for major sectors of th e U.S. economy in the NOPR using public and commercially available data sources and software. DOE will make all methods and

documentation available for review.

14.3 METHODOLOGY

DOE developed Impact of Sector Energy Technologies (ImSET), a model of the

U.S. economy that focuses on sectors most releva nt to industrial, comme rcial, and residential building energy use. 1 

### ImSET is a special-purpose version of the U.S. Benchmark National I-O model designed to estimate the national employment and income effects of energy-saving technologies deployed by the DOE Office of Energy Efficiency and Renewable Energy. Compared with previous versions of the model used in earlier energy conservation rulemakings, the current version allows for more complete and automated analysis of the essential features of

14-1

### energy efficiency investments in buildings, industry, transportation, and the electric power

sectors.

The ImSET model includes structural coefficients to characterize economic flows among the multiple sectors. ImSET’s national economic I-O structure is based on the 1997 Benchmark

U.S. table, 2 

### which is specially aggregated to 188 sectors. The time scale of the model is 50 years.

The I-O model is static, which allows a great deal of flexibility for types of energy efficiency effects. For example, certain economic effects of energy efficiency improvements require an assessment of inter-indus try purchases, which is handled in the model. Some energy efficiency investments will not only reduce the costs of energy in the economy but also the costs of labor and other goods and se rvices, which is accommodated through a recalculation of the I-O structure in the model. Output from ImSET can be used to estimate changes in employment, industry output, and wage income in the ove rall U.S. economy resulting from changes in expenditures in the various sectors of the economy.

The following is an example of how the employment impact analysis might track impacts from a standard for fluorescent lamp ballasts. De pending on the design options considered, one possible outcome is that the standards for thes e ballasts would reduce energy expenditures and increase equipment prices in the commercial sector. These expenditure changes may reduce commercial and energy sector employment. At the same time, the standard may increase investment in the commercial sector and empl oyment in other sectors. DOE designed the employment impact analysis to estimate the annual net national employment impact of these types of expenditure flows.

14-2

### REFERENCES

1. Roop, J. M., M. J. Scott, and R. W. Schultz. ImSET: Impact of Sector Energy Technologies.

2005. Pacific Northwest National Laborator y: Richland, WA. Report No. PNNL-15273.

2. Lawson, A. M., K. S. Bersani, M. Fahim-Nader, and J. Guo. Benchmark Input-Output Accounts of the United States, 1997. Survey of Current Business . 2002. 82 (December): pp.

19–109.

14-3

### ENVIRONMENTAL ASSESSMENT FOR PROPOSED ENERGY CONSERVATION

STANDARDS FOR FLUORESCENT LAMP BALLASTS

TABLE OF CONTENTS

EA.1 INTRODUCTION

............................................................................................................. .. 1

EA.2 METHODOLOGY

.............................................................................................................. 1

EA.2.1 Carbon Dioxide

........................................................................................................ 1

EA.2.2 Sulfur Dioxide

......................................................................................................... . 1

EA.2.3 Nitrogen Oxides

....................................................................................................... 2

EA.2.4 Mercury

................................................................................................................ .... 3

EA.2.5 Particulate Matter

..................................................................................................... 3

EA.2.6 Monetization of Emissi ons Reduction Benefits

....................................................... 3

EA.3 RESULTS

.................................................................................................................. .......... 4

REFERENCES

.................................................................................................................... ............ 5

EA-i

### ENVIRONMENTAL ASSESSMENT FOR PROPOSED ENERGY CONSERVATION

STANDARDS FOR FLUORESCENT LAMP BALLASTS

EA.1 INTRODUCTION

The U.S. Department of Energy (DOE) will conduct an environmental assessment as part of the notice of proposed rulemaking for fluorescent lamp balla sts. DOE will assess environmental effects by using a variant of the Energy Information Administration’s National Energy Modeling System (NEMS) known as NEMS -Building Technologies (BT) to provide key input to the analysis. The environmental assessm ent produces results in a manner similar to those provided in the Annual Energy Outlook (

AEO ).

The primary environmental effects of these standards would be reduced power plant emissions resulting from reduced consumption of electricity. DOE will assess these environmental effects by using NEMS-BT to provi de key inputs to its analysis. The portion of

the environmental assessment that NEMS-B T will produce considers carbon dioxide (CO 2 

### ), nitrogen oxides (NO

x 

### ), and mercury (Hg). The environmen tal assessment also considers impacts

on SO 2 

### emissions. For each trial standard level (T SL), DOE will calculate total undiscounted and discounted power plant emissions using NEMS-BT.

EA.2 METHODOLOGY

DOE will conduct each environm ental assessment performed in this rulemaking as an incremental policy impact ( i.e. , a standard for the products under evaluation; in this case, fluorescent lamp ballasts) of the AEO2009 forecast, applying the same basic set of assumptions

used in AEO2009

. 1 

### For example, the emissions characteristics of an electricity generating plant will be exactly those used in AEO2009 . Also, forecasts conducted with NEMS-BT consider the supply-side and demand-side effects on the elec tric utility industry. Thus, the analysis will account for any factors affecting the type of el ectricity generation and in turn the type and amount of airborne emissions the utility industry generates.

EA.2.1 Carbon Dioxide

In the absence of any Federal emissions cont rol regulation of power plant emissions of

CO 2 

### , a DOE standard is likely to result in reductions of these emissions. The CO 2 

### emission reductions likely to result from a standard will be estimated using NEMS-BT and national energy savings estimates drawn from the national impact analysis spreadsheet model. The net benefit of the standard is the difference between emissions estimated by NEMS-BT at each standard level

considered and the AEO reference case. NEMS-BT tracks CO 2 

### emissions using a detailed module that provides results with broad coverage of all sector s and inclusion of interactive

effects.

EA.2.2 Sulfur Dioxide

DOE has preliminarily determined that SO 2 

### emissions from affected electric generating units (EGUs) are subject to nationwide and regional emissions cap and trading programs that are likely to eliminate the standards’ impact on SO 2 

### emissions. The costs of meeting such emission

EA-1

### cap requirements are reflected in the electricity prices and forecasts used in DOE’s analysis of

the standards. Title IV of the Clean Ai r Act sets an annual emissions cap on SO 2 

### for all affected

EGUs. SO 2 

### emissions from 28 eastern States and the District of Columbia (DC) are also limited under the Clean Air Interstate Rule (CAIR, published in the Federal Register on May 12, 2005, 70 FR 25162), which creates an allowance-based trading program that will gradually replace the Title IV program in those States and DC. (The recent legal history surrounding CAIR is discussed below.) The attainment of the emissions caps is flexible among EGUs and is enforced through the use of emissions allowances and tradable permits. Under existing U.S. Environmental Protection Agency (EPA) regulations, any excess SO 2 

### emission allowances resulting from the lower electricity demand caused by the imposition of an efficiency standard could be used to permit offsetting increases in SO 2 

### emissions by any regulated EGU. However, if the standard resulted in a permanent increase in the quantity of unused emission allowances,

there would be an overall reduction in SO 2 

### emissions from the standards. While there remains some uncertainty about the ultimate effects of efficiency standards on SO 2 

### emissions covered by the existing cap and trade system, the NEMS-BT modeling system that DOE plans to use to

forecast emissions reductions curre ntly indicates that no physical reductions in power sector

emissions would occur for SO 2



### .

Even if there is no significant redu ction in the overall emissions of SO 2 

### that results from the standard, there may still be some ec onomic benefit from reduced demand for SO 2 

### emission allowances that is not fully reflected in the co st savings experienced by individual consumers. Electricity savings that decrease the overall demand for SO 2 

### emissions allowances could lower allowance prices and thereby result in some econo mic benefits for all electricity consumers, not just those that reduced their electricity use as a result of an efficiency standard.

EA.2.3 Nitrogen Oxides

NEMS-BT also has an algorithm for estimating NO

x 

### emissions from power generation. The impact of these emissions, however, will be affected by CAIR, which the EPA issued on May 12, 2005. CAIR will permanently cap emissions of NO X 

### in 28 eastern states and DC. 70 FR 25162 (May 12, 2005).

Much like SO 2 

### emissions, a cap on NO

x 

### emissions means that the amended fluorescent lamp ballast standards may have little or no physical effect on these emissions in the 28 eastern States and DC covered by CAIR. Although CA IR has been remanded to the EPA by the DC Circuit, it will remain in effect until it is replaced by a rule cons istent with the Court’s July 11, 2008 opinion in North Carolina v. EPA , 531 F.3d 896 (DC Cir. 2008); see also North Carolina v.

EPA , 550 F.3d 1176 (DC Cir. 2008). Because all Stat es covered by CAIR opted to reduce NO

x 

### emissions through par ticipation in cap-and-trade progr ams for electric generating units, emissions from these sources are capped across th e CAIR region. DOE also plans to use NEMS

BT to estimate the emissions reductions from possible standards in the 22 States where emissions are not capped.

Standards may produce an envir onmental-related econo mic benefit in the form of lower prices for emissions allowance credits. As with SO 2 

### allowance prices, DOE does not plan to monetize this particul ar benefit because the effect on the NO

x 

### allowance price from any single energy conservation standard is lik ely small and highly uncertain.

EA-2

### EA.2.4 Mercury

Similar to emissions of SO 2 

### and NO

x 

### , future emissions of Hg would have been subject to emissions caps. In May 2005, EPA issued th e Clean Air Mercury Rule (CAMR). 70 FR 28606 (May 18, 2005). CAMR would have permanently capped emissions of mercury for new and existing coal-fired power plants in all States by 2010. However, on February 8, 2008, the DC

Circuit issued its decision in New Jersey v. Environmental Protection Agency , in which the DC Circuit, among other actions, vacated th e CAMR. 517 F.3d 574 (DC Cir. 2008). EPA has decided to develop emissions standards for pow er plants under the Clean Air Act (Section 112), consistent with the DC Circuit’s opinion on the CAMR. 2 

### Pending EPA’s forthcoming revisions to the rule, DOE is excluding the CAMR from its environmental analysis. In the absence of CAMR, a DOE standard would likely reduce Hg emissions, and DOE plans to use NEMS-BT to

estimate these emission reductions.

EA.2.5 Particulate Matter

DOE acknowledges that particulate matter (PM) impacts are of concern due to human exposures that can impact health. Impacts of PM emissions reduction, however, are much more difficult to estimate than other emissions reductions due to the complex interactions between PM, other power plant emissions, meteorology, and atmospheric chemistry that impact human exposure to particulates. Human exposure to PM us ually occurs at a significant distance from the power plants that are emitting particulates and particulate precursors. When power plant emissions travel this distance, they undergo highly complex atmospheric chemical reactions. Although the EPA does keep inventories of direct PM emissions of power plants, in its source attribution reviews, the EPA doe s not separate direct PM emissions from power plants from the sulfate particulates indirectly produced through complex atmos pheric chemical reactions. The great majority of PM emissions from power plan ts are of these seconda ry particles (secondary sulfates). Thus, it is not useful to examine how the amended standard impacts direct PM emissions independent of indir ect PM production and atmospheric dynamics. Therefore, DOE is not planning to assess the impact of these standa rds on particulate emissions. Further, even the cumulative impact of PM emissions from power plan ts and indirect emissions of pollutants from other sources is unlikely to be significant.

EA.2.6 Monetization of Emissi ons Reduction Benefits

For those emissions for which real nationa l emission reductions are anticipated (CO 2 

### , Hg,

and NO

x 

### for 22 States), only ranges of estimated economic values base d on environmental damage studies of varying quality and applicability are available. Therefore, DOE plans on reporting estimates of monetary benefits derived using these values and plans to consider these benefits in weighing the costs and benefits of each of the standard levels. In accordance with

U.S. Office of Management and Budget (OMB) guidance, DOE will conduct two calculations of the monetary benefits derived for each of the eco nomic values, one using a real discount rate of 3 percent and another using a real discount rate of 7 percent. 3



### In order to estimate the monetary value of benefits resulting from reduced emissions of

CO 2 

### emissions, it is DOE’s intent to use in its an alysis the most current social cost of carbon (SCC) values developed a nd/or agreed to by interagency reviews. The SCC is intended to be a monetary measure of the incremental damage resulting from greenhouse gas (GHG) emissions,

EA-3

### including but not limited to net agricultural productivity loss, human health effects, property damage from sea level rise, and changes in ecosy stem services. Any effort to quantify and to monetize the harms associated with climate change will raise serious questions of science, economics, and ethics. With full regard for the limits of both quantifica tion and monetization, the SCC can be used to provide estimates of the so cial benefits of reductions in GHG emissions.

At the time of this notice, the most recen t interagency estimates of the potential global benefits resulting from reduced CO 2 

### emissions in 2010 were $4.7, $21.4, $35.1, and $64.9 per

metric ton in 2007 dollars. These values are th en adjusted to 2009$ using the standard GDP deflator value for 2008 and 2009. For emissions (or emission reductions) that occur in later years, these values grow in real terms over time. Additionally, the interagency group determined that a range of values from 7 percent to 23 per cent should be used to adjust the global SCC to calculate domestic effects, although preference will be given to consideration of the global benefits of reducing CO 2 

### emissions. See Appendix A of the a nnex to chapter 15 of the technical support document for the full range of annual SCC estimates from 2010 to 2050.

DOE recognizes that scientific and economic kno wledge continues to evolve rapidly as to

the contribution of CO 2 

### and other GHG to changes in the fu ture global climate and the potential resulting damages to the world economy. Thus, these values are subject to change.

DOE also intends to estimate the potential monetary benefit of reduced NO

x 

### , and Hg emissions resulting from the standard levels it considers. For NO

x 

### emissions, available estimates suggest a very wide range of monetary values for NO

x 

### emissions, ranging from $370 per ton to $3,800 per ton of NO X 

### from stationary sources, measured in 2001$ (equivalent to a range of $442 to $4,540 per ton in 2008$). 4



### For Hg emissions reductions, DOE has previ ously determined that the impact of Hg emissions from power plants on humans is c onsidered highly uncertain. However, DOE identified two estimates of the environmental damage of Hg based on two estimates of the adverse impact of childhood exposure to methyl mercury on intelligence quotient (IQ) for American children, and subsequent loss of life time economic productivit y resulting from these IQ losses. The high-end estimate is based on an estimate of the current aggregate cost of the loss of IQ in American children that results from ex posure to Hg of U.S. power plant origin ($1.3 billion per year in 2000$), which works out to $33.3 million per ton emitted per year (2008$). 5


### The low-end estimate is $0.66 million per ton em itted (in 2004$) or $0.745 million per ton in 2008$. DOE derived this estimate from a published evaluation of mercury control using different methods and assumptions from the first study but also based on the present value of the lifetime earnings of children exposed to Hg. 6 

### The estimate was derived by back-calculating the annual benefits per ton from the net present value of benefits reported in the study.

EA.3 RESULTS

The results for the environmental assessment are similar to a complete NEMS run as published in the AEO2009 . These results include power-sector emissions for SO 2 

### , NO

x 

### , CO 2 

### , and Hg in five-year forecasted increments extrapolated to 2044. The outcome of the analysis for each TSL is reported as a deviation from the AEO2009 reference (base) case.

EA-4

### REFERENCES

1. U.S. Department of Energy–E nergy Information Administration. Annual Energy Outlook 2009: With Projections to 2030 . March 2009. Report No. DOE/EIA-0383 (2009). (Last accessed March 11, 2010.) < http://www.eia.doe.gov/oiaf/a rchive/aeo09/pdf/0383(2009).pdf >

2. Environmental Protection Agency v. State of New Jersey, et al. 2009. Supreme Court of the United States No. 08-512. February 6. (Last accessed March 11, 2010.)

< http://www.epa.gov/air/mercuryr ule/pdfs/certpetition_withdrawal.pdf >

3. Office of Management and Budget. 2003. Circul ar A-4: Regulatory Analysis. September 17. (Last accessed March 11, 2003.) < http://www.whitehouse.gov/om b/circulars/a004/a-4.pdf >

4. Office of Management and Budget, Office of Information and Regulatory Affairs. 2006 Report to Congress on the Costs and Benef its of Federal Regu lations and Unfunded Mandates on State, Local, and Tribal Entities. January 2007. Unavailable online.

5. Trasande, L., C. Schechter, K. A. Haynes, and P. J. Landrigan. Applying Cost Analyses to Drive Policy that Protects Childre n: Mercury as a Case Study. Annals of the New York Academy of Sciences . 2006. 1076 (September): pp. 911–923.

6. Gayer, T. and R. Hahn. Designing Environmental Policy: Le ssons from the Regulation of Mercury Emissions . 2005. American Enterprise Institute-Brookings Joint Center for Regulatory Studies: Washington, DC. Regulatory Analysis 05-01. A version of this paper was published in the Journal of Regulatory Economics in 2006.

EA-5

### REGULATORY IMPACT ANALYSIS FOR FLUORESCENT LAMP BALLASTS

TABLE OF CONTENTS

RIA.1 INTRODUCTION

........................................................................................................... 1

RIA.2 METHODOLOGY

.......................................................................................................... 1

RIA-i

### REGULATORY IMPACT ANALYSIS FOR FLUORESCENT LAMP BALLASTS

RIA.1 INTRODUCTION

The U.S. Department of Energy (DOE) will prepare a draft regulatory impact analysis in compliance with Executive Order 12866, “Regulator y Planning and Revi ew,” which will be subject to review by the Office of Manageme nt and Budget’s Office of Information and Regulatory Affairs. 58 FR 51735 (September 30, 1993). DOE will conduct this analysis as part of the notice of proposed rulemaking (NOPR).

RIA.2 METHODOLOGY

As part of the regulatory impact analysis and as discussed in chapter 12, “Manufacturer Impact Analysis,” of the preliminary technica l support document (TSD), DOE will identify and seek to mitigate the overlapping effects on manufacturers of new or amended energy conservation standards and other regulatory ac tions affecting the same products. Through manufacturer interviews and literature searches, DOE will compile information on burdens from existing and pending regulations aff ecting fluorescent lamp ballasts.

The regulatory impact analysis also will address the potential for non-regulatory approaches to supplant or augment energy cons ervation standards to improve the efficacy of fluorescent lamp ballasts. The NOPR will include a complete quantitative analysis of alternatives to the proposed energy conservation standards. DOE will use the National Energy Savings (NES) model (discussed in chapter 10, “National Impact Analysis,” of the preliminary TSD) to calculate the NES and net present value (NPV) for the alternatives to the proposed energy conservation standards. Listed below are some of the alternative means of achieving energy efficiency improvements that DOE ha s used in prior rulemakings.

• 

### no new regulatory action;

• 

### consumer tax incentives;

• 

### manufacturer tax incentives;

• 

### performance standards;

• 

### rebates;

• 

### voluntary energy efficiency targets;

• 

### early replacement ( i.e. , retrofit); and

• 

### bulk government purchases.

The TSD in support of the NOPR will include a complete analysis of each alternative.

To compare each alternative to proposed en ergy conservation standards, DOE will need to quantify the effect of each alternative on the purchase and use of more efficacious fluorescent lamp ballasts. Once DOE estimates the impacts of alternatives to the standard, DOE will run

these standard-alternative scenarios in the NES model. Key inputs that DOE may adjust in the NES model for this analysis include:

RIA-1

### • 

### energy prices and escalation factors;

• 

### implicit market discount rates for trading off purchase price against operating expense when choosing equipment efficiency;

• 

### customer purchase price, operating cost, and shipment scenarios;

• 

### customer price versus effi ciency relationships; and

• 

### equipment stock data (purchase of new equi pment or turnover rate s for inventories).

The output from the NES model for each alternative considered will be as follows:

• 

### Energy use (EJ = 10 18 

### joule) is the cumulative energy use of the equipment from the

effective date of the amended standard to 2044. DOE will report elec tricity consumption as primary energy.

• 

### National energy savings is the cumulative national energy use from the base case projection less the alte rnative projection.

• 

### Net present value is the value of future operating cost savings from fluorescent lamp ballasts bought in the period between the effec tive date of the new standard and the close of the analysis period (2044). DOE calculat es the NPV as the difference between the present value of equipment and operating expenditures ( e.g. , energy) in the base case, and the present value of expenditures in each a lternative case. DOE will discount future operating and equipment expenditures to its anal ysis year using two discount rates: 7 and 3 percent. DOE will also calculate operating expenses (including electricity costs) over the life of the equipment.

RIA-2

### APPENDIX AA. ACRONYMS AND ABBREVIATIONS

ACEEE American Council for an Energy Efficiency Economy

AEO Annual Energy Outlook ANOPR advanced notice of proposed rulemaking

ANSI American National Standards Institute ASAP Appliance Standards Awareness Project

ASE Alliance to Save Energy BE ballast efficiency

BEF ballast efficacy factor

BF ballast factor

BLS Bureau of Labor Statistics

BOM bill of material

BT Building Technologies Program

BTU British Thermal Unit

CAIR Clean Air Interstate Act CAMR Clean Air Mercury Rule CBECS Commercial Buildings Energy Consumption Survey

CCT correlated color temperature

CEC California Energy Commission

CEE Consortium for Energy Efficiency

CFR Code of Federal Regulations

CFL compact fluorescent lamp

CIE International Commission on Illumination

CMH ceramic metal halide

CO 2 

### carbon dioxide

CPI Consumer Price Index

CRI color rendering index

CSA Canadian Standards Association

CSL candidate standard level DALI digitally addressable lighting interface DIY do-it-yourself

DOE U.S. Department of Energy

DOJ U.S. Department of Justice EERE Office of Energy Efficiency and Renewable Energy EIA Energy Information Administration EISA 2007 Energy Independence and Security Act of 2007 EL efficiency level EMI electromagnetic interference

E.O. Executive Order

EPA Environmental Protection Agency EPACT 1992 Energy Policy Act of 1992 EPACT 2005 Energy Policy Act of 2005 EPCA Energy Policy and Conservation Act

ERP expected risk premium F degrees Fahrenheit F28T5 Nominally 28W T5 4-foot miniature bipin lamp F54T5HO Nominally 54W T5 4-foot miniature bipin high output lamp

AA-1

### F32T8 Nominally 32W T8 4-foot medium bipin lamp F34T12 Nominally 34W T12 4-foot medium bipin lamp F40T12 Nominally 40W T12 4-foot medium bipin lamp F96T12 Nominally 75W T12 8-foot single pin slimline lamp F96T12/ES Nominally 60W T12 8-foot single pin slimline lamp F96T12HO Nominally 110W T12 8-foot recessed double contact high output lamp F96T12HO/ES Nominally 95W T12 8-foot r ecessed double contact high output lamp FEMP Federal Energy Management Program FR Federal Register

FTC Federal Trade Commission

GE General Electric Lighting and Industrial GHG greenhouse gas GRIM Government Regulatory Impact Model

GW gigawatt Hg mercury HID high-intensity discharge

HO high output HVAC Heating, Ventilating and Air-Conditioning

IEC International Electrotechnical Commission IESNA Illuminating Engineering Society of North America ImSET Impact of Sector Energy Technologies INPV industry net present value

I-O input-output

IPCC Intergovernmental Panel on Climate Change

IR Infrared IRFA initial regulatory flexibility analysis

IS instant start K degrees Kelvin

kt kilotons LCC life-cycle cost LED Light-Emitting Diode

Lms lumens

LMC U.S. Lighting Market Characterization Volume I Lm/W lumens per watt MBP medium bipin MECS Manufacturer Energy Consumption Survey (MECS) MIA Manufacturer Impact Analysis MiniBP miniature bipin

MMt million metric tons

MPC manufacturer production cost

MSP manufacturer selling price

Mt metric tons

MW megawatts NAECA 1988 National Appliance Energy Conservation Amendments of 1988 NAICS North American Industry Classification System

NCLC National Consumer Law Center NECPA National Energy Conservation Policy Act of 1978 NEEP Northeast Energy Efficiency Partnership

AA-2

### NEMA National Electrical Manufacturers Association NEMS National Energy Modeling System NEMS-BT National Energy Modeling System – Building Technologies

NES national energy savings NIA National Impact Analysis

NIST National Institute of Standards and Technology NOPM notice of public meeting NOPR notice of proposed rulemaking

NO X 

### nitrogen oxides

NPCC Northwest Power and Conservation Council

NPV net present value

NRCan Natural Re sources Canada

NRDC Natural Resources Defense Council NVLAP National Voluntary Laboratory Accreditation Program NYSERDA New York State Energy Res earch and Development Authority

OEM Original Equipment Manufacturer OIRA Office of Information and Regulatory Affairs OMB U.S. Office of Management and Budget

PAR parabolic aluminized refl ector (reflector lamp shape) PBP payback period PF power factor

PG&E Pacific Gas and Electric PM particulate matter

PPI producer price index PS programmed start quad quadrillion BTU

R reflector (reflector lamp shape) R-CFL reflector compact fluorescent lamp

R&D research and development

RDC recessed double contact RECS Residential Energy Consumption Survey RIA regulatory impact analysis

RoHS Restriction on Hazar dous Substances directive RS rapid start

RSE relative system efficiency

SBA Small Business Administration

SCC social cost of carbon

SCF Survey of Consumer Finances

SEC Securities and Exchange Commission SG&A selling, general, and administrative costs SO standard output

SO 2 

### sulfur dioxide SP single pin

S&P Standard & Poor’s T5, T8, T10, T12 tubular fluorescent lamps, diameters of 0.625, 1, 1.25 or 1.5 inches, respectively

THD total harmonic distortion

TSD technical support document

AA-3

### TSL trial standard level

TWh terawatt-hour

UMRA Unfunded Mandates Reform Act

U.S.C. United States Code

UV ultraviolet

V volts

VHO very high output

W watts WACC weighted-average cost of capital

AA-4

### APPENDIX 3A. FLUORESCENT LAMP BALLASTS IN THE UNITED STATES CODE

AND CODE OF FEDERAL REGULATIONS

TABLE OF CONTENTS

3A.1 INTRODUCTION ........................................................................................................ 3A-1

3A.2 EPCA DIRECTIVES REGARDING FLUOR ESCENT LAMP BALLASTS............. 3A-1

3A.3 DEFINITIONS .............................................................................................................. 3A-6

3A.4 ENERGY INDEPENDENCE AND SECURITY ACT OF 2007 .............................. 3A-10

3A-i

### APPENDIX 3A. FLUORESCENT LAMP BALLASTS IN THE UNITED STATES CODE

AND CODE OF FEDERAL REGULATIONS

3A.1 INTRODUCTION

This appendix lists the releva nt requirements and definitions that apply to fluorescent lamp ballasts listed in the in the energy policy and conservation act (EPCA) and in the code of federal regulations (CFR).

3A.2 EPCA DIRECTIVES REGARDING FLUORESCENT LAMP BALLASTS

This section lists the relevant statut ory requirements under 42 U.S.C. 6295(g) ( i.e.

, section 325(g) of EPCA, as amended by the Ener gy Policy Act of 2005) that apply to fluorescent lamp ballasts, as well as standards established by DOE in the 2000 Ballast Rule.

42 U.S.C. 6295(g). Standards for dishwashers; clothes washers; clothes dryers; fluorescent lamp ballasts

(5) Except as provided in paragraph (6), each fluorescent lamp ballast-­ (A) (i) manufactured on or after January 1, 1990; (ii) sold by the manufacturer on or after April 1, 1990; or (iii) incorporated into a luminaire by a luminaire manufacturer on or after April 1, 1991; and (B) designed-­ (i) to operate at nominal input voltages of 120 or 277 volts; (ii) to operate with an input cu rrent frequency of 60 Hertz; and (iii) for use in connection with an F40T12, F96T12, or F96T12HO lamps; (C) shall have a power factor of 0.90 or greater and shall have a ballast efficacy factor not less than the following:

Application for

Operation of Ballast Input Voltage Total Nominal Lamp Watts Ballast Efficacy

Factor

One F40T12 lamp 120 40 1.805

277 40 1.805

Two F40T12 lamps 120 80 1.060

277 80 1.050

Two F96T12 lamps 120 150 0.570

277 150 0.570

Two F96T12HO lamps 120 220 0.390

277 220 0.390

3A-1

### (6) The standards described in paragraph (5) do not apply to (A) a ballast which is designed for dimming or fo r use in ambient temperatures of 0° F or
less, or (B) a ballast which has a power factor of less than 0.90 and is designed and labeled for use only in residential building applications.

(7) (A) The Secretary shall publish a final rule no later than January 1, 1992, to determine if the standards established under paragraph (5) shoul d be amended, including whether such standards should be amended so that they w ould be applicable to ballasts described in paragraph (6) and other fluorescent lamp ballasts. Such rule shall contain such amendment, if any, and provide that the amendment shall apply to products manufactured on or after January 1, 1995.

(B) After January 1, 1992, the Secretary shall publish a final rule no later than five years after the date of publication of a previous fi nal rule. The Secretary shall determine in such rule whether to amend the standards in effect for fluorescent lamp ballasts, including whether such standards should be am ended so that they would be applicable to additional fluorescent lamp ballasts.

(C) Any amendment prescribed under subparagraph (B) shall apply to products manufactured after a date which is five years after-­ (i) the effective date of the previous amendment; or (ii) if the previous final rule did not ame nd the standards, the earliest date by which a previous amendment could have been effective; except that in no case may any amended st andard apply to products manufactured within three years after publication of the final rule establishing such amended standard.

(8)(A) Each fluorescent lamp ballast (other than replacement ballasts or ballasts described in subparagraph (C))— (i) (I) manufactured on or after July 1, 2009; (II) sold by the manufacturer on or after October 1, 2009; or (III) incorporated into a luminaire by a luminaire manufacture r on or after July
1, 2010; and (ii) designed— (I) to operate at nominal input voltages of 120 or 277 volts; (II) to operate with an input curre nt frequency of 60 Hertz; and (III) for use in connection with F34T12 lamps, F96T12/ES lamps, or F96T12HO/ES lamps; shall have a power factor of 0.90 or greater and shall have a ballast efficacy factor of not less than the following:

3A-2

### Application for Operation of Ballast Input Voltage Total Nominal Lamp Watts Ballast Efficacy

Factor

One F34T12 lamp 120 34 2.61

277 34 2.61

Two F34T12 lamps 120 68 1.35

277 68 1.35

Two F96T12/ES lamps 120 120 0.77

277 120 0.77

Two F96T12HO/ES 120 190 0.42

277 190 0.42 (B) The standards described in subparagraph (A) shall apply to all ballasts covered by subparagraph (A)(ii) that are manufactured on or after July 1, 2010, or sold by the manufacturer on or a fter October 1, 2010.

(C) The standards described in subparagraph (A) do not apply to— (i) a ballast that is designed for dimming to 50 percent or less of the maximum output of the ballast; (ii) a ballast that is designed for use with 2 F96T12HO lamps at ambient temperatures of 20°F or less and for use in an outdoor sign; or (iii) a ballast that has a power factor of less than 0.90 and is designed and labeled for use only in residential applications.;

10 CFR 430.32(m) Energy Conservation Standards

(m)(1) Fluorescent lamp ballasts. Except as pr ovided in paragraphs (m)(2), (m)(3), (m)(4), (m)(5), (m)(6) and (m)(7) of this section, each fluorescent lamp ballast—

(i) (A) Manufactured on or after January 1, 1990; (B) Sold by the manufacturer on or after April 1, 1990; or (C) Incorporated into a luminaire by a lu minaire manufacturer on or after April 1, 1991;

and (ii) Designed— (A) To operate at nominal input voltages of 120 or 277 volts; (B) To operate with an input curre nt frequency of 60 Hertz; and (C) For use in connection with an F40T12, F96T12, or F96T12HO lamps shall have a power factor of 0.90 or greater and shall ha ve a ballast efficacy factor not less than the following :

3A-3

### Application for Operation of Ballast Input Voltage Total Nominal Lamp Watts Ballast Efficacy

Factor

One F40T12 lamp 120 40 1.805

277 40 1.805

Two F40T12 lamps 120 80 1.060

277 80 1.050

Two F96T12 lamps 120 150 0.570

277 150 0.570

Two F96T12HO lamps 120 220 0.390

277 220 0.390

(2) The standards described in paragraph (m)(1) of this section do not apply to— (i) A ballast that is designed for dimming or fo r use in ambient temperatures of 0 °F or
less, or (ii) A ballast that has a power factor of less than 0.90 and is designed for use only in residential building applications.

(3) Except as provided in paragraph (m)(4) of this section, each fluorescent lamp ballast— (i) (A) Manufactured on or after April 1, 2005; (B) Sold by the manufacturer on or after July 1, 2005; or (C) Incorporated into a luminaire by a luminaire manufacturer on or after April 1,
2006; and (ii) Designed— (A) To operate at nominal input voltages of 120 or 277 volts; (B) To operate with an input curre nt frequency of 60 Hertz; and (C) For use in connection with an F40T12, F96T12, or F96T12HO lamps; shall have a power factor of 0.90 or greater and shall have a ballast efficacy factor not less than the following:

Application for

Operation of Ballast Input Voltage Total Nominal Lamp Watts Ballast Efficacy Factor

One F40 T12 lamp 120 40 2.29

277 40 2.29

Two F40 T12 lamps 120 80 1.17

277 80 1.17

Two F96T12 lamps 120 150 0.63

277 150 0.63

Two F96T12HO lamps 120 220 0.39

277 220 0.39

(4) (i) The standards described in paragraph (m)(3) do not apply to: (A) A ballast that is designed for dimming to 50 percent or less of its maximum output; (B) A ballast that is designed for use with two F96T12HO lamps at ambient temperatures of

− 20 °F or less and for use in an outdoor sign;

3A-4

### (C) A ballast that has a power factor of less than 0.90 and is designed and labeled for use only in residential building applications; or (D) A replacement ballast as defined in paragraph (m)(4)(ii) of this section. (ii) For purposes of this paragraph (m), a replacement ballast is defined as a ballast that: (A) Is manufactured on or before June 30, 2010; (B) Is designed for use to replace an existing ba llast in a previously installed luminaire; (C) Is marked “FOR REPLACEMENT USE ONLY”; (D) Is shipped by the manufacturer in pack ages containing not more than 10 ballasts; (E) Has output leads that when fully extende d are a total length that is less than the length of the lamp with which it is intended to be operated; and (F) Meets or exceeds the ballast effica cy factor in the following table:

Application for

Operation of Ballast Input Voltage Total Nominal Lamp Watts Ballast Efficacy

Factor

One F40T12 lamp 120 40 1.805

277 40 1.805

Two F40T12 lamps 120 80 1.060

277 80 1.050

Two F96T12 lamps 120 150 0.570

277 150 0.570

Two F96T12HO lamps 120 220 0.390

277 220 0.390

(5) Except as provided in paragraph (m)(7) of this section, each fluorescent lamp ballast (other than replacement ballasts defined in §430.2)— (i) (A) Manufactured on or after July 1, 2009; (B) Sold by the manufacturer on or after October 1, 2009; or (C) Incorporated into a luminaire by a luminaire manufacturer on or after July 1,
2010; and (ii) Designed— (A) To operate at nominal input voltages of 120 or 277 volts; (B) To operate with an input curre nt frequency of 60 Hertz; and (C) For use in connection with F34T12 lamps, F96T12/ES lamps, or F96T12HO/ES lamps; shall have a power factor of 0.90 or greater and shall have a ballast efficacy factor of not less than the following: Application for

Operation of Ballast Input Voltage Total Nominal Lamp Watts Ballast Efficacy

Factor

One F34 T12 lamp 120 34 2.61

277 34 2.61

Two F34 T12 lamps 120 68 1.35

277 68 1.35

Two F96T12/ES lamps 120 120 0.77

277 120 0.77

Two F96T12HO/ES 120 190 0.42

3A-5

### lamps 277 190 0.42

(6) The standards in paragraph (m)(5) shall apply to all ballasts covered by paragraph (m)(5)(ii), including replacement ballasts and ba llasts described in paragraph (m)(7) of this section, that are manufactured on or after July 1, 2010, or sold by the manufacturer on or after October 1, 2010. (7) The standards in paragraph (m)(5) do not apply to— (i) A ballast that is designed for dimming to 50 percent or less of the maximum output of
the ballast; (ii) A ballast that is designed for use with 2 F96T12HO lamps at ambient temperatures of 20 degrees F or less and for use in an outdoor sign; or (iii) A ballast that has a power factor of less than 0.90 and is designed and labeled for use only in residential applications.

3A.3 DEFINITIONS

This section provides the rele vant definitions under the statute (42 U.S.C. 6291) and DOE regulations (10 CFR 430.2) that are applicable to the lighting products covered under this rulemaking. DOE takes the definitions from th e statute and codifies them into the CFR; therefore, some terms in this section may be listed twice.

42 U.S.C. 6291(29)

(A) The term "fluorescent lamp ballast" means a device which is used to start and operate fluorescent lamps by providing a starting voltage and current and limiting the current during normal operation. (B) The term "ANSI standard" means a standar d developed by a committee accredited by

the American National Standards Institute. (C) The term "ballast efficacy factor" means the relative light output divided by the power input of a fluorescent lamp ballast, as measured under test conditions specified in ANSI standard C82.2-1984, or as may be prescribed by the Secretary. (D) (i) The term "F40T12 lamp" means a nominal 40 watt tubular fluorescent lamp which is 48 inches in length and one-and-a- half inches in diameter, and conforms to ANSI standard C78.81-2003 (Data Sheet 7881-ANSI-1010-1). (ii) The term "F96T12 lamp" means a nominal 75 watt tubular fluorescent lamp which is 96 inches in length and one-and-a- half inches in diameter, and conforms to ANSI standard C78.3-1978 (R1984). (iii) The term "F96T12HO lamp" means a nominal 110 watt tubular fluorescent lamp which is 96 inches in length and one-and-a-half inches in diameter, and conforms to ANSI standard C78.81- 2003 (Data Sheet 7881-ANSI-1019-1).

3A-6

### (E) The term "input current" means the r oot-mean-square (RMS) current in amperes delivered to a fluorescent lamp ballast. (F) The term "luminaire" means a complete lighting unit consisting of a fluorescent lamp or lamps, together with parts designed to di stribute the light, to position and protect such lamps, and to connect such lamps to the power supply through the ballast. (G) The term "ballast input voltage" means the rated input voltage of a fluorescent lamp

ballast. (H) The term "nominal lamp watts" means the wattage at which a fluorescent lamp is designed to operate. (I) The term "power factor" means the power input divided by the product of ballast input voltage and input current of a fluorescent lamp ballast, as measured under test conditions specified in ANSI standard C82.2- 1984, or as may be prescribed by the Secretary. (J) The term "power input" means the power consumption in watts of a ballast and fluorescent lamp or lamps, as determined in accordance with the test procedures specified in ANSI standard C82.2-1984, or as ma y be prescribed by the Secretary. (K) The term "relative light output" means th e light output delivered through the use of a ballast divided by the light output deliver ed through the use of a reference ballast, expressed as a percent, as determined in accordance with the test procedures specified in ANSI standard C82.2-1984, or as may be prescribed by the Secretary. (L) The term "residential building" means a structure or portion of a structure which provides facilities or shelter for human residency, except that such term does not include any multifamily residential structure of more than three stories above grade. (M) The term "F34T12 lamp" (also known as a "F40T12/ES lamp") means a nominal 34 watt tubular fluorescent lamp that is 48 inch es in length and 1 1/2 inches in diameter, and conforms to ANSI standard C78.81- 2003 (Data Sheet 7881-ANSI-1006-1). (N) The term "F96T12/ES lamp" means a nomi nal 60 watt tubular fluorescent lamp that is 96 inches in length and 1 1/2 inches in diameter, and conforms to ANSI standard C78.81-2003 (Data Sheet 7881-ANSI-3006-1). (O) The term "F96T12HO/ES lamp" means a nominal 95 watt tubular fluorescent lamp that is 96 inches in length and 1 1/2 inches in diameter, and conforms to ANSI standard C78.81-2003 (Data Sheet 7881-ANSI-1017-1). (P) The term "replacement ballast" means a ballast that – (i) is designed for use to replace an existing ballast in a previously installed
luminaire; (ii) is marked "FOR REPLACEMENT USE ONLY"; (iii) is shipped by the manufacturer in packages containing not more than 10
ballasts; and (iv) has output leads that when fully ext ended are a total length that is less than the length of the lamp with which the ballast is intended to be operated.

“Fluorescent Lamps”

42 U.S.C. 6291(30)(A)

3A-7

### (A) Except as provided in subparagraph (E), the term “fluorescent lamp” means a low pressure mercury electric-dis charge source in which a fluorescing coating transforms some of the ultraviolet energy generated by the mercury discharge into light, including only the following: (i) Any straight-shaped lamp (commonly referred to as 4-foot medium bi-pin lamps) with medium bi-pin bases of nominal overall length of 48 inches and rated wattage of 28 or more. (ii) Any U-shaped lamp (commonly referred to as 2-foot U-shaped lamps) with medium bi-pin bases of nominal over all length between 22 and 25 inches and rated wattage of 28 or more. (iii)Any rapid start lamp (commonly referre d to as 8-foot high output lamps) with recessed double contact bases of nominal overall length of 96 inches and 0.800 nominal amperes, as defined in ANSI C78.1-1978 and related supplements. (iv) Any instant start lamp (commonly referred to as 8-foot slimline lamps) with single pin bases of nominal overall length of 96 inches and rated wattage of 52 or more,as defined in ANSI C78.3-1978 (R1984) and related supplement ANSI C78.3a1985.

42 U.S.C. 6291(30)(E)

(E) The terms “fluorescent lamp” and “inc andescent lamp” do not include any lamp excluded by the Secretary, by rule, as a result of a determination that standards for such lamp would not result in significant energy savings because such lamp is designed for special applications or has sp ecial characteristics not available in reasonably substitutable lamp types.

“Ballast”

42 U.S.C. 6291(58)

The term `ballast' means a device used with an electric discharge lamp to obtain necessary circuit conditions (voltage, current, and waveform) for starting and operating.

“Electronic Ballast”

42 U.S.C. 6291(60)

The term `electronic ballast' means a device that uses semiconductors as the primary means to control lamp starting and operation.

DEFINITIONS IN DOE REGULATIONS

3A-8

### 10 CFR 430.2 – Definitions

Ballast means a device used with an electric discharge lamp to obtain necessary circuit conditions (voltage, current, and waveform) for starting and operating.

Ballast efficacy factor means the relative light output divided by the power input of a fluorescent lamp ballast, as measured under test cond itions specified in ANSI Standard C82.2–1984.

Electronic ballast means a device that uses semiconductors as the primary means to control lamp starting and operation.

Fluorescent lamp means a low pressure mercury electric-discharge source in which a fluorescing coating transforms some of the ultraviolet energy generated by the mercury discharge into light, including only the following: (1) Any straight-shaped lamp (commonly referred to as 4-foot medium bipin lamps) with medium bipin bases of nominal overall length of 48 inches and rated wattage of 25 or

more; (2) Any U-shaped lamp (commonly referred to as 2-foot U-shaped lamps) with medium bipin bases of nominal overall length between 22 and 25 inch es and rated wattage of 25

or more; (3) Any rapid start lamp (commonly referred to as 8-foot high output lamps) with

recessed double contact bases of nomin al overall length of 96 inches; (4) Any instant start lamp (commonly referred to as 8-foot slimline lamps) with single pin bases of nominal overall leng th of 96 inches and rated wattage of 52 or more; (5) Any straight-shaped lamp (commonly referr ed to as 4-foot miniature bipin standard output lamps) with miniature bipin bases of nominal ove rall length between 45 and 48 inches and rated wattage of 26 or more; and (6) Any straight-shaped lamp (commonly referr ed to 4-foot miniature bipin high output lamps) with miniature bipin bases of nomin al overall length between 45 and 48 inches and rated wattage of 49 or more.

Fluorescent lamp ballast means a device which is used to start and operate fluorescent lamps by providing a starting voltage and current and limiting the current during normal operation.

Replacement ballast means a ballast that—

(1) Is designed for use to replace an existing fluorescent lamp ballast in a previously installed luminaire; (2) Is marked “FOR REPLACEMENT USE ONLY”; (3) Is shipped by the manufacturer in packages containing not more than 10 fluorescent lamp ballasts; and (4) Has output leads that when fully extended are a total length that is less than the length of the lamp with which the ballast is intended to be operated.

3A-9

### This appendix provides the DOE test procedures for measuring the energy consumption of fluorescent lamp ballasts, as containe d in 10 CFR 430, Subpart B, Appendix Q.

3A.4 ENERGY INDEPENDENCE AND SECURITY ACT OF 2007

On December 19, 2007, the President signed into law the Energy Independence and Security Act of 2007 (EISA 2007) (P.L. 110-140). This legi slation amended certai n aspects of EPCA, including, in particular, the potential amendment of existing testing requirements for fluorescent lamp ballasts (see section 310 of EISA 2007) and addition of mandatory efficiency standards for metal halide lamp fixtures ( see section 324 of EISA 2007). Among other things, the new standard for metal halide lamp fixtures establishes requirements for the efficiency of the ballasts installed in metal halide lamp fixtures. DOE is aware that some companies that produce fluorescent lamp ballasts may also manufacture metal halide lamp ballasts and fixtures; therefore, the entirety of EISA 2007 section 324 is included here for reference.

SEC. 310. STANDBY MODE.

Section 325 of the Energy Policy and Conservation Act (42 U.S.C. 6295) is amended—

(1) in subsection (u)—

(A) by striking paragraphs (2), (3), and (4); and

(B) by redesignating paragraphs (5) and (6) as paragraphs (2) and (3), respectively;

(2) by redesignating subsection (gg) as subsection (hh);

(3) by inserting after subsection (ff) the following:

`(gg) Standby Mode Energy Use­

`(1) DEFINITIONS­

`(A) IN GENERAL- Unless the Secretar y determines otherwise pursuant to subparagraph (B), in this subsection:

`(i) ACTIVE MODE- The term `active mode' means the condition in which an energy-using product—

`(I) is connected to a main power source;

`(II) has been activated; and

3A-10

### `(III) provides 1 or more main functions.

`(ii) OFF MODE- The term `off mode ' means the condition in which an energy-using product—

`(I) is connected to a main power source; and

`(II) is not providing any st andby or active mode function.

`(iii) STANDBY MODE- The term `st andby mode' means the condition in which an energy-using product—

`(I) is connected to a main power source; and

`(II) offers 1 or more of the following user-oriented or protective functions:

`(aa) To facilitate the activation or deactivation of other functions (including active mode) by remote switch (including remote control), in ternal sensor, or timer.

`(bb) Continuous functions, including information or status displays (including clocks) or sensor-based functions.

`(B) AMENDED DEFINITIONS- The Secretary may, by rule, amend the definitions under subparagraph (A), taking into consideration the most current versions of Standards 62301 and 62087 of th e International Electrotechnical

Commission.

`(2) TEST PROCEDURES-

`(A) IN GENERAL- Test procedures for all covered products shall be amended pursuant to section 323 to include standby mode and off mode energy consumption, taking into consideration the most current versions of Standards 62301 and 62087 of the International Elect rotechnical Commission, with such energy consumption integrated into the overall energy efficiency, energy consumption, or other energy descriptor for each covered product, unless the Secretary determines that—

`(i) the current test procedures for a covered product already fully account for and incorporate the standby mode and off mode energy consumption of the covered product; or

3A-11

### `(ii) such an integrated test procedure is technically infeasible for a particular covered product, in which ca se the Secretary shall prescribe a separate standby mode and off mode en ergy use test procedure for the covered product, if technically feasible

. `(B) DEADLINES- The test procedure amendments required by subparagraph (A) shall be prescribed in a final rule no later than the following dates:

`(i) December 31, 2008, for battery char gers and external power supplies.

`(ii) March 31, 2009, for clothes dr yers, room air conditioners, and fluorescent lamp ballasts.

`(iii) June 30, 2009, for residential clothes washers.

`(iv) September 30, 2009, for resi dential furnaces and boilers.

`(v) March 31, 2010, for residential water heaters, direct heating equipment, and pool heaters.

`(vi) March 31, 2011, for residential dishwashers, ranges and ovens, microwave ovens, and dehumidifiers.

`(C) PRIOR PRODUCT STANDARDS- The test procedure amendments adopted pursuant to subparagraph (B) shall not be used to determine compliance with product standards established prior to the adoption of the amended test procedures.

`(3) INCORPORATION INTO STANDARD-

`(A) IN GENERAL- Subject to subparagraph (B), based on the test procedures required under paragraph (2), any final rule establishing or revising a standard for a covered product, adopted after July 1, 2010, shall incorporate standby mode and off mode energy use into a singl e amended or new standard, pursuant to subsection (o), if feasible.

`(B) SEPARATE STANDARDS- If not feas ible, the Secretary shall prescribe within the final rule a separate standard for standby mode and off mode energy consumption, if justified unde r subsection (o).'; and

(4) in paragraph (2) of subsection (hh) (as redesignated by paragraph (2)), by striking `(ff)' each place it appears and inserting `(gg)'.

3A-12

### SEC. 324. METAL HALIDE LAMP FIXTURES.

(a) DEFINITIONS.-- Section 321 of the Energy Policy and Conservation Act (42 U.S.C. 6291) (as amended by section 322(a)(2)) is am ended by adding at the end the following:

`(58) BALLAST.-- The term `ballast' means a device used with an electric discharge lamp to obtain necessary circuit conditions (vo ltage, current, and waveform) for starting and
operating.

`(59) BALLAST EFFICIENCY.--

`(A) IN GENERAL.-- The term `ballast e fficiency' means, in the case of a high intensity discharge fixture , the efficiency of a lamp and ballast combination, expressed as a percentage, and calculated in accordance with the following formula: Efficiency = P out 

### /P in



### .

`(B) EFFICIENCY FORMULA.-- For the purpose of subparagraph (A)-­

`(i) P out 

### shall equal the measured operating lamp wattage;

`(ii) P in 

### shall equal the measured operating input wattage;

`(iii) the lamp, and the capacitor when the capacitor is provid ed, shall constitute a nominal system in accordance with the ANSI Standard C78.43-2004;

`(iv) for ballasts with a frequency of 60 Hz, P in 

### and P out 

### shall be measured after lamps have been stabilized according to section 4.4 of ANSI Standard C82.6-2005 using a wattmeter with accuracy specifie d in section 4.5 of ANSI Standard C82.6­
2005; and

`(v) for ballasts with a frequency greater than 60 Hz, P in 

### and P out 

### shall have a basic accuracy of ±0.5 percent at the higher of-­

`(I) 3 times the output operating frequency of the ballast; or

`(II) 2 kHz for ballast with a frequency greater than 60 Hz.

`(C) MODIFICATION.-- The Secretary may, by rule, modify the definition of `ballast efficiency' if the Secretary determines that the modification is necessary or appropriate to carry out the purposes of this Act.

`(60) ELECTRONIC BALLAST.-- The term `el ectronic ballast' means a device that uses semiconductors as the primary means to control lamp starting and operation.

`(61) GENERAL LIGHTING APPLIC ATION.-- The term `general lighting application' means lighting that provides an interior or exterior area with overall illumination.

3A-13

### `(62) METAL HALIDE BALLAST.-- The term `metal halide ballast' means a ballast used to start and operate metal halide lamps.

`(63) METAL HALIDE LAMP.-- The term `m etal halide lamp' means a high intensity discharge lamp in which the major portion of the light is produced by radiation of metal halides and their products of dissociation, possi bly in combination with metallic vapors.

`(64) METAL HALIDE LAMP FIXTURE.-- The term `metal halide lamp fixture' means a light fixture for general ligh ting application designed to be operated with a metal halide lamp and a ballast for a metal halide lamp.

`(65) PROBE-START METAL HALIDE BALLAST. -- The term `probe-start metal halide

ballast' means a ballast that--

`(A) starts a probe-start metal halide lamp that contains a third starting electrode (probe) in the arc tube; and

`(B) does not generally contain an igniter but instead starts lamps with high ballast open circuit voltage.

`(66) PULSE-START METAL HALIDE BALLAST.--

`(A) IN GENERAL.-- The term `pulse-start metal halide ballast' means an electronic or electromagnetic ballast that starts a pulse-start metal halide lamp with high voltage pulses.

`(B) STARTING PROCESS.-- For th e purpose of subparagraph (A)-­

`(i) lamps shall be started by first providing a high voltage pulse for ionization of the gas to produce a glow discharge; and

`(ii) to complete the starting process, power shall be provided by the ballast to sustain the discharge through the glow-to-arc transition.'.

(b) COVERAGE.-- Section 322(a) of the Ener gy Policy and Conservation Act (42 U.S.C. 6292(a)) is amended-­

(1) by redesignating paragraph (19) as paragraph (20); and

(2) by inserting after paragraph (18) the following:

`(19) Metal halide lamp fixtures.'.

(c) TEST PROCEDURES.-- Section 323(b) of the Energy Policy and Conservation Act (42

U.S.C. 6293(b)) (as amended by section 301(b)) is amended by adding at the end the following:

3A-14

### `(18) METAL HALIDE LAMP BALLASTS.-- Test procedures for metal halide lamp ballasts shall be based on ANSI Standard C82.6-2005, entitled `Ballasts for High Intensity Discharge Lamps--Method of Measurement'.'.

(d) LABELING.-- Section 324(a)(2) of the En ergy Policy and Conservation Act (42 U.S.C. 6294(a)(2)) is amended-­

(1) by redesignating subparagraphs (C) through (G) as subparagraphs (D) through (H), respectively; and

(2) by inserting after subparagraph (B) the following:

`(C) METAL HALIDE LAMP FIXTURES.--

`(i) IN GENERAL.-- The Commission shall issue labeling rules under this section applicable to the covered product specified in section 322(a)(19) and to which standards are applicable under section 325.

`(ii) LABELING.-- The rules shall provide that the labeling of any metal halide lamp fixture manufactured on or after the later of January 1, 2009, or the date that is 270 days after the date of enactm ent of this subparagraph, shall indicate conspicuously, in a manner prescribed by the Commission under subsection (b) by July 1, 2008, a capital lette r `E' printed within a circle on the packaging of the fixture, and on the ballast contained in the fixture.'.

(e) STANDARDS.-- Section 325 of the Energy Policy and Conservation Act (42 U.S.C. 6295) (as amended by section 310) is amended-­

(1) by redesignating subsection (hh) as subsection (ii);

(2) by inserting after subsection (gg) the following:

`(hh) METAL HALIDE LAMP FIXTURES.-­

`(1) STANDARDS.-­

`(A) IN GENERAL.-- Subject to s ubparagraphs (B) and (C), metal halide lamp fixtures designed to be operated with lamps rated greater than or equal to 150 watts but less than or equal to 500 watts shall contain--

`(i) a pulse-start metal halide ballast with a minimum ballast efficiency of 88 percent;

`(ii) a magnetic probe-start ballast with a minimum ballast efficiency of 94 percent; or

3A-15

### `(iii) a nonpulse-start electronic ballast with-­

`(I) a minimum ballast efficiency of 92 percent for wattages greater than 250 watts; and

`(II) a minimum ballast efficiency of 90 percent for wattages less than or equal to 250 watts.

`(B) EXCLUSIONS.-- The standards established under subparagraph (A) shall not apply to--

`(i) fixtures with regulated lag ballasts;

`(ii) fixtures that use electronic ballasts that operate at 480 volts;

or

`(iii) fixtures that-­

`(I) are rated only for 150 watt lamps;

`(II) are rated for use in wet locations, as specified by the National Electrical Code 2002, section 410.4(A); and

`(III) contain a ballast that is rated to operate at ambient air temperatures above 50°C, as specified by UL 1029­

2001.

`(C) APPLICATION.-- The standards established under subparagraph (A) shall apply to metal halide lamp fix tures manufactured on or after the later of-­

`(i) January 1, 2009; or

`(ii) the date that is 270 days after the date of enactment of this

subsection.

`(2) FINAL RULE BY JANUARY 1, 2012.-­

`(A) IN GENERAL.-- Not later t han January 1, 2012, the Secretary shall publish a final rule to determine wh ether the standards established under paragraph (1) should be amended.

`(B) ADMINISTRATION.-- The final rule shall--

`(i) contain any amended standard; and

`(ii) apply to products manufactured on or after January 1, 2015.

3A-16

### `(3) FINAL RULE BY JANUARY 1, 2019.-­

`(A) IN GENERAL.-- Not later t han January 1, 2019, the Secretary shall publish a final rule to determine whether the standards then in effect

should be amended.

`(B) ADMINISTRATION.-- The final rule shall--

`(i) contain any amended standards; and

`(ii) apply to products manufactured after January 1, 2022.

`(4) DESIGN AND PERFORMANCE REQUIREMENTS.-- Notwithstanding any other provision of law, any standard est ablished pursuant to this subsection may contain both design and performance requirements.'; and

(3) in paragraph (2) of subsection (ii) (as redesignated by paragraph (2)), by striking `(gg)' each place it appears and inserting `(hh)'.

(f) EFFECT ON OTHER LAW.-- Section 327(c) of the Energy Policy and Conservation Act (42

U.S.C. 6297(c)) is amended-­

(1) in paragraph (8)(B), by striking the period at the end and inserting `; and'; and

(2) by adding at the end the following:

`(9) is a regulation concerning metal halid e lamp fixtures adopted by the California Energy Commission on or before January 1, 2011, except that-­

`(A) if the Secretary fails to issue a final rule within 180 days after the deadlines for rulemakings in section 325(hh), notw ithstanding any other provision of this section, preemption shall not apply to a regulation concerning metal halide lamp fixtures adopted by the California Energy Commission--

`(i) on or before July 1, 2015, if the Secretary fails to meet the deadline specified in section 325(hh)(2); or

`(ii) on or before July 1, 2022, if the Secretary fails to meet the deadline specified in section 325(hh)(3).'.

3A-17

### APPENDIX 5A. MATERIAL PRICES

TABLE OF CONTENTS

5A.1 INTRODUCTION .................................................................................................. 5A-1

5A.2 METHODOLOGY ................................................................................................. 5A-1

REFERENCES .................................................................................................................... ..... 5A-3

LIST OF TABLES

Table 5A.2.1 Baseline 2-lamp F32T8 IS Ballast ...................................................................... 5A-2

5A-i

### APPENDIX 5A. MATERIAL PRICES

5A.1 INTRODUCTION

This appendix presents the results of an anal ysis to determine how material prices might affect the manufacturer selling price of ballasts.

5A.2 METHODOLOGY

As discussed in the engineering analysis, preliminary TSD chapter 5, DOE conducted teardowns to determine the cost of the bill of materials (BOM) and appropriate direct labor costs for certain fluorescent lamp ballasts. The BO Ms use material prices from January 2009. DOE understands that changes in mate rial prices can affect the u ltimate manufacture r selling price. Therefore, DOE conducted an analysis to deter mine how the cost of the BOM would be affected if DOE used a 5-year average of material prices instead of the material prices in January 2009. For each component type, DOE determined the January 2009 index and a 5-year average index (spanning 2004 to 2008) from the Bureau of Labo r Statistics Producer Price Indices (PPIs). 1


### DOE then evaluated how the January 2009 material costs for ballasts varied from the 5-year average price for all ballasts. Including all changes in PPI from the 5-year average, the BOM price was affected by 1.4% for the baseline 2- lamp F32T8 ballast as shown in Table 5A.2.1. DOE analyzed the percentage difference for all ballasts and found that the BOM ranged from

- 0.4% to 2.9% different from the 5-year average. Because these variances are insignificant, DOE decided not to incorporate these material price changes in the engineering analysis.

5A-1

### Table 5A.2.1 Baseline 2-lamp F32T8 IS Ballast

Component Type Percentage

Cost of

BOM January

2009 PPI 2004 to 2008 Average PPI Percentage change from January 2009 to 5-year Average

PPI Capacitor 14.5% 108.0 109.0 1.0%

Resistor 2.0% 172.4 166.2 -3.7%

Diode* 6.4% 102.6 107.8 4.8%

Transistor* 12.8% 66.4 72.7 8.6%

Analog † 

### 3.4% 63.6 81.7 22.2%

Printed Circuit Board 6.3% 103.0 101.4 -1.6% Magnetic 26.8% 171.2 152.9 -11.9%

Connector 9.3% 222.6 256.9 13.3%

Cold-Rolled Sheets 11.0% 170.4 191.0 10.8%

Fuse 1.0% N/A N/A N/A

Plastics & Elastomers 4.8% N/A N/A N/A

Other 1.7% N/A N/A N/A

Total 100% 1.4%
*2004 to 2008 Average PPI does not include the December 2008 price.

† Price represents a 3.5 year average as data previous to June 2005 is not available. N/A signifies that the PPI for that material was not available

5A-2

### REFERENCES

1 

### U.S. Department of Labor, Bureau of Labor Statistics, Producer Price Indices. (Last accessed June 30, 2009). < http://www.bls.gov/ppi >.

5A-3

### APPENDIX 5B. T5 MAGNETIC MINIATURE BIPIN BASELINE BALLASTS

TABLE OF CONTENTS

5B.1 INTRODUCTION .........................................................................................................5B-1

5B.2 METHODOLOGY AND RESULTS ............................................................................5B-1

LIST OF TABLES

Table 5B.2.1 Common Electronic 2-lamp 4-f oot MiniBP T5 SO and HO Ballasts..................5B-1 Table 5B.2.2 Commercially Available Magnetic and Electronic Ballasts ................................5B-2 Table 5B.2.3 Model Magnetic and Electronic 2-lamp 4-foot MiniBP T5 SO and HO

Ballasts .........................................................................................................5B-3

5B-i

### APPENDIX 5B. T5 MAGNETIC MINIATURE BIPIN BASELINE BALLASTS

5B.1 INTRODUCTION

Most T5 ballasts are efficient electronic ballasts. During manufacturer interviews, several manufacturers expressed concern that less-efficacious T5 ballasts may enter the U.S. market if no standard is put into place. One manufact urer in particular stat ed that a magnetic T5 ballast might enter the market in the future if T5 ballasts were not covered by standards. Because DOE believes that consumers will pur chase magnetic 4-foot T5 balla sts without a T5 standard if such ballasts are brought to market, DOE develope d models of 4-foot T5 standard output (SO) and high output (HO) magnetic ballasts as ba selines for the SO and HO T5 product classes, respectively. This appendix details the deve lopment of those models. In particular, DOE developed models of a 2-lamp ma gnetic ballast that operates F28T5 lamps and 2-lamp magnetic ballast that operates F54T5HO lamps.

5B.2 METHODOLOGY AND RESULTS

To determine the BEF of a magnetic T5 ballast, DOE analyzed the percentage difference

in BEF for normal ballast factor systems with a similar input power to the T5 system under investigation. DOE tested a range of 2-lamp F28T5 and F54T5HO ballast s from multiple ballast

manufacturers and found that the least effici ent but most common ballast exhibited the

characteristics shown in the table below. The va st majority of F28T5 and F54T5HO ballasts are programmed start (PS), electronic, have a high power factor (PF) (>0.98), low total harmonic distortion (THD) (<10%), and are universal voltage. Furthermore DOE tested the ballast at 277 volts (V) as the majority of ballasts operate in commercial buildings at 277V.

Table 5B.2.1 Common Electronic 2-lamp 4- foot MiniBP T5 SO and HO Ballasts

For Operation

of Starting Method, Input Voltage, Ballast Type, PF,

THD Ballast

Factor

(BF) Input

Power

(W) Ballast Efficiency BEF

2, F28T5 PS, 277V, Electronic, Universal Voltage, 0.99 PF, <10% THD 1.02 64.9 87.1% 1.441

2, F54T5HO PS, 277V, Electronic, Universal Voltage, >0.98 PF, <10% THD 0.99 124.8 85.4% 0.791



### The input power of the 2-lamp F28T5 ballast is similar in range to the input power of the 2-lamp F34T12 and F32T8 electronic ballasts (58W and 60W respectively). The input power of the 2-lamp F54T5HO is in similar range to the input power of the 2-lamp F96T12/ES electronic

5B-1

### ballast (110W). a 

### Because magnetic ballasts are commercially available to operate these lamps, DOE was able to determine the percentage di fference in input power between magnetic and electronic ballasts. Because magnetic ballasts do not exhibit the same BF as electronic ballasts, DOE adjusted the input power of the magnetic ballast so that DOE could compare the input power directly. The adjusted input power was calculated as follows:

Electronic 

### AdjustedInputPower = BF * InputPower Magnetic 

### Equation 5B.2.1 BF Magnetic 

### AdjustedInputPower = 

### Input Power of Magnetic Ballast adjusted to account for difference in
ballast factor (BF)

BF Electronic 

### = BF of electronic ballast

BF Magnetic 

### = 

### BF of magnetic ballast

InputPower Magnetic 

### = 

### Input power of magnetic ballast

Table 5B.2.2 Commercially Available Magnetic and Electronic Ballasts

For Operation

Of Ballast Type BF Input Power Adjusted Input Power

2, F32T8

Lamps Magnetic 0.95 76 70

2, F32T8

Lamps Electronic 0.88 58 58

2, F34T12

Lamps Magnetic 0.88 72 71

2, F34T12

Lamps Electronic 0.87 60 60

2, F96T12/ES Lamps Magnetic 0.88 126 126

2, F96T12/ES Lamps Electronic 0.88 110 110



### Using the adjusted input power, DOE calculated th at the average increase in input power while maintaining BF. For the F32T8 and F34T12, the av erage increase in input power was 20%. For the F96T12/ES, the average increase in input pow er was 15%. DOE applied these percentages to the F28T5 and F54T5HO ballasts respectively to determine the input power of the ballast. DOE

assumed this ballast would exhi bit the same BF as its electronic counterpart. The results are displayed in the following table.

a Although DOE tested electronic F96T12/ES and F32T8 elec tronic ballasts, DOE used catalog values because DOE chose not to test magnetic F96T12/ES and F32T8 magnetic ballasts.

5B-2

### Table 5B.2.3 Model Magnetic and Electronic 2-la mp 4-foot MiniBP T5 SO and HO Ballasts

For Operation

Of Ballast Type BF Input Power

2, F28T5 Magnetic 1.02 77.8

2, F54T5HO Magnetic 0.99 143.5



### DOE assumed that these magnetic ballasts would exhibit the similar characteristics as their electronic counterparts (e.g., th ese ballasts would be PS) because DOE believes that these ballasts would be used as replacements and ther efore be in the same product class as their electronic counterparts.

5B-3

### APPENDIX SC . FLUORES C ENT LAMP BALLAST TEST DATA

TABLE OF C ONTENTS

SC

. l INTRODU C TION

......................................................................................................... SC-l

SC

. 2 TEST DATA

.................................................................................................................. SC-l

LIST OF TABLES

T able SC

. l B allasts T hat O perate F our- F oot MBP and T wo- F oot U

- S haped L amps

............... SC-l

T able SC

. 2 B allasts T hat O perate F our- F oot M ini BP T S SO L amps

........................................ SC-S

T able SC

. 3 B allasts T hat O perate F our- F oot M ini BP T S H O L amps

....................................... SC-6

T able SC

. B allasts T hat O perate E ight- F oot SP S limline L amps

............................................ SC-6

T able SC

. S B allasts T hat O perate E ight- F oot RD C H O L amps

................................................ SC-7

T able SC

. 6 B allasts T hat O perate F our- F oot MBP and T wo- F oot U

- S haped L amps in the

R esidential S ector

........................................................................................ SC-8

T able SC

. 7 B allasts that O perate E ight- F oot H O L amps in Cold T emperature

A pplications and O utdoor S igns

.................................................................. SC-8

S C

- iAPPENDIXSC.FLUORESCENT LAMP BALLAST TEST DATASC.tINTRODUCTIONThefollowingappendixlists thetest dataDOEused to develop the engineeringanalysis.DOEchoseto test a varietyofballasts from many different manufacturers.Through an independent testingfacility,DOEtested both the ballast efficacy factor (BEF)and ballast efficiency (BE) of the ballast. ForBEF,DOEused the test procedure outlined in l0 CFR30,SubpartB,Appendix �. ForBE,DOEused the test procedure proposed in the fluorescentlamp ballast activemode test procedure notice of proposed rulema�ing.Three examples of each ballast type were tested, and the averageof the three test results is displayed for each ballast type inthe tablesbelow.SC.2TESTDATATableSC.tBallastsThatOperateFour-FootMBPandTwo-FootU-ShapedLampsManufacturerNumberofLampsLampDiameter(t18ofinches)LampLength(inches)LampNominalPower(W)StartingMethodBallastNominalInputVoltage(V)UniversalInputVoltage?(Y1N)MeasuredBallastInputVoltage(V)inBEFtestingMeasuredBallastInputPower(W)inBEFtestingMeasuredBallastFactorinBEFtestingMeasuredBallastEfficacyFactorMeasuredBallastInputVoltage(V)inBEtestingMeasuredBallastInputPower(W)inBEtestingMeasuredLampArcPower(W)inBEtestingMeasuredBallastEfficiencyAlT8832ISl20Nl20.0333.0.8892.6S8l20.033.728.30.8lBlT8832ISl20Nl20.0330.60.8 22.7 7l20.030.S2S.20.827AlT8832IS277Y277.l032.20.8772.722277.l032.927.l0.823AlT8832IS277Y277.l029.70.8 92.8SS277.0829.2.90.8 SAlT8832IS277N277.l732.30.8822.736277.0832.726.S0.8l2BlT8832IS277N277.l03l.S0.8632.7 3277.063l.32S.S0.8lBlT8832IS277Y277.l028.00.8 83.026277.082.32l.70.892BlT8832IS277Y277.l027.80.8 33.036277.l323.92l.30.89lClT8832IS277Y277.l030.20.88S2.929277.l03l.827.60.869ClT8832IS277Y277.0730.00.8SS2.8S2277.0830.32S.70.8 8SC-lManufacturerNumberofLampsLampDiameter(t18ofinches)LampLength(inches)LampNominalPower(W)StartingMethodBallastNominalInputVoltage(V)UniversalInputVoltage?(Y1N)MeasuredBallastInputVoltage(V)inBEFtestingMeasuredBallastInputPower(W)inBEFtestingMeasuredBallastFactorinBEFtestingMeasuredBallastEfficacyFactorMeasuredBallastInputVoltage(V)inBEtestingMeasuredBallastInputPower(W)inBEtestingMeasuredLampArcPower(W)inBEtestingMeasuredBallastEfficiencyDlT8832IS277N277.l03l.l0.8892.8S9277.0S3l.826.90.8 SDlT8832IS277Y277.l029.80.8 32.833277.0329.02.00.828DlT8832IS277Y277.l030.80.8662.8l277.0630.92S.60.830DlT8832PS277Y277.0732.60.92S2.838277.0733.828.0.8 0A2Tl283RS277N276.9763.S0.862l.3S9N.D.N.D.N.D.N.D.B2Tl283RS277Y276.996.30.8SSl.330N.D.N.D.N.D.N.D.C2Tl283RS277N276.9l63.0.862l.36lN.D.N.D.N.D.N.D.D2Tl283RS277N276.986l.20.8 ll.37N.D.N.D.N.D.N.D.D2Tl283RS277N277.0l6S.30.8S2l.30SN.D.N.D.N.D.N.D.A2T8832IS277Y277.07S3.30.79Sl.92277.078.S2.20.870A2T8832IS277Y277.02S7.90.880l.Sl9277.086l.lSS.00.900A2T8832IS277Y277.0078.0l.lS6l.82277.lllS.3l0S.0.9lA2T8832IS277Y277.07S0.80.763l.S03277.l8.839.30.876A2T8832IS277Y277.03S6.00.860l.S3S277.09S7.SS2.00.90SA2T8832IS277N277.0078.9l.l8Sl.S02276.99l22.Sll3.00.923A2T8832IS277N277.060.0.87Sl.S0****B2T8832IS277N277.07S8.20.8 6l.S277.09S7.S9.0.860B2T8832IS277Y277.0078.6l.l99l.S2277.0879.87.l0.928B2T8832IS277Y277.039.S0.7S8l.S3l277.2039.23S.l0.89SB2T8832IS277Y277.06S.l0.8 2l.SS277.078.3.30.9l8B2T8832IS277Y277.0078.l.lS6l.7S277.02ll6.l06.00.9llB2T8832IS277Y277.07S0.00.760l.S20277.ll3.738.l0.87lB2T8832IS277Y276.98S6.0.866l.S3S277.0S8.9S3.S0.908C2T8832IS277Y277.0079.0l.l79l.93276.9l2S.3llS.S0.92lC2T8832IS277Y277.07S0.00.7S8l.SlS277.0l.239.0.890C2T8832IS277Y277.02S6.0.87l.S 9276.96S9.3S.60.920C2T8832IS277Y276.9780.3l.l92l.8S277.0ll26.llS.70.9lSC2T8832IS277Y277.07S.20.766l.l3277.067.38.S0.8llC2T8832IS277Y277.0SSS.90.863l.S276.99S7.9S3.l0.9l7D2T8832IS277N277.078.S0.7 6l.S38277.lll.637.30.897D2T8832IS277N277.03S2.l0.8ll.S63277.07S0.0S.80.9l6SC-2ManufacturerNumberofLampsLampDiameter(t18ofinches)LampLength(inches)LampNominalPower(W)StartingMethodBallastNominalInputVoltage(V)UniversalInputVoltage?(Y1N)MeasuredBallastInputVoltage(V)inBEFtestingMeasuredBallastInputPower(W)inBEFtestingMeasuredBallastFactorinBEFtestingMeasuredBallastEfficacyFactorMeasuredBallastInputVoltage(V)inBEtestingMeasuredBallastInputPower(W)inBEtestingMeasuredLampArcPower(W)inBEtestingMeasuredBallastEfficiencyD2T8832IS277N277.07S3.S0.78ll.60277.0S9.ll.80.8S2D2T8832IS277N277.02S9.00.86l.66277.0l60.7S2.30.86lD2T8832IS277Y277.039.80.7S2l.S08277.073.l37.S0.869D2T8832IS277Y277.03SS.0.8 0l.Sl6277.0S.88.80.890D2T8832IS277Y277.007S.Sl.llSl.76277.02l08.399.30.9l6D2T8832IS277Y277.00SS.60.8SSl.S38277.00S6.8Sl.S0.907A2T8832PS277Y277.076.00.683l.83277.0S3S.229.80.8 6A2T8832PS277Y276.9SS6.70.86ll.Sl7277.03SS.SS0.00.902A2T8832PS277N276.9863.S0.896l.l2277.069.2S8.30.8 3B2T8832PS277N277.00S8.30.879l.S09277.036l.SSS.l0.896B2T8832PS277Y277.0076.6l.l33l.79276.99ll0.Sl0l.80.92lB2T8832PS277Y277.008.30.7lSl.83277.060.3.0.8SlB2T8832PS277Y277.07S8.60.87ll.86277.036l.S.70.89lB2T8832PS277Y277.07S.80.609l.33l277.03.2.l0.70lC2T8832PS277Y276.98S6.90.863l.Sl6276.97S8.9S3.l0.902D2T8832PS277Y277.0063.30.89ll.08277.0S62.Sl.60.827A3T8832IS277Y276.878S.30.869l.0l9277.l388.079.70.906A3T8832IS277Y277.0083.20.8 6l.0l7277.lS82.S7.l0.898A3T8832IS277N277.008S.90.872l.0lS277.0989.680.70.900B3T8832IS277N277.0083.90.8l.006277.l983.7.60.89SB3T8832IS277Y276.9782.S0.8S0l.03l277.098l.77.20.907B3T8832IS277Y276.978.80.8Sl.008277.08S.776.20.890C3T8832IS277Y276.978S.00.868l.022277.lS87.879.80.909C3T8832IS277YN.D.N.D.N.D.N.D.277.0087.079.S0.9l3D3T8832IS277N277.0379.0.826l.0 0277.l077.87l.60.920D3T8832IS277N277.0087.60.8 S0.96277.0788.27S.60.8S7D3T8832IS277Y277.0083.l0.8 8l.02l277.078.976.90.90SD3T8832IS277Y277.0082.70.8l.02l277.0982.87.0.900D3T8832PS277Y277.0090.80.86l0.9 9277.l288.37S.00.8 9AT8832IS277Y276.93l00.S0.7760.772277.l389.679.60.888AT8832IS277Y276.8Sll2.80.8S20.7S6276.87ll.3l0.70.9l6SC-3ManufacturerNumberofLampsLampDiameter(t18ofinches)LampLength(inches)LampNominalPower(W)StartingMethodBallastNominalInputVoltage(V)UniversalInputVoltage?(Y1N)MeasuredBallastInputVoltage(V)inBEFtestingMeasuredBallastInputPower(W)inBEFtestingMeasuredBallastFactorinBEFtestingMeasuredBallastEfficacyFactorMeasuredBallastInputVoltage(V)inBEtestingMeasuredBallastInputPower(W)inBEtestingMeasuredLampArcPower(W)inBEtestingMeasuredBallastEfficiencyAT8832IS277Y276.90lSS.6l.l9l0.766277.02237.62ll.70.89lAT8832IS277Y276.979S.30.7 S0.782277.l80.772.l0.89AT8832IS277Y276.92ll.0.8660.7S7276.90ll8.ll08.60.920AT8832IS277N276.86llS.S0.8730.7S6276.86l20.Sll0.90.920BT8832IS277N277.0llll.S0.8370.7Sl277.2lll0.299.70.90SBT8832IS277Y276.90l 3.6l.l360.79l277.0Sl76.0l66.S0.9 6BT8832IS277Y276.9796.0.7S00.777277.l383.67.60.892BT8832IS277Y276.9Sll0.l0.8390.762276.92l07.899.30.92lBT8832IS277Y276.90l 7.l.l 20.77S BT8832IS277Y276.93ll0.60.8S80.776277.l0ll2.ll0l.l0.902BT8832IS277YN.D.N.D.N.D.N.D.277.086.277.60.900CT8832IS277Y276.93l S.2l.l20.77** **CT8832IS277Y276.9797.90.77l0.788277.l88.l80.90.9l8CT8832IS277Y276.9lll3.70.86l0.7S8276.97ll7.ll07.80.92lCT8832IS277Y276.9796.00.7S30.78S277.l682.87.20.897CT8832IS277Y276.9ll2.60.8720.77276.9llS.0l06.l0.923DT8832IS277N276.9793.30.7360.789277.l78.67l.70.9llDT8832IS277N276.93l06.80.8230.77l276.87l03.696.0.93lDT8832IS277N276.90l 7.7l.l370.770277.l220S.ll90.S0.929DT8832IS277N277.0096.80.7 70.772277.lS83.77.80.89DT8832IS277N276.86ll0.90.8 20.760276.8Slll.2l02.l0.9l8DT8832IS277Y276.9393.0.7370.788277.lS79.972.30.90SDT8832IS277Y276.90l09.20.83l0.76l276.88l08.099.00.9l7DT8832IS277Y276.97l09.S0.8S30.779277.lSlll.3l0l.20.909BT8832PSl20Nl20.0ll7.00.8670.7 2l20.l2l22.0ll0.S0.906AT8832PS277Y277.0392.l0.7l20.772277.l27l.06.30.907AT8832PS277Y276.88ll.60.8880.77S276.9lll0.ll02.60.932AT8832PS277N276.90l20.30.86S0.7l9276.8Sl30.ll09.l0.839BT8832PS277Y276.90l 8.8l.l 70.77l277.0322.2207.0.92SBT8832PS277Y276.97ll2.70.8770.778276.87ll9.8ll0.80.92SCT8832PS277Y276.83ll6.l0.8800.7S8276.9l9S.78S.S0.89SCManufacturerNumberofLampsLampDiameter(t18ofinches)LampLength(inches)LampNominalPower(W)StartingMethodBallastNominalInputVoltage(V)UniversalInputVoltage?(Y1N)MeasuredBallastInputVoltage(V)inBEFtestingMeasuredBallastInputPower(W)inBEFtestingMeasuredBallastFactorinBEFtestingMeasuredBallastEfficacyFactorMeasuredBallastInputVoltage(V)inBEtestingMeasuredBallastInputPower(W)inBEtestingMeasuredLampArcPower(W)inBEtestingMeasuredBallastEfficiencyDT8832PS277Y276.9lll8.80.8 30.709276.88ll2.69.60.8 0B6T8832IS277YN.D.N.D.N.D.N.D.277.03283.3267.30.9 3N.D.indicatesDOEdid not perform the measurement, "no data."*When connected to a resistor, the ballast did not operate.The ballast did operate a lamp successfully.TableSC.2BallastsThatOperateFour-FootMiniBP TSSO LampsManufacturerNumberofLampsLampDiameter(t18ofinches)LampLength(inches)LampNominalPower(W)StartingMethodBallastNominalInputVoltage(V)UniversalInputVoltage?(Y1N)MeasuredBallastInputVoltage(V)inBEFtestingMeasuredBallastInputPower(W)inBEFtestingMeasuredBallastFactorinBEFtestingMeasuredBallastEfficacyFactorMeasuredBallastInputVoltage(V)inBEtestingMeasuredBallastInputPower(W)inBEtestingMeasuredLampArcPower(W)inBEtestingMeasuredBallastEfficiencyClTS628PS277Y277.2330.80.9973.23277.0932.928.80.873A2TS628PS277Y277.ll6.9l.0l9l.S70277.l67.lS8.0.87lB2TS628PS277Y277.0S9.80.9S7l.600277.l7S8.2Sl.l0.877B2TS628PS277Y276.9870.Sl.l ll.6l8277.lS89.8l.l0.907C2TS628PS277Y277.0663.6l.0l0l.S87277.lS67.0S8.S0.87C2TS628PS277Y276.876l.7l.000l.620277.08l8.39.60.S2SD2TS628PS277Y277.0SS8.70.9 8l.6l3276.8962.SS.0.869D2TS628PS277Y276.936S.l.06ll.62276.6968.l6l.00.896SC-STableSC.�BallastsThatOperateFour-FootMiniBP TS�O LampsManufacturerNumberofLampsLampDiameter(t18ofinches)LampLength(inches)LampNominalPower(W)StartingMethodBallastNominalInputVoltage(V)UniversalInputVoltage?(Y1N)MeasuredBallastInputVoltage(V)inBEFtestingMeasuredBallastInputPower(W)inBEFtestingMeasuredBallastFactorinBEFtestingMeasuredBallastEfficacyFactorMeasuredBallastInputVoltage(V)inBEtestingMeasuredBallastInputPower(W)inBEtestingMeasuredLampArcPower(W)inBEtestingMeasuredBallastEfficiencyClTS6SPS277Y276.89S9.2l.0l6l.7l6277.06S9.SS3.S0.899A2TS6SPS277Y277.l3l26.3l.0l70.806277.0Slll.97.80.878B2TS6SPS277Y277.07l2.80.9880.79l****B2TS6SPS277Y276.97l20.70.9700.80276.99l08.696.90.892C2TS6SPS277Y276.9l23.7l.0060.8l3277.0Sl0S.393.90.89lD2TS6SPS277Y277.0l22.l.0lS0.829277.0Sl03.93.0.903ATS6SPS277Y277.032 0.9l.0Sl0.36276.99228.207.60.909BTS6SPS277Y277.07220.70.97S0.2276.992ll.9l89.S0.89DTS6SPS277Y277.03226.Sl.0l30.7277.02207.7l87.S0.903*When connected to a resistor, the ballast did not operate.The ballast did operate a lamp successfully.TableSC.�BallastsThatOperateEight-FootSPSlimlineLampsManufacturerNumberofLampsLampDiameter(t18ofinches)LampLength(inches)LampNominalPower(W)StartingMethodBallastNominalInputVoltage(V)UniversalInputVoltage?(Y1N)MeasuredBallastInputVoltage(V)inBEFtestingMeasuredBallastInputPower(W)inBEFtestingMeasuredBallastFactorinBEFtestingMeasuredBallastEfficacyFactorMeasuredBallastInputVoltage(V)inBEtestingMeasuredBallastInputPower(W)inBEtestingMeasuredLampArcPower(W)inBEtestingMeasuredBallastEfficiencyBlT896S9IS277Y277.07S6.00.89l.S96276.969.0S.30.926BlT896S9IS277Y277.07S7.60.878l.S23277.0lS3.77.30.882DlT896S9IS277N277.00S7.70.883l.S29277.l9S.98.60.88D2Tl29660ISl20Nll9.92l07.0.8S00.792N.D.N.D.N.D.N.D.A2Tl29660IS277N277.00ll.30.9070.79N.D.N.D.N.D.N.D.B2Tl29660IS277Y276.89lll.90.8920.798N.D.N.D.N.D.N.D.C2Tl29660IS277N277.00ll.80.9080.79lN.D.N.D.N.D.N.D.D2Tl29660IS277N276.83lll.l0.88S0.797N.D.N.D.N.D.N.D.D2Tl29660IS277N276.86l09.S0.880.807N.D.N.D.N.D.N.D.D2Tl29660IS277Y276.88lll.20.9000.809N.D.N.D.N.D.N.D.A2T896S9ISl20Nl20.Sll0.S0.8290.79l20.ll89.8l.20.908B2T896S9ISl20Nl20.20ll2.90.8760.776l20.l0l02.29l.70.898A2T896S9IS277Y277.03l0S.70.8S00.80277.l92.88.80.9lSC-6ManufacturerNumberofLampsLampDiameter(t18ofinches)LampLength(inches)LampNominalPower(W)StartingMethodBallastNominalInputVoltage(V)UniversalInputVoltage?(Y1N)MeasuredBallastInputVoltage(V)inBEFtestingMeasuredBallastInputPower(W)inBEFtestingMeasuredBallastFactorinBEFtestingMeasuredBallastEfficacyFactorMeasuredBallastInputVoltage(V)inBEtestingMeasuredBallastInputPower(W)inBEtestingMeasuredLampArcPower(W)inBEtestingMeasuredBallastEfficiencyA2T896S9IS277N277.00l0S.0.8Sl0.807277.l92.28.0.9lSB2T896S9IS277N277.00l07.S0.8S90.799277.l697.S89.60.920B2T896S9IS277Y276.9ll0S.20.8S90.8l7277.069l.88.90.92SB2T896S9IS277YN.D.N.D.N.D.N.D.277.l298.290.70.92C2T896S9IS277Y276.9l09.S0.8870.8l0277.0999.892.l0.922C2T896S9IS277Y276.97l l.Sl.l260.796277.0ll76.ll6.30.933C2T896S9IS277Y277.0093.S0.7S80.8ll276.97l.96S.80.9lC2T896S9IS277Y276.77l08.00.870.8l0277.0397.089.0.922D2T896S9IS277N276.86l0.90.8680.827277.l69.88.S0.938D2T896S9IS277N277.0092.80.7S80.8l7277.l772.l66.90.928D2T896S9IS277N276.97ll0.20.8730.792277.ll02.l92.S0.906D2T896S9IS277N276.93l7.ll.lS60.786277.07l8.3l69.l0.9l7D2T896S9IS277Y276.92l09.70.8660.789277.lS99.889.80.900N.D.indicatesDOEdid not perform the measurement, "no data."TableSC.SBallastsThatOperateEight-FootRDC�O LampsManufacturerNumberofLampsLampDiameter(t18ofinches)LampLength(inches)LampNominalPower(W)StartingMethodBallastNominalInputVoltage(V)UniversalInputVoltage?(Y1N)MeasuredBallastInputVoltage(V)inBEFtestingMeasuredBallastInputPower(W)inBEFtestingMeasuredBallastFactorinBEFtestingMeasuredBallastEfficacyFactorMeasuredBallastInputVoltage(V)inBEtestingMeasuredBallastInputPower(W)inBEtestingMeasuredLampArcPower(W)inBEtestingMeasuredBallastEfficiencyA2Tl2969SRS277Y276.90l88.30.8S80.S6N.D.N.D.N.D.N.D.A2Tl2969SRS277N276.9ll66.00.80.S09N.D.N.D.N.D.N.D.B2Tl2969SRS277N276.87l96.70.8790.7N.D.N.D.N.D.N.D.C2Tl2969SRS277N276.7S208.0.9l70.0N.D.N.D.N.D.N.D.C2Tl2969SRS277N276.92l6.60.8360.S08N.D.N.D.N.D.N.D.D2Tl2969SRS277N276.8l72.20.87S0.S08N.D.N.D.N.D.N.D.D2Tl2969SRS277Y276.8ll69.l0.8970.S3lN.D.N.D.N.D.N.D.D2Tl2969SRS277N276.92l9S.00.90l0.62N.D.N.D.N.D.N.D.D2T89686ISl20Nl20.03l38.80.6220.8l20.08l08.296.l0.888B2T89686IS277Y277.07l38.70.6S20.70277.ll97.386.S0.889SC-7D2T89686IS277N277.03l 2.80.6760.73277.l6l02.79l.80.89A2T89686PS277Y276.93l8S.80.860.6S277.03l97.2l72.60.87SC2T89686PS277Y277.l0l7S.00.7730.2277.08l6S.7l 8.0.896A2T89686RSl20Nl20.00l62.l0.7 00.S6l20.02l3.9ll3.0.8 lN.D.indicatesDOEdid not perform the measurement, "no data."TableSC.�BallastsThatOperateFour-FootMBPandTwo-FootU-ShapedLampsintheResidentialSectorManufacturerNumberofLampsLampDiameter(t18ofinches)LampLength(inches)LampNominalPower(W)StartingMethodBallastNominalInputVoltage(V)UniversalInputVoltage?(Y1N)MeasuredBallastInputVoltage(V)inBEFtestingMeasuredBallastInputPower(W)inBEFtestingMeasuredBallastFactorinBEFtestingMeasuredBallastEfficacyFactorMeasuredBallastInputVoltage(V)inBEtestingMeasuredBallastInputPower(W)inBEtestingMeasuredLampArcPower(W)inBEtestingMeasuredBallastEfficiencyAlTl283RSl20Nll9.9S3.00.66Sl.9S7N.D.N.D.N.D.N.D.A2Tl283RSl20Nl20.0063.l0.8 ll.332N.D.N.D.N.D.N.D.B2Tl283RSl20Nll9.976.60.860l.332N.D.N.D.N.D.N.D.�2Tl283RSl20Nl20.l82.0.627l.80N.D.N.D.N.D.N.D.L2Tl283RSl20Nl20.l0S0.30.6S2l.297N.D.N.D.N.D.N.D.E2T8832ISl20Nll9.88SS.30.832l.S0Sl20.0S.38.l0.88SE2T8832ISl20Nl20.02S3.l0.780l.70l20.0S8.82.20.86A2T8832ISl20Nl20.00S.80.83ll.Sl7ll9.99S3.38.20.90B2T8832ISl20Nl20.00SS.70.8l8l.70ll9.98S2.96.0.877C2T8832ISl20Nl20.00S7.S0.8S7l.90ll9.96S6.8S0.20.88SD2T8832ISl20Nl20.00SS.90.839l.S00ll9.98SS.39.0.893AT8832ISl20Nl20.l0l02.l0.7830.767l20.l792.82.0.89lBT8832ISl20Nl20.l0l07.20.82l0.766l20.lSl02.9l.80.897CT8832ISl20Nl20.l0ll3.20.8S60.7S6l20.llll2.7l00.l0.888DT8832ISl20Nl20.l0ll.60.8 S0.738l20.0Sll3.298.60.87lN.D.indicatesDOEdid not perform the measurement, "no data."TableSC.�BallaststhatOperateEight-Foot�O LampsinColdTemperatureApplicationsandOutdoorSignsManufacturerNumberofLampsLampDiameter(t18ofinches)LampLength(inches)LampNominalPower(W)StartingMethodBallastNominalInputVoltage(V)UniversalInputVoltage?(Y1N)MeasuredBallastInputVoltage(V)inBEFtestingMeasuredBallastInputPower(W)inBEFtestingMeasuredBallastFactorinBEFtestingMeasuredBallastEfficacyFactorMeasuredBallastInputVoltage(V)inBEtestingMeasuredBallastInputPower(W)inBEtestingMeasuredLampArcPower(W)inBEtestingMeasuredBallastEfficiencyFlTl296ll0ISl20Nl20.l0l03.90.90l0.867N.D.N.D.N.D.N.D.SC-8ManufacturerNumberofLampsLampDiameter(t18ofinches)LampLength(inches)LampNominalPower(W)StartingMethodBallastNominalInputVoltage(V)UniversalInputVoltage?(Y1N)MeasuredBallastInputVoltage(V)inBEFtestingMeasuredBallastInputPower(W)inBEFtestingMeasuredBallastFactorinBEFtestingMeasuredBallastEfficacyFactorMeasuredBallastInputVoltage(V)inBEtestingMeasuredBallastInputPower(W)inBEtestingMeasuredLampArcPower(W)inBEtestingMeasuredBallastEfficiencyF2Tl296ll0ISl20Nl20.03l7.0.7900.S3N.D.N.D.N.D.N.D.D2Tl296ll0ISl20Yl20.00l33.0.6l30.60N.D.N.D.N.D.N.D.F3Tl296ll0ISl20Nl20.l0l7S.l0.S370.306N.D.N.D.N.D.N.D.�3Tl296ll0ISl20Nl20.l3l77.l0.S 20.306N.D.N.D.N.D.N.D.FTl296ll0ISl20Nl20.l0269.l0.6030.22N.D.N.D.N.D.N.D.HTl296ll0ISl20Nll9.90260.80.6l80.237N.D.N.D.N.D.N.D.�Tl296ll0ISl20Nl20.l0269.70.6070.22SN.D.N.D.N.D.N.D.DTl296ll0ISl20Yl20.002S.60.6070.238N.D.N.D.N.D.N.D.DTl296ll0ISl20Yll9.9026.00.6280.238N.D.N.D.N.D.N.D.FTl296ll0RSl20Nl20.03388.0.7780.200N.D.N.D.N.D.N.D.ITl296ll0RSl20Nl20.03l80.00.300.l69N.D.N.D.N.D.N.D.DTl296ll0RSl20Nl20.00393.60.77l0.l96N.D.N.D.N.D.N.D.F6Tl296ll0ISl20Nll9.733 0.30.S3l0.lS6N.D.N.D.N.D.N.D.F6Tl296ll0ISl20Nl20.2308.80.6360.lS6N.D.N.D.N.D.N.D.H6Tl296ll0ISl20Nl20.03397.80.62S0.lS7N.D.N.D.N.D.N.D.�6Tl296ll0ISl20Nl20.003 9.30.6090.l7N.D.N.D.N.D.N.D.�6Tl296ll0ISl20Nll9.903 3.80.S 60.lS9N.D.N.D.N.D.N.D.D6Tl296ll0ISl20Yl20.00399.20.6 l0.l6lN.D.N.D.N.D.N.D.�6Tl296ll0ISl20Yl20.l0l8.S0.6290.lS0N.D.N.D.N.D.N.D.N.D.indicatesDOEdid not perform the measurement, "no data."SC-9

### APPENDIX 5D. MAX-TECH

TABLE OF CONTENTS

5D.1 OVERVIEW ................................................................................................................. 5D-1

5D.2 METHODOLOGY ....................................................................................................... 5D-1

5D.3 ACTIVE RECTIFICATION ......................................................................................... 5D-1

5D.3.1 Efficiency .................................................................................................... 5D-2

5D.3.2 Price ............................................................................................................ 5D-2

5D.4 IMPROVED COMPONENTS...................................................................................... 5D-2

5D.4.1 Efficiency .................................................................................................... 5D-3

5D.4.2 Price ............................................................................................................ 5D-3

5D.5 CONCLUSION ............................................................................................................. 5D-4

LIST OF TABLES

Table 5D.1 Incremental Price Increase Per Ballast To Go From Passive to Active

Rectification ................................................................................................ 5D-2 Table 5D.2 Component Price Mar kups and Price Composition............................................... 5D-4

5D-i

### APPENDIX 5D. MAX-TECH

5D.1 OVERVIEW

When the U.S. Department of Energy (DOE) pr oposes to adopt or to decline to adopt an amended or new standard for a type (or class) of covered product, as pa rt of the rulemaking process, DOE must ‘‘determine the maximum improvement in energy efficiency or maximum reduction in energy use that is technologically feasible’’ for the product. (42 U.S.C. 6295(p)(1)) In the technology assessment, DOE identifie d various technology options employed in commercially available ballasts to improve efficiency. DOE then applied the four screening criteria to determine which of these options DOE would consider in the engineering analysis. In this chapter DOE presents two technology options that are not currently used in commercially available ballasts. Although these two options have not yet met the screening criteria of technological feasibility, DOE believes they may be a viable option for improving the efficiency of ballasts beyond that which exists in the market today. In this appendix, DOE discusses these options and presents incremental efficiency and price increases associated with each one. DOE requests comment on the maximum technologically f easible ballast efficiency and its associated

costs.

5D.2 METHODOLOGY

DOE investigated multiple sources to identify the two possible technology options presented in this appendix. DOE obtained info rmation from manufacturer interviews, subject matter experts, scholarly article s, U.S. patents, and manufactur er marketing information. DOE also considered efficiency improvements used in comparable products, such as power supplies. The following sections discuss active rectifi cation and certain improved components that DOE identified to improve a ballast’s efficiency beyond that of the most efficient ballasts currently

available.

5D.3 ACTIVE RECTIFICATION

In the engineering analysis, the most efficient ballasts DOE identified were electronic ballasts. As described in the technology a ssessment (preliminary TSD chapter 3), the second stage of an electronic ballast is the input rectifier, which convert s AC to DC current. Through its research, DOE learned that commercially availa ble ballasts use a process known as passive rectification to complete this step. A passive rect ification circuit typically consists of four diodes to rectify the AC waveform. Passive rectification is currently used in commercially available ballasts because it is simple to design, contains few parts, is very reliable, and is cheap to

manufacture. 1



### With technological advancem ents in electronics in th e past few decades and new developments in controls, meta l-oxide-semiconductor field-effect transistors (MOSFETs) have become a popular component of power electronics . MOSFETs have much lower electrical losses compared to diodes. Active rectification uses th ese MOSFETs in place of diodes to convert AC to DC current. Because MOSFETs operate in a slightly different manner than diodes, an

5D-1

### integrated circuit is necessary to switch the MOSFETs on and off as required. Even though this requires additional circuitry, the use of active rectification still results in an overall increase in efficiency because the electrical losses of the MOSFETs are much smaller than that of the

diodes.

5D.3.1 Efficiency

In the technology assessment (preliminar y TSD chapter 3), DOE classified the rectification stage of an electronic ballast as having a relatively low impact on overall ballast efficiency. However, when considering impr ovements required to move above 92 percent efficiency, even small improveme nts matter. After conversations with subject matter experts and parts suppliers, DOE believes that going from passive to active rectification could result in a one percentage point increase in overall efficiency.

5D.3.2 Price

To determine the incremental increase in pric e to go from passive to active rectification, DOE interviewed part suppliers and reviewed the bill of material from its teardown analysis to identify prices of individual components. DOE calculated the average cost of a passive rectification circuit – assuming the main component s of the circuit were four diodes. DOE then calculated a minimum, average, and maximum cost of an active rectification circuit – assuming the circuit was composed of four MOSFETs and a chip instead of four diodes. The incremental prices specified in the table below represent th e minimum, average, and maximum cost of an active rectification circuit minus the average cost of a passive rectification circuit.

Table 5D.1 Incremental Price Increase Per Ballast To Go From Passive to Active

Rectification

Min
$ Average
$ Max
$
Manufacturer Selling Price 0.02 1.69 4.62



### 5D.4 IMPROVED COMPONENTS

As described in the technology assessment (preliminary TSD chapter 3), improving the quality of the components in a ballast can increase efficiency. In particular, diodes, transistors, transformers, and capacitors are the main components that impact efficiency. Using the most efficient 2-lamp, 4-foot 32 watt medium bipin ballast as a point of reference, DOE used manufacturer datasheets to identify alternative co mponents with lower electrical losses to be used in a more efficient ballast design. If mo re than one alternative existed, DOE chose the component that demonstrated the lowest electri cal losses and therefore had the greatest potential to impact overall efficiency. DOE considered imp rovements for all components of the ballast, regardless of the stage in which they were used.

5D-2

### 5D.4.1 Efficiency

Based on conversations with subject matte r experts and members of the ballast and electronics community, DOE believes improving th e efficiency (reducing electrical losses) of components which are currently included in the most efficient commercia lly available ballast could result in a 1 to 2 percentage point increase in efficiency. In this section, DOE discusses the characteristics of the alternative compone nts it identified as possible substitutes.

DOE discovered that many types of diodes are employed in fluorescent ballasts, including: traditional silicon p-n junction diodes; avalanche diodes; Zener diodes; transient voltage suppression diodes; switc hing diodes; Schottky diodes; and DIAC trigger diodes. For this analysis, DOE proposes to replace traditional silicon p-n junction diodes with silicon carbide Schottky diodes. Although the substitute is significantly more expensive than the diode currently in use in commercially available ballasts, it offers the greatest improvement in efficiency. Economic impacts are considered in the life-cycle cost and national impact analyses. For the remaining diode types, DOE did not identify more efficient alternatives.

For transformers, DOE considered the use of improved core materials to reduce core losses. A higher quality core material can decrease the losses attributable to hysteresis and eddy currents. DOE assumed transformers currently used in fluorescent lamp ballasts employ an inexpensive, low-grade steel. DOE believes that M-43 non-oriented steel best approximates the low-grade, non-oriented steel in commercially av ailable ballasts. Thus, to improve efficiency, DOE proposes using M-2 a 

### grain-oriented steel instead of lo w-grade, non-oriented steel in the

core of the transformers.

For transistors and capacitors, DOE had limite d success in identifying more efficient replacements. As indicated in Table 5D.2, DOE found altern ative MOSFETs with reduced electrical losses, but did not lo cate more efficient bipolar tran sistors. Thus, DOE only proposes to replace existing MOSFETS with a more effici ent substitute. For electrolytic capacitors, DOE identified several more efficient components as po tential replacements for low-voltage (less than 100 volts) electrolytic capacitors, but did not find more efficient alternatives for high-voltage (greater than 100 volts) electrolytic capacitors or for metalized polypropylene film capacitors. Consequently, DOE only proposes to replace exis ting low-voltage electrolytic capacitors with

more efficient substitutes.

5D.4.2 Price

To determine the incremental price for replacing the components found in the most efficient commercially available ballast with the most effici ent components available, DOE compared online pricing from electronics distribut ors. DOE divided the price of most efficient component on the market by the price for the component currently used in the ballast to determine a price markup. DOE then applied the markup to the component prices identified in the teardown analysis of the most efficient commercially available ballast. The resulting price is an estimate of the cost of the most efficient component on the market. By executing this process

a The American Iron and Steel Institute designates the grad e of electrical steel with an ‘M’ followed by a number.

Smaller numbers indicate electrical steel with smaller losses.

5D-3

### for all of the components for which DOE identified a more efficient replacement, DOE was able to calculate the price of a ballast that uses the most efficient components available. b 

### DOE estimated the MSP of this theoretical ballast to be 56 percent more expensive than the most efficient commercially available ballast.

Table 5D.2 Component Price Markups and Price Composition

Component Type % of MSP for the most efficient commercially available ballast Markup % of MSP for the theoretical

max-tech ballast Diode, silicon p-n junction type 2% 29.1 31%

MOSFET 5% 1.45 4% Electrolytic capac itor <1% 1.4 <1% Transformer, core c 14% 1.99 17%



### 5D.5 CONCLUSION

As described in the above sections, DOE identified two technology options that may improve ballast efficiency beyond that of commercially available ba llasts. Both of these options are employed in power supplies and other comp arable power products. Although neither option is present in commercially available ballasts, DOE believes it is likely that they are technologically feasible because they are em ployed in similar products. As such, DOE has included them in this appendix to request comme nt on the likelihood that these two options will improve the overall efficiency of existing ballasts. DOE also requests comment its estimates of the incremental efficiency improvements and price increases associated with each option.

b For example, if the price for the component currently used in the ballast was $0.50 using an online distributor’s pricing and the most efficient replacement was $0.75, the markup would be 1.5. The markup of 1.5 would then be applied to the estimated price in the teardown bill of materials (for example, $0.30) to estimate a max-tech component cost of $0.45.

c For transformers, DOE assumed 60 percent of the manufactur er production cost is attributable to the core and 40 percent to the windings. These estimates were based on a bill of material acquired from a teardown analysis of a small electric motor. The small electric motor in this analysis had copper wire windings and non-oriented steel

cores.
5D-4

### REFERENCES

1 

### Santiago, Walter and Arthur G. Birchenough. Single Phase Rectification Versus Active Rectification Applied to High Power Stirling Engines . Third International Energy Conversion Engineering Conference; 2005 Aug 15 – 18; San Fr ancisco, California. Maryland: NASA Center for Aerospace Information; 2006. p. 1-12.

5D-5

### APPENDIX 12A. MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDE



# Fluorescent Lamp Ballasts Rulemaking Manufacturer Analysis Interview Guide

October 23, 2008

12A-1

### P ART 

### 1. M ARKET 

### , T ECHNOLOGY 

### , AND 

### E NGINEERING 

### A NALYSIS



### A. Market Data

This section addresses informati on on the distribution of fluorescen t lamp ballast by efficiency and ballast type. At the framework meeting, DOE said that it would consider covering those ballasts that operate lamps covered in the lamps rulemaking while maintaining current exemptions (i.e, low power factor residential ba llasts, cold temperature F96HO ballasts used in outdoor signs, and dimming ballasts). The following lists those ballasts that cover those lamps proposed for coverage in the lamps ANOPR.

o 1-lamp, 2-lamp, 3-lamp, and 4-lamp ballasts that opera te 4-foot linear and 2-foot Ushaped medium bipin T8 and T12 lamps (e.g., F40T12, F34T12, F32T8, F30T8, F28T8, F25T8)

o 1-lamp and 2-lamp ballasts that operate 8-foot single pin slimline T8 and T12 lamps (e.g., F96T12, F96T12/ES, F96T8, F96T8/ES)

o 1-lamp and 2-lamp ba llasts that operate 8-foot rece ssed double contact high output T8 and T12 lamps (e.g., F96T12HO, F96T12HO/ES, F96T8HO)

DOE received written comments and comments at th e public meeting that DOE should cover the following ballast types:

o Low power factor, re sidential ballasts

o Dimming ballasts for T5, T8, and T12 lamps

o Cold temperature ballasts used in outdoor signs

o Ballasts that operate T5 lamps

o Mini ballasts

o Ballasts for straight and U-shaped lamps ranging in size from two to eight feet and T5

to T12

A.1 DOE seeks comment on the current market share of each of the balla st types listed above (e.g., low power factor, residen tial ballasts) and how that market share might change in

the future.

A.2 DOE seeks comment on whether it is technologic ally feasible to improve the efficiency

of the ballasts mentioned above.

A.3 Are there specific reasons why DOE should or should not cover any of the ballasts listed above? Should DOE consider covering any additional ballasts to those listed above?

DOE is considering analyzing the following ballasts in the engineering analysis:

o 2-lamp and 4-lamp F40T12, F34T12, and F32T8 ballasts

o 2-lamp F96T12, F96T12/ES, and F96T8 ballasts

12A-2

### o 2-lamp F96T12HO, F96T12HO/ES, and F96T8HO ballasts

A.4 DOE seeks comment on whether these are the mo st appropriate fluores cent lamp ballasts to study in detail.

A.5 For the ballasts identified, DOE seeks comment on the most common ballast sold in each of the ballast categories. Please describe ba llast attributes (i.e ., electronic/magnetic, starting method, ballast factor, i nput power, THD, power factor)

In order to calculate the aggregate national ener gy savings, DOE would need data on shipment trends. For each of the ballast types, DOE is in terested in obtaining shipment data by number of lamps operated and ba llast efficiency. DOE is also intere sted in understanding general market dynamics.

A.6 For each ballast type considered for coverage (e.g., for F32T8 ballasts, F40T12 ballasts, or F96T12 ballasts), what is the proportion of ballasts shipped that operate 1-lamp, 2

- lamp, 3-lamp, and 4-lamps? Do you expect these proportions to change overtime? If so,

how?

A.7 For electronic F32T8 and F96T8 ballasts, what is the proportion of ballasts shipped that are high efficiency versus standard ef ficiency? Absent new energy conservation standards, do you expect these proportions to change overtime? If so, how?

A.8 For F32T8 ballasts, what is the proportion of ballasts shipped that are programmed start versus instant start? Absent new energy conservation standards, do you expect these proportions to change overtime? If so, how?

A.9 For F96T12HO and F96T12HO/ES ballasts, what proportion of ballasts shipped are magnetic versus electronic? Absent new en ergy conservation standards, do you expect these proportions to change overtime? If so, how?

A.10 For F32T8 ballasts, what propor tion of ballasts shipped are ma gnetic versus electronic? Absent new energy conservation standards, do you expect these proportions to change overtime? If so, how?

A.11 What are general trends you see in the market? Absent new energy conservation standards, do you foresee other technologies (e.g., HID or LED) increasing in market share over the next thirty-five years? If so, how?

12A-3

### A.12 What proportion of ballasts shipped are sold in the new renovation market, the replacement market, the early retrofit market, and the new construction market?

B. Engineering Analysis

DOE would like to understand the incremental costs of reducing ballast en ergy consumption by understanding the design options involved in e fficiency improvements. Please describe the discrete design steps you would undertake to achiev e the ballasts in the tables below. In each case, start with a standard efficiency balla st, and list the necessary design changes 1 

### to enable it to become more efficient. For each design change, please also provide an estimate of your incremental production cost over the baseline, as well as the total unit selling price to an OEM or

distributor. If additional rows are needed to describe all the design changes you would make, please feel free to modify the tables.

The column labeled “Incr. Cost (over Std. Ballast ) per Imp.” represents the cost of the specific improvement described. The column labeled “Total Mfr. Unit Selling Price to OEM Fixture Mfr” is your final selling price to your OEM fixture manufacturer. The column labeled “Total Mfr. Unit Selling Price to Comm. or Ind. Sect.” is your final selling price to a distributor or

contractor in the commercia l or industrial sector.

We recognize that detailed designs may be difficult to prepare; therefore, in the interests of generating reasonable results in a short space of time, we invite you to use your best judgment and experience when completing the following tables.

1 Design changes could include using capacitors with low effective series resistance, diodes with low forward voltage drop or low conduction losses, low loss magnetic materials, or low loss DC to AC circuit topologies.

12A-4Table 1 Engineering Analysis for Electro nic Instant Start 2-lamp F32T8 Ballasts

Total Total

Mfr. Mfr.

# Ballast Type Input Power,

Ballast

Factor Defining Design

Characteristics Mfr.

Production

Cost Unit Selling

Price to

OEM

Fixture Unit Selling

Price to

Comm.

or Ind.

Mfr. Sect.

Standard

0 Instant Start 2

- Lamp F32T8

Ballasts

# Ballast Type Input Power,

Ballast

Factor Improvements over Standard

Ballast Incr. Cost (over Std. Ballast) per Imp. Total

Mfr.

Unit Selling

Price to

OEM

Fixture

Mfr. Total

Mfr.

Unit Selling

Price to

Comm.

or Ind.

Sect.

High Efficiency Instant Start, 2

- 1 Lamp F32T8

Ballasts

Maximum Technologically

Feasible Instant 2 Start 2-Lamp,

F32T8 Ballasts

12A-5Table 2 Engineering Analysis for Electroni c Programmed Start 2-lamp F32T8 Ballasts

Total Total

Mfr. Mfr.

# Ballast Type Input Power,

Ballast

Factor Defining Design

Characteristics Mfr.

Production

Cost Unit Selling

Price to

OEM

Fixture Unit Selling

Price to

Comm.

or Ind.

Mfr. Sect.

Standard

0 Programmed 2

- Lamp F32T8

Ballast

# Ballast Type Input Power,

Ballast

Factor Improvements over Standard

Ballast Incr. Cost (over Std. Ballast) per Imp. Total

Mfr.

Unit Selling

Price to

OEM

Fixture

Mfr. Total

Mfr.

Unit Selling

Price to

Comm.

or Ind.

Sect.

High Efficiency Programmed Star,

1 2-Lamp F32T8

Ballast

Maximum Technologically Feasible,

2 Programmed Start 2-Lamp F32T8

Ballast



### D.1 For 2-lamp F40T12 or F34T12 electronic ba llasts, what are the defining design characteristics and the total manufacturing selling price? Can the efficiency for these commercially available ballasts be improved? If so, what improveme nts can be made and how would this impact the power consumed, th e cost to manufacture the ballast, and the selling price?

D.2 How would the answers given in Table 1 and Table 2 change for fluorescent lamp ballasts operating 4-lamps?

12A-6Table 3 Engineering Analysis for Electro nic Instant Start 2-lamp F96T8 Ballasts

Total Total

Mfr. Mfr.

# Ballast Type Input Power,

Ballast

Factor Defining Design

Characteristics Mfr.

Production

Cost Unit Selling

Price to

OEM

Fixture Unit Selling

Price to

Comm.

or Ind.

Mfr. Dist.

Standard,

0 Instant Start 2

- Lamp F96T8

Ballast

# Ballast Type Input Power,

Ballast

Factor Improvements over Standard

Ballast Incr. Cost (over Std. Ballast) per Imp. Total

Mfr.

Unit Selling

Price to

OEM

Fixture

Mfr. Total

Mfr.

Unit Selling

Price to

Comm.

or Ind.

Sect.

High Efficiency,

Instant Start 2

- 1 Lamp F96T8

Ballast

Maximum Technologically

2 Feasible 2-Lamp

F96T8 Ballast



### D.3 For 2-lamp F96T12 or F96T12/ES electronic ballasts, what are the defining design characteristics and the total manufacturing selling price? Can the efficiency for these commercially available ballasts be improved? If so, what improveme nts can be made and how would this impact the power consumed, th e cost to manufacture the ballast, and the selling price?

12A-7Table 4 Engineering Analysis for 2-lamp F96T12HO Ballasts

Total Total

Mfr. Mfr.

# Ballast Type Input Power,

Ballast

Factor Defining Design

Characteristics Mfr.

Production

Cost Unit Selling

Price to

OEM

Fixture Unit Selling

Price to

Comm.

or Ind.

Mfr. Sect.

Magnetic, Rapid

0 Start 2-Lamp

F96T12HO Ballast

# Ballast Type Input Power,

Ballast

Factor Improvements over Standard

Ballast Incr. Cost (over Std. Ballast) per Imp. Total

Mfr.

Unit Selling

Price to

OEM

Fixture

Mfr. Total

Mfr.

Unit Selling

Price to

Comm.

or Ind.

Sect.

Electronic, Rapid

Start 2-Lamp 1 F96T12HO Ballast

Maximum Technologically

2 Feasible 2-Lamp

F96T12HO Ballast



### D.4 For 2-lamp electronic F96T8HO ballasts, what are the defining design characteristics and the total manufacturing selling price? Can the efficiency for these commercially available ballasts be improved? If so, what improvements can be made and how would this impact the power consumed, the cost to manufacture the ballast, and the manufacturer selling price?

12A-8

### D.5 If there are additional ballasts you feel DOE should cover, what are defining design characteristics and total manufacturer selling price? Can the efficiency of these ballasts be improved? If so, what improvements can be made and how would this impact the power consumed, the cost to manufacture the ballast, and the manufacturer selling price?

D.6 How do you apply markups to your production costs in order to arrive at an OEM and distributor selling price?

C. Distribution Channels, Lifetime and Operating Hours

DOE will need to develop a distribution chain model to understand how ba llasts migrate through

the market from manufacturer to end-user. DOE is interested in understanding both the proportion (volume) of products th at move through certain channe ls and the mark-ups applied. The following figure displays the distributi on chain provided by NEMA in the 2000 Ballast Rule. According a comment provided by NE MA in the 2000 Ballast Rulemaking, 63% of ballasts moved through channel A while 37% moved through channels B and C. DOE also

assumed that a 13% contractor markup was applied from the Contr actor/LMC to the End User of the Lighting System.

Figure 1: 1999 NEMA Ballast Distribution Channels

12A-9

### C.1 Is the distribution chain displayed in Figure 1 an accurate representation of how ballasts reach the end user? If so, what proporti on of shipments move through the various channels (e.g., A, B, or C), and what are the typical mark-ups applied by organizations or individuals in those channels (e.g., mark up applied by the OEM Fixture Manufacturer to the Distributor)? Do your answers vary on the sector of the end-user of the lighting system? If so, how? Assumptions used in th e 2000 Ballast rulemaking for some of these estimates are provided above.

C.2 DOE is intending to consider fluorescent lamp ballasts operating in different sectors. For the fluorescent lamp ballasts under consideration in this rulemaking, can you provide an estimate of the proportion of fluorescent lamp ballasts sold into the commercial, industrial, and residential sect ors? What proportion of ballast shipments to the residential sector are low power factor, residential balla sts versus high power factor ballasts?

According to our analysis using EIA data and data from the U.S. Lighting Market Characterization, Volume I (DOE, 2002), the aver age annual operating hours for GSFL is 3,435 hours for the commercial sector, 4,795 hours for th e industrial sector and 789 hours for the

residential sector.

C.3 Are these reasonable estimates? If not, wh at is the average annual operating hours by sector? Does the average annual operating hours vary significantly by fluorescent lamp ballast type?

In the fluorescent lamp ANOPR analysis, DOE assumed that the most common T8 lamp operating on an instant start electronic balla st had a lifetime of 20,000 hours at 3 hours on 20

minutes off.

C.4 What would the lamp lifetime be when operating on a programmed start electronic ballast at 3 hours on 20 minutes off? at 1 hour on, 15 minutes off?

In the fluorescent lamp ANOPR analysis and in the 2000 Ballast Rule, DOE assumed that

lifetime of a ballast was approximately 50,000 hours. Us ing average operating hours in the commercial sector, industrial, and residential sector, one calculates a ballast life of approximately 15 years, 10 year s, or 63 years respectively.

C.5 DOE understands ballasts are some times replaced before they fa il due to lighting retrofits or renovations. On average, how often are ballasts replaced in each sector (i.e, what is their average useful lifetime)? Does this li fetime vary by starting method, efficiency, or ballast type?

C.6 What is the average fixture lifetime in each sector? In general, why are fixtures replaced (e.g., fixture “failure”, renova tion, or ballast failure)?

D. Test Procedure and Energy Conservation Standards At the framework meeting, NEMA recommended that DOE may want to change the energy

conservation standard metric from ballast efficacy factor (BEF) to ballast efficiency in part because of the inherent variance of the BEF measurement due to the use of fluorescent lamps.

12A-10

### Unfortunately, DOE may not be able to legally change the metric from BEF but it can change the test procedure to measure BEF. One way to acco mplish this is to use resistors instead of lamps

to determine the ballast factor and input power of a ballast. In order for DOE to determine whether or not to change the test procedure fo r ballasts, it must understand whether the new test procedure would improve upon the old test procedure.

D.7 For each of the ballasts described above, what is the variability in input power and ballast factor for any given ballast under the current test procedure?

D.8 For the F30T8, F28T8, F25T8, and F96T8/ES there are no ANSI standards specifying which lamp to use when testing a ballast. What are the qualities of the lamps you use to

test ballast factor and i nput power for these ballasts? These qualities will help DOE establish a new test procedure measuring ba llast efficacy factor using resistors.

In the framework document, DOE proposed that it may establish product classes for fluorescent lamp ballasts regardless of lamp wattage or lamp diameter. To account for the variance in BEF by lamp wattage, DOE could develop an equati on from which manufacturers would calculate the minimum BEF energy conservation standard based on the fluorescent lamps’ wattage.

D.9 Can you describe how ballast efficacy factor varies by lamp wattage for the following fluorescent lamp ballasts?

• 4-lamp and 2-lamp ballasts that operate 4-foot linear and 2-foot U-shaped medium bipin lamps

• 2-lamp ballasts that operate 8-foot single pin slimline lamps

• 2-lamp ballasts that opera te 8-foot recessed double contact high output lamps

The Team is considering extrapolating energy conservation standards from the analyzed fluorescent lamp ballasts to other product classes.

D.10 Can you describe how this ex trapolation might be applied to the following fluorescent lamp ballasts?

• From 4-lamp ballasts to 3-lamp ballasts that operate 4-foot linear and 2-foot Ushaped medium bipin T8 and T12 lamps

• From 2-lamp ballasts to 1-lamp ballasts that operate 4-foot linear and 2-foot Ushaped medium bipin T8 and T12 lamps

• From 2-lamp ballasts to 1-lamp ballasts that operate 8-foot single pin slimline T8 and T12 lamps

• From 2-lamp ballasts to 1-lamp ballasts that opera te 8-foot recessed double contact high output T8 and T12 lamps

12A-11

### P ART 

### 2. P RELIMINARY 

### M ANUFACTURER 

### I MPACT 

### A NALYSIS 

### T OPICS



### 1 Key Issues

1.1 What are the key issues for your company regarding this fluorescent lamp ballast rulemaking?

1.2 Are there any patent, technology, or other issu es that you are aware of that would prevent your company or competitors from implementing higher-efficiency designs?

2 Shipment Projections

2.1 What is your company’s approximate market share for the fluorescent lamp ballasts DOE is considering covering?

2.2 Would you expect your market share to change once standards become effective? Does your outlook change with higher efficiency levels?

2.3 How would you expect shipments to change for the industry as a whole as a function of standards and why?

2.4 Looking at price/cost effects only, how woul d you expect shipments to change for a 25%, 50%, 100% or 200% manufacturer price/cost increase?

3 Conversion Costs

3.1 What level of capital expenditu re and product conversion costs would you anticipate to make at higher standard levels? Please describe what they are and provide your best estimate of their respective magnitudes.

3.2 How would the imposition of new energy conservation standards affect capacity, utilization and manufacturing assets at your domestic production fac ilities? Would a new standard result in stranded capital assets? Would any facilities be closed or downsized? Added or upgraded?

3.3 How might a new standard impact product innovation?

4 Product Mix and Profitability

4.1 How would your company’s product mix and mark eting strategy change with changes in the efficiency standard?

12A-12

### 4.2 Generally how would new product standards impact your customer mix, distribution channels, and corresponding profit margins?

4.3 What is the approximate percenta ge of shipments (i.e., market share) for each ballast type?

4.4 Do you enjoy consistent profitability across all fluorescent lamp ballast types?

5 Market Shares and Industry Consolidation

5.1 In the absence of new standards, do you expect any industry consolidation?

5.2 How would new standards affect your ability to compete?

5.3 Could new standards dispropor tionately advance or harm the competitive positions of

some firms?

5.4 Are there concerns over intellectual property?

5.5 Could new standards result in disproportiona te economic or performance penalties for particular consumer/user subgroups?

5.6 Beyond price and energy efficiency, could ne w standards result in products that will be more or less desirable to consumers due to changes in pr oduct functionality, utility, or

other features?

6 Cumulative Regulatory Burden

6.1 Are there recent or impending regulations on your specific product or other products that impose a cumulative burden on the industry?

6.2 If so, what is the total expected impact of those other regulations?

12A-13

### APPENDIX EA-SCC. SOCIAL COST OF CARBON FOR REGULATORY IMPACT

ANALYSIS UNDER EXE CUTIVE ORDER 12866

TABLE OF CONTENTS

EA-SCC.1 EXECUTIVE SUMMARY

..................................................................................... 1

EA-SCC.2 MONETIZING CARBON DIOXIDE EMISSIONS

............................................... 2

EA-SCC.3 SOCIAL COST OF CARBON VALUES USED IN PAST

REGULATORY ANALYSES

............................................................................................ 4

EA-SCC.4 APPROACH AND KEY ASSUMPTIONS

............................................................ 5

EA-SCC.4.1 Integrated Assessment Models

................................................................. 5

EA-SCC.4.1.1 The DICE Model

.......................................................................... 7

EA-SCC.4.1.2 The PAGE Model

........................................................................ 8

EA-SCC.4.1.3 The FUND Model

........................................................................ 8

EA-SCC.4.1.4 Damage Functions

....................................................................... 9

EA-SCC.4.2 Global versus Domestic Measures of SCC

............................................. 11

EA-SCC.4.2.1 Global SCC

................................................................................ 11

EA-SCC.4.2.2 Domestic SCC

............................................................................ 12

EA-SCC.4.3 Valuing Non-CO 2 

### Emissions

.................................................................. 12

EA-SCC.4.4 Equilibrium Climate Sensitivity

............................................................. 13

EA-SCC.4.5 Socio-Economic and Emissions Trajectories

.......................................... 16

EA-SCC.4.6 Discount Rate

.......................................................................................... 18

EA-SCC.4.6.1 Historically Observed Interest Rates

......................................... 20

EA-SCC.4.6.2 The Ramsey Equation

................................................................ 21

EA-SCC.4.6.3 Accounting for Uncertainty in the Discount Rate

...................... 23

EA-SCC.4.6.4 The Discount Rates Se lected for Estimating SCC

..................... 24

EA-SCC.5 REVISED SCC ESTIMATES

............................................................................... 24

EA-SCC.6 LIMITATIONS OF THE ANALYSIS

.................................................................. 29

EA-SCC.7 A FURTHER DISCUSSION OF CATASTROPHIC IMPACTS AND

DAMAGE FUNCTIONS

.................................................................................................. 32

EA-SCC.7.1 Extrapolation of Climate Damages to High Levels of Warming

............ 32

EA-SCC.7.2 Failure to Incorporate Inter-Sectoral and Inter-Regional

Interactions

............................................................................................................. 33

EA-SCC.7.3 Imperfect Substitutabilit y of Environmental Amenities

......................... 33

EA-SCC.8 CONCLUSION

...................................................................................................... 34

EA-SCC.9 APPENDIX

............................................................................................................ 4 1

EA-SCC.9.1 Other (non-CO 2 

### ) Gases

........................................................................... 42

EA-SCC.9.2 Extrapolating Emi ssions Projections to 2300

......................................... 44

LIST OF TABLES

Table 1.1. Social Cost of CO 2 

### , 2010–2050 (2007$)

........................................................................ 2 Table 4.1. Summary Statistics fo r Four Calibrated Climate Sensitivity Distributions

.................. 14

EA-SCC.i

### Table 4.2. Socioeconomic and Emissions Pr ojections from Select EMF-22 Reference

Scenarios

................................................................................................................ 16 Table 5.1. Disaggregated Social Cost of CO 2 

### Values by Model, Socio-Economic Trajectory, and Discount Rate for 2010 (2007$)

................................................... 27

Table 5.2. Social Cost of CO 2 

### , 2010–2050 (2007$)

...................................................................... 28 Table 5.3. Changes in the Average Annual Growth Rates of S CC Estimates between

2010 and 2050

........................................................................................................ 29 Table 7.1. Probabilities of Various Tipping Points from Expert Elicitation

................................. 32 Table 9.1. Annual SCC Values: 2010–2050 (2007$)

.................................................................... 41

Table 9.2. 2010 Global SCC Estimates at 2.5 Percent Discount Ra te (2007$/ton CO 2 

### )

............... 49

Table 9.3. 2010 Global SCC Estimates at 3 Percent Discount Rate (2007$/ton CO 2 

### )

.................. 49

Table 9.4. 2010 Global SCC Estimates at 5 Percent Discount Rate (2007$/ton CO 2 

### )

.................. 49

Table 9.5. Additional Summa ry Statistics of 2010 Global SCC Estimates

.................................. 50

LIST OF FIGURES

Figure 4.1. Annual Consumption Loss as a Fraction of Global GDP in 2100 Due to an Increase in Annual Global Temperat ure in the DICE, FUND, and PAGE

Models

.................................................................................................................... 10 Figure 4.2. Annual Consumption Loss for Lower Temperature Changes in DICE, FUND,

and PAGE

.............................................................................................................. 10 Figure 4.3. Estimates of the Probability De nsity Function for Equilibrium Climate Sensitivity

.............................................................................................................. 15 Figure 5.1. Level of Global GDP Across EMF Scenarios

............................................................. 28 Figure 9.1. Sulphur Dioxide Emission Scenarios

.......................................................................... 44 Figure 9.2. Global Population, 2000–2300 (pos t-2100 extrapolations assume the population growth rate changes linearly to reach a zero growth rate by 2200)

...................................................................................................................... 46 Figure 9.3. World GDP, 2000-2300 (post-2100 extr apolations assume GDP per capita growth declines linearly, reaching zero in 2300)

................................................... 46 Figure 9.4. Global Fossil and Industrial CO 2 

### Emissions, 2000-2300 (post-2100 extrapolations assume growth rate of CO 2 

### intensity (CO 2 

### /GDP) over 2090–2100 is maintained through 2300)

............................................................... 47 Figure 9.5. Global Net Land Use CO 2 

### Emissions, 2000–2300 (post-2100 extrapolations assume emissions decline linearly, reaching zero in 2200)

................................... 47 Figure 9.6. Global Non-CO 2 

### Radiative Forcing, 2000–2300 (post-2100 extrapolations

assume constant non-CO 2 

### radiative forcing after 2100)

........................................ 48 Figure 9.7. Global CO 2 

### Intensity (fossil & industrial CO 2 

### emissions/GDP), 2000–2300 (post-2100 extrapolations assume decline in CO 2 

### /GDP growth rate over 2090–2100 is maintained through 2300)

............................................................... 48 Figure 9.8. Histogram of Global SCC Estimates in 2010 (2007$/ton CO 2 

### ), by Discount

Rate*

....................................................................................................................... 50

EA-SCC.ii

### APPENDIX EA-SCC. SOCIAL COST OF CARBON FOR REGULATORY IMPACT

ANALYSIS UNDER EXE CUTIVE ORDER 12866 Interagency Working Gr oup on Social Cost of Carbon , United States Government

With participation by

Council of Economic Advisers Council on Environmental Quality Department of Agriculture Department of Commerce

Department of Energy Department of Transportation Environmental Protection Agency

National Economic Council Office of Energy and Climate Change

Office of Management and Budget Office of Science and Technology Policy Department of the Treasury

EA-SCC.1 EXECUTIVE SUMMARY

Under Executive Order (E.O.) 12866, agencies are required, to the extent permitted by law, “to assess both the costs a nd the benefits of the intended regulation and, recognizing that some costs and benefits are difficult to qua ntify, propose or adopt a regulation only upon a

reasoned determination that the be nefits of the intended regulation justify its costs.” The purpose of the “social cost of carbon” (S CC) estimates presented here is to allow agencies to incorporate the social benefits of reducing carbon dioxide (CO 2 

### ) emissions into cost-benefit analyses of regulatory actions that have small, or “mar ginal,” impacts on cumulative global emissions. The estimates are presented with an acknowledgement of the many uncertainties involved and with a clear understanding that they should be updated ov er time to reflect increasing knowledge of the science and economics of climate impacts.

The SCC is an estimate of the monetized damages associated with an incremental increase in carbon emissions in a given year. Itis intended to include but is not limited to changes in net agricultural productivity, human health, property damages from increased flood risk, and the value of ecosystem services due to climate change.

This document presents a summary of the in teragency process that developed these SCC estimates. Technical experts from numerous agenci es met on a regular basis to consider public comments, explore the technical literature in re levant fields, and disc uss key model inputs and assumptions. The main objective of this process was to develop a range of SCC values using a defensible set of input assump tions grounded in the existing scie ntific and econo mic literatures. In this way, key uncertainties and model differenc es transparently and consistently inform the range of SCC estimates used in the rulemaking process.

EA-SCC.1

### The interagency group selected four SCC valu es for use in regulatory analyses (Table 1.1). Three values are based on the average SCC from three integrated assessment models, at discount rates of 2.5, 3, and 5 percent. The fourth value, which represents the 95 th 

### percentile SCC

estimate across all three models at a 3 percent discount rate, is in cluded to represent higher-thanexpected impacts from temperature change furthe r out in the tails of the SCC distribution.

Table 1.1. Social Cost of CO 2 

### , 2010–2050 (2007$)

Year Discount Rate

%

5 3 2.5 3 Avg Avg Avg 95th

2010 4.7 21.4 35.1 64.9

2015 5.7 23.8 38.4 72.8

2020 6.8 26.3 41.7 80.7

2025 8.2 29.6 45.9 90.4

2030 9.7 32.8 50.0 100.0

2035 11.2 36.0 54.2 109.7

2040 12.7 39.2 58.4 119.3

2045 14.2 42.1 61.7 127.8

2050 15.7 44.9 65.0 136.2



### EA-SCC.2 MONETIZING CARBON DIOXIDE EMISSIONS

The “social cost of carbon” (SCC) is an estimate of the monetized damages associated

with an incremental increase in carbon emissions in a given year. It is intended to include but is not limited to changes in net agricultural productivity, human health, property damages from increased flood risk, and the value of ecosystem se rvices. We report estimates of the social cost of carbon in dollars per metric ton of CO 2 

### throughout this document. a



### When attempting to assess the incremental economic impacts of CO 2 

### emissions, the analyst faces a number of serious challenges. A recent report from the National Academies of Science (NRC 2009) points out that any assessm ent will suffer from uncertainty, speculation, and lack of information about (1) future emissi ons of greenhouse gases; (2) the effects of past and future emissions on the climate system; (3) the impact of changes in climate on the physical and biological environment; and (4) the tran slation of these environmental impacts into economic damages. As a result, any effort to quantify and monetize the harms associated with climate change will raise serious questions of science, economic s, and ethics and should be viewed as provisional.

Despite the serious limits of both quantifica tion and monetization, SCC estimates can be useful in estimating the social benefits of reducing CO 2 

### emissions. Under E.O. 12866, agencies are required, to the extent permitted by law, “to assess both the costs and the benefits of the intended regulation and, recognizing that some costs and benefits are difficult to quantify, propose or adopt a regulation only upon a reasoned determination that th e benefits of the

a In this document, we present all values of the SCC as the cost per metric ton of CO 2 emissions. Alternatively, one could report the SCC as the cost per metric ton of carbon emissions. The multiplier for translating between mass of

CO 2 and the mass of carbon is 3.67 (the molecular weight of CO 2 divided by the molecular weight of carbon = 44/12 = 3.67).

EA-SCC.2

### intended regulation justify its costs.” The purpose of the SCC estimates presented here is to make it possible for agencies to incorporate the social benefits from reducing CO 2 

### emissions into costbenefit analyses of regulatory actions that have small or “marginal” impacts on cumulative global emissions. Most Federal re gulatory actions can be expected to have marginal impacts on global emissions.

For such policies, the benefits from reduced (or costs from increased) emissions in any future year can be estimated by multiplying the change in emissions in that year by the SCC value appropriate for that year. The net present value of the benefits can then be calculated by multiplying each of these future benefits by an appropriate discount factor and summing across all affected years. This approach assumes that the marginal damages from increased emissions are constant for small departures from the ba seline emissions path, an approximation that is reasonable for policies that have effects on emissions that are small relative to cumulative global

CO 2 

### emissions. For policies that have a large (non-marginal) impact on global cumulative emissions, there is a separate que stion of whether the SCC is an appropriate tool for calculating the benefits of reduced emissions; we do not attempt to answer that question here.

An interagency group convened on a regular ba sis to consider public comments, explore

the technical literature in releva nt fields, and discuss key inputs and assumptions in order to generate SCC estimates. Agencies that actively participated in the interagency process include the Environmental Protection Agency, and the De partments of Agriculture, Commerce, Energy, Transportation, and Treasury. This process was convened by the Council of Economic Advisers and the Office of Management and Budget, with active participation and regular input from the Council on Environmental Quality, National Economic Council, O ffice of Energy and Climate Change, and Office of Science and Technology Polic y. The main objective of this process was to develop a range of SCC values using a defensible set of input assumptions that are grounded in the existing literature. In this way, key uncertainties and model differences can more transparently and consistently inform the range of SCC estimates used in the rulemaking process.

The interagency group selected four SCC estima tes for use in regulatory analyses. For 2010, these estimates are $4.7, $21.4, $35.1, and $64.9 ( 2007$). The first three estimates are based on the average SCC across models and soci o-economic and emissions scenarios at the 5, 3, and 2.5 percent discount rates, resp ectively. The fourth value is included to represent the higherthan-expected impacts from temperature change furt her out in the tails of the SCC distribution. For this purpose, we use the SCC value for the 95 th 

### percentile at a 3 percent discount rate. The central value is the average SCC across models at the 3 percent discount rate. For purposes of capturing the uncertainties involved in regulatory impact analysis, we emphasize the importance and value of considering the full range. These SCC estimates also grow over time. For instance, the central value increases to $24 per ton of CO 2 

### in 2015 and $26 per ton of CO 2 

### in 2020. See Appendix A for the full range of annual SCC estimates from 2010 to 2050.

It is important to emphasize that the in teragency process is committed to updating these

estimates as the science and economic understanding of clima te change and its impacts on society improves over time. Specifically, we have set a preliminary goal of revisiting the SCC values within 2 years or at such time as substa ntially updated models beco me available, and to continue to support research in this area. In th e meantime, we will continue to explore the issues

EA-SCC.3

### raised in this document and consider public co mments as part of the ongoing interagency

process.

EA-SCC.3 SOCIAL COST OF CARBON VALUES USED IN PAST

REGULATORY ANALYSES

To date, economic analyses for Federal regula tions have used a wide range of values to estimate the benefits associated with reducing CO 2 

### emissions. In the final model year 2011 CAFE rule, the Department of Transportation (DOT) used bot h a “domestic” SCC value of $2 per ton of CO 2 

### and a “global” SCC va lue of $33 per ton of CO 2 

### for 2007 emission reductions (2007$), increasing both values at 2.4 percent per y ear. It also included a sensitivity analysis at $80 per ton of CO 2 

### . A domestic SCC value is meant to reflect the value of damages in the United States resulting from a unit change in CO 2 

### emissions, while a global SCC value is meant to reflect the value of damages worldwide.

A 2008 regulation proposed by DOT assumed a domestic SCC value of $7 per ton CO 2 

### (in 2006 dollars) for 2011 emission reductions (with a range of $0-$14 for sensitivity analysis), also increasing at 2.4 percent per year. A regulation finalized by DOE in October of 2008 used a domestic SCC range of $0 to $20 per ton CO 2 

### for 2007 emission reductions (2007$). In addition, EPA’s 2008 Advance Notice of Proposed Rulemaking for Greenhouse Gases identified what it described as “very preliminary” SCC estimates subject to revi sion. EPA’s global mean values were $68 and $40 per ton CO 2 

### for discount rates of approxima tely 2 percent and 3 percent, respectively (2006$ for 2007 emissions).

In 2009, an interagency process was initiate d to offer a preliminary assessment of how best to quantify the benefits from reducing CO 2 

### emissions. To ensure consistency in how benefits are evaluated across agencies, the Administration sought to develop a transparent and defensible method, specifically designed for the rulemaking process, to quantify avoided climate change damages from reduced CO 2 

### emissions. The interagency group did not undertake any original analysis. Instead, it combined SCC estimates from the existing literature to use as interim values until a more comprehe nsive analysis could be conducted.

The outcome of the preliminary assessment by the interagency group was a set of five interim values: global SCC estimates for 2007 (in 2006 dollars) of $55, $33, $19, $10, and $5 per

ton of CO 2. 

### The $33 and $5 values represented model- weighted means of the published estimates produced from the most recently available versions of three integrated assessment models— DICE, PAGE, and FUND—at appr oximately 3 and 5 percent discount rates. The $55 and $10 values were derived by adjusting the published estimates for uncertainty in the discount rate (using factors developed by Newell and Pizer (2003)) at 3 and 5 percent discount rates, respectively. The $19 value was chosen as a central value between the $5 and $33 per ton estimates. All of these values were assumed to increase at 3 percent annually to represent growth in incremental damages over time as the magnitude of climate change increases.

These interim values represent the first sustained interagency effort within the U.S. government to develop an SCC for use in regulatory analysis. The results of this preliminary effort were presented in several proposed and fi nal rules and were offere d for public comment in

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### connection with proposed rules, including the joint EPA-DOT fuel economy and CO 2 

### tailpipe emission proposed rules.

EA-SCC.4 APPROACH AND KEY ASSUMPTIONS

Since the release of the interim values, interagency group has reconvened on a regular basis to generate improved SCC estimates. Specifically, th e group has considered public comments and further explored the technical literature in relevant fields. This section details the several choices and assumpti ons that underlie the resultin g estimates of the SCC.

It is important to recognize that a number of key uncertainties remain, and that current SCC estimates should be treated as provisional and revisable since they will evolve with improved scientific and economic understanding. The interage ncy group also recognizes that the existing models are imperfect and incomplete. The National Academy of Science (2009) points out that there is tension between the goal of producing quantified estimates of the economic damages from an incremental ton of carbon and the limits of existing efforts to model these effects. Throughout this document, we highlight a number of concerns and problems that should be addressed by the research community, including research programs housed in many of the agencies participating in the interagency process to estimate the SCC.

The U.S. Government will periodically review and reconsider estimates of the SCC used for cost-benefit analyses to reflect increasing knowledge of the science and economics of climate impacts, as well as improvements in modeling. In this context, statements recognizing the limitations of the analysis and calling for further research take on exceptional significance. The interagency group offers the new SCC values with all due humility a bout the uncertainties embedded in them and with a sincere pro mise to continue work to improve them.

EA-SCC.4.1 Integrated Assess ment Models

We rely on three integrated assessment models (IAMs) commonly used to estimate the SCC: the FUND, DICE, and PAGE models. b 

### These models are frequently cited in the peerreviewed literature and used in the IPCC assessment. Each model is given equal weight in the SCC values developed through this process, bearing in mind their different limitations (discussed below).

These models are useful because they combine climate processes, economic growth, and feedbacks between the climate and the global economy into a single modeling framework. At the same time, they gain this advantage at the expense of a more detailed representation of the underlying climatic and economic systems. DICE, PAGE, and FUND all take stylized, reducedform approaches (see NRC 2009 for a more de tailed discussion; see Nordhaus 2008 on the

b The DICE (Dynamic Integrated Climate and Economy) model by William Nordhaus evolved from a series of energy models and was first presented in 1990 (Nordhaus and Boyer 2000, Nordhaus 2008). The PAGE (PolicyAnalysis of the Greenhouse Effect) model was developed by Chris Hope in 1991 for use by European decisionmakers in assessing the marginal impact of carbon emissions (Hope 2006, Hope 2008). The FUND (Climate Framework for Uncertainty, Negotiation, and Distribution) model, developed by Richard Tol in the early 1990s, originally to study international capital transfers in climate policy. is now widely used to study climate impacts ( e.g. , Tol 2002a, Tol 2002b, Anthoff et al. 2009, Tol 2009).

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### possible advantages of this approach). Other IAMs may better reflect the complexity of the science in their modeling frameworks but do not link physical impacts to economic damages. There is currently a limited amount of research linking climate impacts to economic damages, which makes this exercise even more difficult. Underlying the three IAMs selected for this exercise are a number of simplifying assumptions and judgments reflecting the various modelers’ best attempts to synthesize the available scientific and economic research characterizing these relationships.

The three IAMs translate emissions in to changes in atmospheric greenhouse concentrations, atmospheric conc entrations into changes in temperature, and changes in temperature into economic damages. The emissions projections used in the models are based on specified socio-economic (GDP and population) pa thways. These emissions are translated into concentrations using the carbon cycle built into ea ch model, and concentrations are translated into warming based on each model’s simplified representation of the climate and a key parameter, climate sensitivity. Each model uses a different approach to translate warming into damages. Finally, transforming the stream of economic damages over time into a single value requires judgments about how to discount them.

Each model takes a slightly different approa ch to model how changes in emissions result in changes in economic damages. In PAGE, for example, the consumpti on-equivalent damages in each period are calculated as a fraction of GDP, depending on the temperature in that period relative to the pre-industrial average temperat ure in each region. In FUND, damages in each period also depend on the rate of temperatur e change from the prior period. In DICE, temperature affects both consumption and investme nt. We describe each model in greater detail here. In a later section, we discuss key gaps in how the models account for various scientific and economic processes ( e.g. , the probability of catastrophe, and the ability to adapt to climate change and the physical changes it causes).

The parameters and assump tions embedded in the three models vary widely. A key objective of the interagency process was to enable a consistent exploration of the three models while respecting the different approaches to quant ifying damages taken by the key modelers in

the field. An extensive review of the literature was conducted to select three sets of input parameters for these models: c limate sensitivity, soci o-economic and emissions trajectories, and discount rates. A probability distri bution for climate sensitivity was sp ecified as an input into all three models. In addition, the interagency group us ed a range of scenarios for the socio-economic parameters and a range of values for the disc ount rate. All other mode l features were left unchanged, relying on the model developers’ best estimates and judgments. In DICE, these parameters are handled deterministically and re presented by fixed constants; in PAGE, most parameters are represented by probability distri butions. FUND was also run in a mode in which parameters were treated probabilistically.

The sensitivity of the results to other aspects of the models ( e.g. , the carbon cycle or damage function) is also important to explore in the context of future revisions to the SCC but has not been incorporated into these estimates. Areas for future research are highlighted at the

end of this document.

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### EA-SCC.4.1.1 The DICE Model

The DICE model is an optimal growth m odel based on a global pr oduction function with an extra stock variable (atmospheric CO 2 

### concentrations). Emission reductions are treated as analogous to investment in “natural capital.” By investing in natural capital today through reductions in emissions—implying reduced consum ption—harmful effects of climate change can

be avoided and future consum ption thereby increased.

For purposes of estimating the SCC, CO 2 

### emissions are a function of global GDP and the carbon intensity of economic output, with the latte r declining over time due to technological progress. The DICE damage f unction links global average temp erature to the overall impact on the world economy. It varies quadratically with temperature change to capture the more rapid increase in damages expected to occur under more extreme climate change, and is calibrated to include the effects of warming on the production of market and nonmarket goods and services. It incorporates impacts on agriculture, coastal areas (due to sea level rise), “other vulnerablemarket sectors” (based primarily on changes in energy use), human health (based on climaterelated diseases, such as mala ria and dengue fever, and pollu tion), non-market amenities (based on outdoor recreation), and human settlements and ecosystems. The DICE damage function also includes the expected value of damages associated with low probability, high impact “catastrophic” climate change. This last component is calibrated based on a survey of experts (Nordhaus 1994). The expected value of these impact s is then added to the other market and nonmarket impacts mentioned above.

No structural components of the DICE mode l represent adaptation explicitly, though it is included implicitly through the choice of studies us ed to calibrate the aggregate damage function. For example, its agricultural impact estimates assume that farmers can adjust land use decisions in response to changing climate conditions , and its health imp act estimates assume improvements in healthcare over time. In addition, the small impacts on forestry, water systems, construction, fisheries, and out door recreation imply optimistic a nd costless adaptation in these sectors (Nordhaus and Boyer, 2000; Warren et al ., 2006). Costs of resettleme nt due to sea level rise are incorporated into damage estimates, but their magnitude is not clearly reported. Mastrandrea’s (2009) review c oncludes that “in general, DI CE assumes very effective adaptation, and largely ignores adaptation costs.”

Note that the damage function in DICE has a somewhat different meaning from the damage functions in FUND and PAGE. Becaus e GDP is endogenous in DICE and because damages in a given year reduce investment in that year, damages propagate forward in time and reduce GDP in future years. In contrast, GDP is exogenous in FUND and PAGE, so damages in any given year do not propagate forward. c

c Using the default assumptions in DICE 2007, this effect generates an approximately 25 percent increase in the SCC relative to damages calculated by fixing GDP. In DICE2007, the time path of GDP is endogenous. Specifically, the path of GDP depends on the rate of saving and level of abatement in each period chosen by the optimizing representative agent in the model. We made two modifications to DICE to make it consistent with EMF GDP trajectories (see next section): we assumed a fixed rate of savings of 20%, and we re-calibrated the exogenous path of total factor productivity so that DICE would produce GDP projections in the absence of warming that exactly matched the EMF scenarios.

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### EA-SCC.4.1.2 The PAGE Model

PAGE2002 (version 1.4epm) treats GDP growth as exogenous. It divides impacts into economic, non-economic, and catastrophic categories a nd calculates these impacts separately for eight geographic regions. Damages in each regi on are expressed as a fraction of output, where the fraction lost depends on the temperature ch ange in each region. Damages are expressed as power functions of temperature change. The expone nts of the damage function are the same in all regions but are treated as uncertain, with values ranging from 1 to 3 (instead of being fixed at 2 as in DICE).

PAGE2002 includes the consequences of catast rophic events in a separate damage subfunction. Unlike DICE, PAGE2002 models these events probabilistically. The probability of a “discontinuity” ( i.e. , a catastrophic event) is assumed to increase with temperature above a specified threshold. The threshold temperature, th e rate at which the probability of experiencing a discontinuity increases above the threshold, a nd the magnitude of the resulting catastrophe are all modeled probabilistically.

Adaptation is explicitly included in PAGE. Impacts are assumed to occur for temperature increases above some tolerable level (2 °C fo r developed countries and 0 °C for developing countries for economic impacts, and 0 °C fo r all regions for non-economic impacts), but adaptation is assumed to reduce these impacts. Default values in PAGE2002 assume that the developed countries can ultimate ly eliminate up to 90 percent of all economic impacts beyond the tolerable 2 °C increase and that developing countries can eventually eliminate 50 percent of their economic impacts. All regions are assumed to be able to mitigate 25 percent of the noneconomic impacts through adaptation (Hope 2006).

EA-SCC.4.1.3 The FUND Model

Like PAGE, the FUND model treats GDP growth as exogenous. It includes separately calibrated damage functions for eight market and nonmarket sectors: agricu lture, forestry, water, energy (based on heating and cooling demand), sea level rise (based on the value of land lost and the cost of protection), ecosystems, human he alth (diarrhea, vector-borne diseases, and cardiovascular and respiratory mortality), and extreme weather. Each impact sector has a different functional form, and is calculated separately for sixteen geographic regions. In some impact sectors, the fraction of output lost or gained due to climate change depends not only on the absolute temperature change but also on the rate of temperature change and level of regional

income. d 

### In the forestry and agricultural sect ors, economic damages also depend on CO 2 

### concentrations.

Tol (2009) discusses impacts not included in FU ND, noting that many are likely to have a relatively small effect on damage estimates (both positive and negative). However, he characterizes several omitted impacts as “big unknowns:” for instance, extreme climate scenarios, biodiversity loss, and effects on ec onomic development and political violence. With

d In the deterministic version of FUND, the majority of damages are attributable to increased air conditioning demand, while reduced cold stress in Europe, North America, and Central and East Asia results in health benefits in those regions at low to moderate levels of warming (Warren et al . 2006).

EA-SCC.8

### regard to potentially catastrophic events, he not es, “Exactly what would cause these sorts of changes or what effects they would have are not well-understood, although the chance of any one of them happening seems low. But they do have the potential to happen relatively quickly, and if they did, the costs could be substantial. Only a few studies of climate change have examined

these issues.”

Adaptation is included both implicitly and explicitly in FUND. Explicit adaptation is seen in the agriculture and sea level rise sectors. Implicit adaptation is included in sectors such as energy and human health, where wealthier popula tions are assumed to be less vulnerable to climate impacts. For example, the damages to agriculture are the sum of three effects: (1) those due to the rate of temperature change (damages are always positive); (2) those due to the level of temperature change (damages can be positive or negative depending on region and temperature); and (3) those from CO 2 

### fertilization (damages are generally negative but diminishing to zero).

Adaptation is incorporated into FUND by a llowing damages to be smaller if climate change happens more slowly. The combined effect of CO 2 

### fertilization in the agricultural sector, positive impacts to some regions from higher temperatures, and sufficiently slow increases in temperature across these sectors can result in negative economic damages from climate change.

EA-SCC.4.1.4 Damage Functions

To generate revised SCC values, we rely on the IAM modelers’ current best judgments of how to represent the effects of climate change (represented by the increase in global-average surface temperature) on the cons umption-equivalent value of bot h market and non-market goods (represented as a fraction of global GDP). We recognize that these representations are incomplete and highly uncertai n. Given the paucity of data linking the physical impacts to economic damages, we were not able to identify a better way to translate changes in climate into net economic damages, s hort of launching our ow n research program.

The damage functions for the three IAMs are pres ented in Figure 4.1 and Figure 4.2, using the

modeler’s default scenarios and mean input a ssumptions. There are significant differences between the three models both at lower (Figure 4.1) and higher (Figure 4.2) increases in globalaverage temperature.

EA-SCC.9

### Figure 4.1. Annual Consumption Loss as a Frac tion of Global GDP in 2100 Due to an Increase in Annual Global Temperature in the DICE, FUND, and PAGE Models e



### Figure 4.2. Annual Consumption Loss for Lower Temperature Changes in DICE, FUND,

and PAGE

e The x-axis represents increases in annual, rather than equilibrium, temperature, while the y-axis represents theannual stream of benefits as a share of global GDP. Each specific combination of climate sensitivity, socioeconomic, and emissions parameters will produce a differe nt realization of damages for each IAM. The damage functions represented in Figure 4.1 and Figure 4.2 are the outcome of default assumptions. For instance, under alternate assumptions, the damages from FUND may cross from negative to positive at less than or greater than 3

°C.

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### The lack of agreement among the models at lower temperature increases is underscored by the fact that the damages from FUND are well below the 5 th 

### percentile estimated by PAGE, while the damages estimated by DICE are roughly equal to the 95 th 

### percentile estimated by PAGE. This is significant because at higher disc ount rates we expect that a greater proportion of the SCC value is due to damages in years with lower temperature increases. For example, when the discount rate is 2.5 percent, about 45 perc ent of the 2010 SCC value in DICE is due to damages that occur in years when the temperature is less than or equal to 3 °C. This increases to approximately 55 percent and 80 pe rcent at discount rates of 3 and 5 percent, respectively.

These differences underscore the need for a thorough review of damage functions—in particular, how the models incorporate adap tation, technological change, and catastrophic damages. Gaps in the literature make modifying these aspects of the models challenging, which highlights the need for additional research. As knowledge improves, the Federal government is committed to exploring how these (and other) models can be modified to incorporate more accurate estimates of damages.

EA-SCC.4.2 Global versus Domest ic Measures of SCC

Because of the distinctive nature of the climate change problem, we center our current attention on a global measure of SCC. This approach is the same as that taken for the interim values, but it otherwise represents a departure from past practices, which tended to put greater emphasis on a domestic measure of SCC (limited to impacts of climate change experienced within U.S. borders). As a matter of law, cons ideration of both global and domestic values is generally permissible; the relevant statutor y provisions are usually ambiguous and allow

selection of either measure. f



### EA-SCC.4.2.1 Global SCC

Under current OMB guidance contained in Circular A-4, analysis of economically significant proposed and final regulations fro m the domestic perspective is required, while analysis from the international perspective is optional. However, the climate change problem is highly unusual in at least two respects. First, it involves a global externality: emissions of most greenhouse gases contribute to damages around the world even when they are emitted in the United States. Consequently, to address the global nature of the problem, the SCC must incorporate the full (global) damages cause d by GHG emissions. Second, climate change presents a problem that the Unite d States alone cannot solve. Even if the United States were to reduce its greenhouse gas emissions to zero, th at step would be far from enough to avoid substantial climate change . Other countries would also need to take action to reduce emissions if significant changes in the global climate are to be avoided. Emphasizing the need for a global solution to a global problem, the United Stat es has been actively involved in seeking international agreements to reduce emissions and in encouraging other nations, including emerging major economies, to take significant steps to reduce emissions. When these

f It is true that Federal statutes are presumed not to have extraterritorial effect, in part to ensure that the laws of the United States respect the interests of foreign sovereigns. But use of a global measure for the SCC does not give

extraterritorial effect to federal law and hence does not intrude on such interests.

EA-SCC.11

### considerations are taken as a whole, the intera gency group concluded that a global measure of the benefits from reducing U.S. emissions is preferable.

When quantifying the damages associated with a change in emissions, a number of analysts ( e.g. , Anthoff et al . 2009a) employ “equity weighting” to aggregate changes in consumption across regions. This weighting take s into account the relative reductions in wealth in different regions of the world. A per-capita loss of $500 in GDP, for instance, is weighted more heavily in a country with a per-capita GDP of $2,000 than in one with a per-capita GDP of $40,000. The main argument for this approach is that a loss of $500 in a poor country causes a greater reduction in utility or welfare than does the same loss in a wealthy nation. Notwithstanding the theoretical claims on behalf of equity weighting, the interagency group concluded that this approach would not be appropriate for estimating a SCC value used in domestic regulatory analysis. g 

### For this reason, the group concluded that using the global (rather than domestic) value, without equity we ighting, is the appropriate approach.

EA-SCC.4.2.2 Domestic SCC

As an empirical matter, the development of a domestic SCC is greatly complicated by the relatively few region- or country-specific estima tes of the SCC in the literature. One potential source of estimates comes from the FUND model. The resulting estimates suggest that the ratio of domestic to global benefits of emission reductions varies with key parameter assumptions. For example, with a 2.5 or 3 percent discount rate, the U.S. benefit is about 7–10 percent of the global benefit, on average, across the scenarios analyzed. Alternatively, if the fraction of GDP lost due to climate change is assumed to be similar across countri es, the domestic benefit would be proportional to the U.S. share of globa l GDP, which is currently about 23 percent. h



### On the basis of this evidence, the interagency workgroup determined that a range of values from 7 to 23 percent should be used to adjust the global SCC to calculate domestic effects. Reported domestic values should use this ra nge. It is recognized that these values are approximate, provisional, and highly speculative. There is no a priori reason why domestic

benefits should be a constant fraction of net global damages over time. Further, FUND does not account for how damages in other regions could affect the United States ( e.g. , global migration, economic and political destabilization). If more accurate methods for calculating the domestic SCC become available, the Federal government will examine these to determine whether to update its approach.

EA-SCC.4.3 Valuing Non-CO 2 

### Emissions

While CO 2 

### is the most prevalent greenhouse gas emitted into the atmosphere, the U.S. included five other greenhouse gases in its recent endangerment finding: methane, nitrous oxide,

g It is plausible that a loss of $X inflicts more serious harm on a poor nation than on a wealthy one, but development of the appropriate “equity weight” is challenging. Emissions reductions also impose costs, and hence a full account would have to consider that a given cost of emissions re ductions imposes a greater utility or welfare loss on a poor nation than on a wealthy one. Even if equity weighting—for both the costs and benefits of emissions reductions—is appropriate when considering the utility or welfare effects of international action, the interagency group concluded that it should not be used in developing an SCC for use in regulatory policy at this time.

h Based on 2008 GDP (in current US dollars) from the World Bank Development Indicators Report

.

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### hydrofluorocarbons, perfluorocarbons , and sulfur hexafluoride. The climate impact of these gases is commonly discussed in terms of thei r 100-year global warming potential (GWP). GWP measures the ability of different gases to trap heat in the atmosphere ( i.e. , radiative forcing per unit of mass) over a particular timeframe relative to CO 2 

### . However, because these gases differ in both radiative forcing and atmospheric lifetimes, their relative damages are not constant over time. For example, because methane has a short lifetime, its impacts occur primarily in the near term and thus are not discounted as heavily as t hose caused by longer-lived gases. Impacts other than temperature change also vary across gases in ways that are not captured by GWP. For instance, CO 2 

### emissions, unlike methane and other greenhouse gases, contribute to ocean acidification. Likewise, damages from methane emissi ons are not offset by the positive effect of

CO 2 

### fertilization. Thus, tran sforming gases into CO 2 

### -equivalents using GWP, and then multiplying the carbon-equivalents by the SCC, would not result in accurate estimates of the

social costs of non-CO 2 

### gases.

In light of these limitations, and th e significant contributions of non-CO 2 

### emissions to climate change, further research is required to link non-CO 2 

### emissions to economic impacts.

Such work would feed into efforts to deve lop a monetized value of reductions in non-CO 2 

### greenhouse gas emissions. As part of ongoing wo rk to further improve the SCC estimates, the interagency group hopes to devel op methods to value these othe r greenhouse gases. The goal is to develop these estimates by the time we issue revised SCC estimates for CO 2 

### emissions.

EA-SCC.4.4 Equilibrium Climate Sensitivity

Equilibrium climate sensitivity (ECS) is a key input parameter for the DICE, PAGE, and

FUND models. i 

### It is defined as the long-term increase in the annual global-average surface temperature from a doubling of atmospheric CO 2 

### concentration relative to pre-industrial levels (or stabilization at a concentration of approx imately 550 parts per million (ppm)). Uncertainties in this important parameter have received substantial attention in the peer-reviewed literature.

The most authoritative statement about equ ilibrium climate sensitivity appears in the Fourth Assessment Report of the Intergovernmental Panel on Climate Change (IPCC):

Basing our assessment on a combination of seve ral independent lines of evidence...including observed climate change and th e strength of known feedbacks simulated in [g lobal climate models], we conclude that the global mean equilibrium warming for doubling CO 2 

### , or ‘equilibrium climate sensitivity,’ is likely to lie in the range 2 °C to 4.5 °C, with a most likely value of about 3 °C. Equilibri um climate sensitivity is very likely larger than 1.5 °C. j



### For fundamental physical reasons as well as data limitations, values substantially higher than

4.5 °C still cannot be excluded, but agreement with observations and prox y data is generally

i The equilibrium climate sensitivity includes the response of the climate system to increased greenhouse gas concentrations over the short to medium term (up to 100–200 years), but it does not include long-term feedback effects due to possible large-scale changes in ice sheets or the biosphere, which occur on a time scale of many hundreds to thousands of years ( e.g. , Hansen et al . 2007).

j This is in accord with the judgment that it “is likely to lie in the range 2 °C to 4.5 °C” and the IPCC definition of “likely” as greater than 66 percent probability (Le Treut et al . 2007). “Very likely” indicates a greater than 90 percent probability.

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### worse for those high values than for valu es in the 2 °C to 4.5 °C range. (Meehl et al . 2007, p. 799)

After consulting with several lead authors of this chapter of the IPCC report, the interagency workgroup selected four candidate pr obability distributions and calibrated them to

be consistent with the above statement: Roe a nd Baker (2007), log-normal, gamma, and Weibull. Table 4.1 gives summary statistics for the four calibrated distributions.

Table 4.1. Summary Statistics for Four Calib rated Climate Sensit ivity Distributions

Rank Roe & Baker Log-Normal Gamma Weibull Pr(ECS < 1.5 °C) 0.013 0.050 0.070 0.102 Pr(2 °C < ECS < 4.5 °C) 0.667 0.667 0.667 0.667

5 t h Percentile 1.72 1.49 1.37 1.13

10 t h Percentile 1.91 1.74 1.65 1.48

Mode 2.34 2.52 2.65 2.90 Median (50 t h percentile) 3.00 3.00 3.00 3.00

Mean 3.50 3.28 3.19 3.07

90 t h Percentile 5.86 5.14 4.93 4.69

95 t h Percentile 7.14 5.97 5.59 5.17



### Each distribution was calibrated by appl ying three constraints from the IPCC:

(1) a median equal to 3 °C, to reflect the judg ment of “a most likely value of about 3 °C;” k


### (2) two-thirds probability that the equilibrium climate sensitiv ity lies between 2 and 4.5 °C;

and (3) zero probability that it is less than 0 °C or greater than 10 °C (Hegerl et al. 2006, p. 721).

We selected the calibrated Roe and Baker distribution from the four candidates for two reasons. First, the Roe and Baker distribution is the only one of the four that is based on a theoretical understanding of the response of th e climate system to increased greenhouse gas concentrations (Roe and Baker 2007; Roe 2008). In contrast, the other th ree distributions are mathematical functions that are arbitrarily chos en based on simplicity, c onvenience, and general shape. The Roe and Baker distribution results fro m three assumptions about climate response: (1) absent feedback effects, the equilibrium climate sensitivity is equal to 1.2 °C; (2) feedback factors are proportional to the change in surface temperature; and (3) uncertainties in feedback factors are normally distributed. There is widespread agreement on the first point and the second and third points are common assumptions.

k Strictly speaking, “most likely” refers to the mode of a distribution rather than the median, but common usage would allow the mode, median, or mean to serve as candidates for the central or “most likely” value and the IPCC report is not specific on this point. For the distributions we considered, the median was between the mode and the mean. For the Roe and Baker distribution, setting the median equal to 3 °C, rather than the mode or mean, gave a

95 th percentile that is more consistent with IPCC judgments and the literature. For example, setting the mean and mode equal to 3 °C produced 95 th percentiles of 5.6 and 8.6 °C, respectively, which are in the lower and upper end of the range in the literature. Finally, the median is closer to 3 °C than is the mode for the truncated distributions selected by the IPCC (Hegerl et al . 2006); the average median is 3.1 °C and the average mode is 2.3 °C, which is most consistent with a Roe and Baker distribution with the median set equal to 3 °C.

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### Second, the calibrated Roe and Baker distribu tion better reflects the IPCC judgment that “values substantially higher than 4.5°C still ca nnot be excluded.” Although the IPCC made no quantitative judgment, the 95 th 

### percentile of the calibrated Roe & Baker distribution (7.1 °C) is much closer to the mean and the median (7.2 °C) of the 95 th 

### percentiles of 21 previous studies summarized by Newbold and Daigneault (2009). It is also closer to the mean (7.5 °C) and median (7.9 °C) of the nine truncated di stributions examined by the IPCC (Hegerl et al . 2006)

than are the 95 th 

### percentiles of the three other ca librated distributions (5.2–6.0 °C).

Finally, we note the IPCC judgment that the equilibrium climate sensitivity “is very likely larger than 1.5°C.” Although the calibrated Roe & Baker distribution, for which the probability of equilibrium climate sensitivity being greater than 1.5 °C is almost 99 percent, is

not inconsistent with the IPCC definition of “very likely” as “greater than 90 percent probability,” it reflects a greater degree of certain ty about very low values of ECS than was expressed by the IPCC.

To show how the calibrated Roe and Baker distribution compares to different estimates of the probability distribution function of equilibrium climate sensitivity in the empirical literature, Figure 4.3 overlays it on Figure 9.20 fro m the IPCC Fourth Assessment Report. These functions are scaled to integrate to unity betw een 0 °C and 10 °C. The horizontal bars show the respective 5 percent to 95 percent ranges; dots indicate the median estimate. l

Calibrated

Roe & Baker



### Figure 4.3. Estimates of the Probability Dens ity Function for Equilibrium Climate Sensitivity

l The estimates based on instrumental data are from Andronova and Schlesinger (2001), Forest et al. (2002; dashed line, anthropogenic forcings only), Forest et al . (2006; solid line, anthropogenic and natural forcings), Gregory et al

. (2002), Knutti et al . (2002), Frame et al . (2005), and Forster and Gregory (2006). Hegerl et al . (2006) are based on multiple palaeoclimatic reconstructions of north hemisphere mean temperatures over the last 700 years. Also shown are the 5–95 percent approximate ranges for two estimates from the last glacial maximum (dashed, Annan et al

. 2005; solid, Schneider von Deimling et al . 2006), which are based on models with different structural properties.

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### EA-SCC.4.5 Socio-Economic and Emissions Trajectories

Another key issue considered by the interage ncy group is how to select the set of socioeconomic and emissions parameters for use in PAGE, DICE, and FUND. Socio-economic pathways are closely tied to climate damages because, all else equal, more and wealthier people tend to emit more greenhouse gases and also have a higher (absolute) willingness to pay to avoid climate disruptions. For this r eason, we consider how to model several input pa rameters in tandem: GDP, population, CO 2 

### emissions, and non-CO 2 

### radiative forcing. A wide variety of scenarios have been developed and used for climate change policy simulations ( e.g. , SRES 2000, CCSP 2007, EMF 2009). In determining which scenario s are appropriate for inclusion, we aimed to select scenarios that span most of the plausible ranges of outcomes for these variables.

To accomplish this task in a transparent way, we decided to rely on the recent Stanford Energy Modeling Forum exercise, EMF-22, which us es ten well-recognized models to evaluate substantial, coordinated global action to meet specific stabilization targets. A key advantage of relying on these data is that GDP, population, and emission trajectories are internally consistent

for each model and scenario evaluated. The EMF- 22 modeling effort also is preferable to the IPCC SRES due to their age (SRES were developed in 1997) and the fact that 3 of 4 of the SRES scenarios are now extreme outliers in one or more variables. Although the EMF-22 scenarios have not undergone the same leve l of scrutiny as the SRES scenarios, they are recent, peerreviewed, published, and publicly available.

To estimate the SCC for use in evaluating domestic policies that will have a small effect on global cumulative emissions, we use socio-economic and emission trajectories that span a range of plausible scenarios. Fi ve trajectories were selected from EMF-22 (Table 4.2). Four of these represent potential business-as-usual (BAU ) growth in population, wealth, and emissions

and are associated with CO 2 

### (only) concentrations ranging from 612 to 889 ppm in 2100. One represents an emissions pathway that achieves stabilization at 550 ppm CO 2 

### e ( i.e. , CO 2 

### -only concentrations of 425–484 ppm or a radiative forcing of 3.7 W/m 2 

### ) in 2100, a lower-than-BAU trajectory. m 

### Out of the 10 models included in the EMF- 22 exercise, we selected the trajectories used by MiniCAM, MESSAGE, IMAGE, and the optimistic scenario from MERGE. For the BAU pathways, we used the GDP, population, and emission trajectories from each of these four models. For the 550 ppm CO 2 

### e scenario, we averaged th e GDP, population, and emission trajectories implied by these same four models.

Table 4.2. Socioeconomic and Emissions Projections from Select EMF-22 Reference

Scenarios

Reference Fossil and Industrial CO 2 Emissions

GtCO 2 /yr

EMF – 22 Based Scenarios 2000 2010 2020 2030 2050 2100

IMAGE 26.6 31.9 36.9 40.0 45.3 60.1 MERGE Optimistic 24.6 31.5 37.6 45.1 66.5 117.9

MESSAGE 26.8 29.2 37.6 42.1 43.5 42.7

MiniCAM 26.5 31.8 38.0 45.1 57.8 80.5

m

Such an emissions path would be consistent with widespread action by countries to mitigate GHG emissions, though it could also result from technological advances. It was chosen because it represents the most stringent case analyzed by the EMF-22 where all the models converge: a 550 ppm, not to exceed, full participation scenario.

EA-SCC.16550 ppm average 26.2 31.1 33.2 32.4 20.0 12.8

Reference GDP market exchange rates in trillion 2005$ n

EMF – 22 Based Scenarios 2000 2010 2020 2030 2050 2100

IMAGE 38.6 53.0 73.5 97.2 156.3 396.6 MERGE Optimistic 36.3 45.9 59.7 76.8 122.7 268.0

MESSAGE 38.1 52.3 69.4 91.4 153.7 334.9

MiniCAM 36.1 47.4 60.8 78.9 125.7 369.5 550 ppm average 37.1 49.6 65.6 85.5 137.4 337.9 Global Population

billions

EMF – 22 Based Scenarios 2000 2010 2020 2030 2050 2100

IMAGE 6.1 6.9 7.6 8.2 9.0 9.1 MERGE Optimistic 6.0 6.8 7.5 8.2 9.0 9.7

MESSAGE 6.1 6.9 7.7 8.4 9.4 10.4

MiniCAM 6.0 6.8 7.5 8.1 8.8 8.7 550 ppm average 6.1 6.8 7.6 8.2 8.7 9.1



### We explore how sensitive the SCC is to va rious assumptions about how the future will evolve without prejudging what is likely to o ccur. The interagency group considered formally assigning probability weights to different states of the world, but this proved challenging to do in an analytically rigorous way given the dearth of information on the likelihood of a full range of future socio-economic pathways.

There are a number of caveats. First, EMF BAU scenarios represent the modelers’ judgment of the most likely pathway abse nt mitigation policies to reduce greenhouse gas emissions, rather than the wider range of possi ble outcomes. Nevertheless, these views of the most likely outcome span a wide range, from the more optimistic ( e.g. , abundant low-cost, lowcarbon energy) to more pessimistic ( e.g. , constraints on the availability of nuclear and renewables). o 

### Second, the socio-economic trajector ies associated with a 550 ppm CO 2 

### e concentration scenario are not derived from an assessment of what policy is optimal from a benefit-cost standpoint. Rather, it is indicative of one po ssible future outcome. The emission trajectories underlying some BAU scenarios ( e.g. , MESSAGE’s 612 ppm) also are consistent

n While the EMF-22 models used market exchange rates (MER) to calculate global GDP, it is also possible to use purchasing power parity (PPP), which takes into account the different price levels across countries, so it more accurately describes relative standards of living across countries. MERs tend to make low-income countries appear poorer than they actually are. Because many models assu me convergence in per capita income over time, use of MER-adjusted GDP gives rise to projections of higher economic growth in low income countries. There is an ongoing debate about how much this will affect estimated climate impacts. Critics of the use of MER argue that it leads to overstated economic growth and hence a signif icant upward bias in projections of greenhouse gas emissions, and unrealistically high future temperatures ( e.g. , Castles and Henderson 2003). Others argue that convergence of the emissions-intensity gap across countries at least partially offset the overstated income gap so that differences in exchange rates have less of an effect on emissions (Holtsmark and Alfsen, 2005; Tol, 2006). Nordhaus (2007b) argues that the ideal appr oach is to use superlative PPP accounts ( i.e. , using cross-sectional PPP measures for relative incomes and outputs and national accounts price and quantity indexes for time-series extrapolations). However, he notes that it important to keep this debate in perspective; it is by no means clear that exchange-rate-conversion issues are as important as uncertainties about population, technological change, or the many geophysical uncertainties.

o For instance, in the MESSAGE model’s reference case total primary energy production from nuclear, biomass, and non-biomass renewables is projected to increase from about 15 percent of total primary energy in 2000 to 54 percent in 2100. In comparison, the MiniCAM reference case shows 10 percent in 2000 and 21 percent in 2100.

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### with some modest policy action to address climate change. p 

### We chose not to include socioeconomic trajectories that achieve even lower GHG concentrations at this time, given the difficulty many models had in converging to meet these targets.

For comparison purposes, the Energy Information Agency in its 2009 Annual Energy

Outlook projected that global CO 2 

### emissions will grow to 30.8, 35.6, and 40.4 gigatons in 2010, 2020, and 2030, respectively, while world GDP is projected to be $51.8, $71.0 and $93.9 trillion (2005$ using market exchange rates) in 2010, 2020, and 2030, respectively. These projections

are consistent with one or more EMF-22 scenarios. Likewise, the United Nations’ 2008 Population Prospect projects population will grow from 6.1 billion people in 2000 to 9.1 billion people in 2050, which is close to the populati on trajectories for the IMAGE, MiniCAM, and

MERGE models.

In addition to fossil and industrial CO 2 

### emissions, each EMF scenario provides projections of methane, nitrous oxide, fl uorinated greenhouse gases, and net land use CO 2 

### emissions out to 2100. These assumptions also are used in the three models while retaining the default radiative forcings due to other factors ( e.g. , aerosols and other gases). See the Appendix for greater detail.

EA-SCC.4.6 Discount Rate

The choice of a discount rate , especially over long periods of time, raises highly contested and exceedingly difficult questions of science, economics, philosophy, and law. Although it is well understood that th e discount rate has a large influence on the current value of future damages, there is no consensus about wh at rates to use in this context. Because CO 2 

### emissions are long-lived, subsequent damages occu r over many years. In calculating the SCC, we first estimate the future damages to agri culture, human health, and other market and nonmarket sectors from an additional unit of CO 2 

### emitted in a particular year in terms of reduced consumption (or consumption equi valents) due to the impacts of elevated temperatures, as represented in each of the three IAMs. Then we discount the stream of future damages to its present value in the year when the additional unit of emissions was released using the selected discount rate, which is intended to reflect society’s marg inal rate of substitution between consumption in different time periods.

For rules with both intra- and intergenerational effects, agencies traditionally employ

constant discount rates of both 3 percent and 7 percent in accordance with OMB Circular A-4. As Circular A-4 acknowledges, however, the c hoice of discount rate for intergenerational problems raises distinctive problems and presents considerable challenges. After reviewing those challenges, Circular A-4 states, “If your rule will have important intergenerational benefits or costs you might consider a further sensitivity analysis using a lower but positive discount rate in addition to calculating net benef its using discount rates of 3 a nd 7 percent.” For the specific purpose of developing the SCC, we adapt and revise that approach here.

p For example, MiniCAM projects if all non-US OECD countries reduce CO 2 emissions to 83 percent below 2005 levels by 2050 (per the G-8 agreement) but all other countries continue along a BAU path CO 2 concentrations in 2100 would drop from 794 ppmv in its reference case to 762 ppmv.

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### Arrow et al. (1996) outlined two main approaches to determine the discount rate for climate change analysis, which they labeled “descriptive” and “prescriptive.” The descriptive approach reflects a positive (non-normative) pe rspective based on observations of people’s

actual choices— e.g. , savings versus consumption decisions over time, and allocations of savings among more and less risky investments. Advocates of this approach generally call for inferring

the discount rate from market rates of return “b ecause of a lack of justification for choosing a social welfare function that is any different than what decision makers [i ndividuals] actually use” (Arrow et al . 1996).

One theoretical foundation for the cost-benefit an alyses in which the social cost of carbon will be used—the Kaldor-Hicks potential-compensation test—also suggests that market rates

should be used to discount future benefits and costs, because it is the market interest rate that would govern the returns potentially set aside today to compensate future individuals for climate damages that they bear ( e.g. , Just et al . 2004). As some have noted, the word “potentially” is an important qualification; there is no assurance that such returns will actually be set aside to provide compensation, and the very idea of co mpensation is difficult to define in the intergenerational context. On the other ha nd, societies provide compensation to future generations through investments in human capita l and the resulting incr ease in knowledge, as well as infrastructure and other physical capital.

The prescriptive approach specifies a social welfare function that formalizes the normative judgments that the decision-maker wants explicitly to incorporate into the policy

evaluation— e.g. , how inter-personal comparisons of utilit y should be made, and how the welfare of future generations should be weighed against that of the present generation. Ramsey (1928), for example, has argued that it is “ethically indefensible” to apply a positive pure rate of time preference to discount values across gene rations, and many agree with this view.

Other concerns also motivate making adju stments to descriptive discount rates. In particular, it has been noted that the preferen ces of future generations with regard to consumption versus environmental amenities may not be the same as those today, making the current market rate on consumption an inappropriate metric by which to discount future climaterelated damages. Others argue that the discount ra te should be below market rates to correct for

market distortions and uncertaintie s or inefficiencies in intergenerational transfers of wealth, which in the Kaldor-Hicks logic are presumed to compensate future generations for damage (a potentially controversial assu mption, as noted above; Arrow et al . 1996, Weitzman 1999).

Further, a legitimate concern about both desc riptive and prescriptive approaches is that they tend to obscure important heterogeneity in the population. Th e utility function that underlies the prescriptive approach assumes a representative agent with perfect foresight and no credit constraints. This is an artificial rendering of th e real world that misses ma ny of the frictions that

characterize individuals’ lives a nd indeed the available descriptive evidence supports this. For instance, many individuals smooth consumption by borrowing with credit cards that have relatively high rates. Some are unable to access traditional credit markets and rely on payday lending operations or other high cost forms of smoothing consumption. Whether one puts greater weight on the prescriptive or descriptive approach, the high interest rates that credit-constrained

EA-SCC.19

### individuals accept suggest that some account should be given to the discount rates revealed by

their behavior.

We draw on both approaches but rely primarily on the descriptive approach to inform the

choice of discount rate. With reco gnition of its limitations, we find th is approach to be the most defensible and transparent give n its consistency with the sta ndard contemporary theoretical foundations of benefit-cost analys is and with the approach required by OMB’s existing guidance. The logic of this framework also suggests that ma rket rates should be used for discounting future consumption-equivalent damages. Regardless of the theoretic al approach used to derive the appropriate discount rate(s), we note the inherent conceptual and practical difficulties of adequately capturing consumption trade-offs over many decades or even centuries. While relying primarily on the descriptive approach in selec ting specific discount rates, the interagency group has been keenly aware of the deeply normative dimensions of both the debate over discounting in the intergenerational context and the consequen ces of selecting one disc ount rate over another.

EA-SCC.4.6.1 Historically Observed Interest Rates

In a market with no distortions, the return to savings would equal the private return on investment, and the market rate of interest would be the appr opriate choice for the social discount rate. In the real world risk, taxes, and other market imperfections drive a wedge between the risk-free rate of return on capital a nd the consumption rate of interest. Thus, the literature recognizes two conceptual discount conc epts—the consumption rate of interest and the opportunity cost of capital.

According to OMB’s Circular A-4, it is appropriate to use the rate of return on capital when a regulation is expected to displace or alter the use of capital in the private sector. In this case, OMB recommends Agencies use a discount rate of 7 percent. When regulation is expected to primarily affect private consumption—for inst ance, via higher prices for goods and services— a lower discount rate of 3 percen t is appropriate to reflect how private individuals trade-off current and future consumption.

The interagency group examined the econo mics literature and c oncluded that the consumption rate of interest is the correct concep t to use in evaluating the benefits and costs of a marginal change in carbon emissions (Lind 1990, Arrow et al ., 1996, Arrow 2000). The consumption rate of interest also is appropriate when the impacts of a regulation are measured in consumption (-equivalent) units, as is done in th e three integrated assessment models used for estimating the SCC.

Individuals use a variety of savings instrume nts that vary with ri sk level, time horizon, and tax characteristics. The standard analytic framework used to develop intuition about the discount rate typically assumes a representativ e agent with perfect foresight and no credit constraints. The risk-free rate is appropriate for discounting certain future benefits or costs, but the benefits calculated by IAMs are uncertain. To use the risk-free rate to discount uncertain benefits, these benefits first must be transformed into “certainty equivalents,” i.e. , the maximum certain amount that we would exchange for th e uncertain amount. However, the calculation of the certainty-equivalent requires first estimating the correlation between the benefits of the policy and baseline consumption.

EA-SCC.20

### If the IAM projections of future impacts represent expected values (not certaintyequivalent values), then the a ppropriate discount rate generally does not equal the risk-free rate. If the benefits of the policy tend to be high in those states of the world in which consumption is low, then the certainty-equivalent benefits will be higher than the expected benefits (and vice versa). Since many (though not necessarily all) of the important impacts of climate change will flow through market sectors such as agriculture and energy, and since willingness to pay for environmental protections typically increases with income, we might expect a positive (though not necessarily perfect) correlation between the net benefits from climate policies and market returns. This line of reasoning suggests that the proper discount rate would exceed the riskless rate. Alternatively, a negative correlation between the returns to climate policies and market returns would imply that a discount rate below the riskless rate is appropriate.

This discussion suggests that both the post- tax riskless and risky rates can be used to capture individuals’ consumption-e quivalent interest rate. As a measure of the post-tax riskless rate, we calculate the average real return from Treasury notes over the longest time period available (those from Newell and Pizer 2003) and adjust for Federal taxes (the average marginal rate from tax years 2003 through 2006 is around 27 percent). q 

### This calculation produces a real interest rate of about 2.7 pe rcent, which is roughly cons istent with Circular A-4’s recommendation to use 3 percent to repres ent the consumption rate of interest. r 

### A measure of the post-tax risky rate for investments whose returns are positively correlated with overall equity market returns can be obtained by adjusting pre-tax rates of household returns to risky investments (approximately 7 perc ent) for taxes yields a real rate of roughly 5 percent. s



### EA-SCC.4.6.2 The Ramsey Equation

Ramsey discounting also provides a useful framework to inform the choice of a discount rate. Under this approach, the analyst applies either positive or normative judgments in selecting values for the key parameters of the Ramsey equation: η (coefficient of relative risk aversion or elasticity of the marginal utility of consumption) and ρ (pure rate of time preference). t 

### These are then combined with g (growth rate of per-capita consumption) to equal the interest rate at which

qThe literature argues for a risk-free rate on government bonds as an appropriate measure of the consumption rate of interest. Arrow (2000) suggests that it is roughly 3-4 percent. OMB cites evidence of a 3.1 percent pre-tax rate for 10-year Treasury notes in the A-4 guidance. Newell and Pizer (2003) find real interest rates between 3.5 and 4 percent for 30-year Treasury securities.

r The positive approach reflects how individuals make allocation choices across time, but it is important to keep in mind that we wish to reflect preferences for society as a whole, which generally has a longer planning horizon.

s Cambell et al . (2001) estimates that the annual real return from stocks for 1900-1995 was about 7 percent. The annual real rate of return for the S&P 500 from 1950–2008 was about 6.8 percent. In the absence of a better way to population-weight the tax rates, we use the middle of the 20–40 percent range to derive a post-tax interest rate (Kotlikoff and Rapson 2006).

t The parameter ρ  measures the pure rate of time preference : people’s behavior reveals a preference for an increase in utility today versus the future. Consequently, it is standard to place a lower weight on utility in the future. The

parameter η captures diminishing marginal utility : consumption in the future is likely to be higher than consumption today, so diminishing marginal utility of consumption implies that the same monetary damage will cause a smaller reduction of utility for wealthier individuals, either in the future or in current generations. If η = 0, then a one dollar increase in income is equally valuable regardless of level of income; if η = 1, then a one percent increase in income is equally valuable no matter the level of income; and if η > 1, then a one percent increase in income is less valuable

to wealthier individuals.

EA-SCC.21

### future monetized damages are discounted: ρ + η ·g. u 

### In the simplest version of the Ramsey model, with an optimizing representative agent with perfect foresight, what we are calling the “Ramsey discount rate,” ρ + η ·g, will be equal to the rate of return to capital, i.e. , the market interest rate.

A review of the literature provides some guidance on reasonable parameter values for the Ramsey discounting equation, based on both pr escriptive and descriptive approaches.

• η . Most papers in the climate change literature adopt values for η in the range of 0.5 to 3 (Weitzman cites plausible values as those ra nging from 1 to 4), although not all authors

articulate whether their choice is based on prescriptive or descriptive reasoning. v 

### Dasgupta (2008) argues that η should be greater than 1 and may be as high as 3, since η equal to 1 suggests savings rates that do not conform to observed behavior.

• ρ . With respect to the pure rate of time preference, most papers in the climate change literature adopt values for ρ in the range of 0 to 3 percent per year. The very low rates tend to follow from moral judgments involving intergenerational neut rality. Some have argued that to use any value other than ρ = 0 would unjustly discriminate against future generations ( e.g. , Arrow et al . 1996, Stern 2006). However, even in an inter-generational setting, it may make sense to use a small positive pure rate of time preference because of the small probability of unforeseen cataclysmic events (Stern 2006).

• g. A commonly accepted approximation is around 2 percent per year. For the socioeconomic scenarios used for this exercise, the EMF models assume that g is about 1.5–2 percent to 2100.

Some economists and non-econo mists have argued for cons tant discount rates below 2 percent based on the prescriptive approach. When grounded in the Ramsey framework, proponents of this approach have argued that a ρ of zero avoids giving preferential treatment to one generation over another. The choice of η has also been posed as an ethical choice linked to

the value of an additional dolla r in poorer countries compared to wealthier ones. Stern (2006) applies this perspectiv e through his choice of ρ = 0.1 percent per year, η = 1 and g = 1.3 percent per year, which yields an annual discount rate of 1.4 percent. In the context of permanent income

u In this case, g could be taken from the selected EMF socioeconomic scenarios or alternative assumptions about the rate of consumption growth.

v Empirical estimates of η span a wide range of values. A benchmark value of 2 is near the middle of the range of values estimated or used by Szpiro (1986), Hall and Jones (2007), Arrow (2007), Dasgupta (2006, 2008), Weitzman (2007, 2009), and Nordhaus (2008). However, Chetty (2006) developed a method of estimating η using data on labor supply behavior. He shows that existing evidence of the effects of wage changes on labor supply imposes a tight upper bound on the curvature of utility over wealth (CRRA < 2) with the mean implied value of 0.71 and concludes that the standard expected utility model cannot generate high levels of risk aversion without contradicting established facts about labor supply. Recent work has jointly estimated the components of the Ramsey equation. Evans and Sezer (2005) estimate η = 1.49 for 22 OECD countries. They also estimate ρ = 1.08 percent per year using data on mortality rates. Anthoff et al . (2009b) estimate η = 1.18, and ρ = 1.4 percent. When they multiply the bivariate probability distributions from their work and Evans and Sezer (2005) together, they find η = 1.47, and ρ = 1.07.

EA-SCC.22

### savings behavior, however, Stern’ s assumptions suggest that individuals would save 93 percent

of their income. w



### Recently, Stern (2008) revisited the values us ed in Stern (2006), stating that there is a case to be made for raising η due to the amount of weight lower values place on damages far in the future (over 90 percent of expected damages occur after 2200 with η = 1). Using Stern’s assumption that ρ = 0.1 percent, combined with a η of 1.5 to 2 and his original growth rate, yields a discount rate greater 2 percent.

We conclude that arguments made under the pr escriptive approach can be used to justify discount rates between roughly 1.4 and 3.1 percen t. In light of concerns about the most appropriate value for η , we find it difficult to justify rates at the lower end of this range under the Ramsey framework.

EA-SCC.4.6.3 Accounting for Uncertainty in the Discount Rate

While the consumption rate of interest is an important driver of the benefits estimate, it is uncertain over time. Ideally, we would formally model this uncertainty, just as we do for climate sensitivity. Weitzman (1998, 2001) showed theo retically and Newell and Pizer (2003) and Panipoulou et al. (2004) confirm empirically that discount rate uncertainty can have a large effect on net present values. A main result from these studies is that if there is a persistent element to the uncertainty in the discount rate ( e.g. , the rate follows a random walk), then it will result in an effective (or certainty-equivale nt) discount rate that declines over time. Consequently, lower discount rates tend to do minate over the very long term (Weitzman 1998, 1999, 2001; Newell and Pizer 2003; Panipoulou et al. (2004); Gollier 2008; Summers and Zeckhauser 2008; and Gollier and Weitzman 2009).

The proper way to model discount rate uncer tainty remains an active area of research. Newell and Pizer (2003) employ a model of how long-term interest rate s change over time to

forecast future discount rates. Their model inco rporates some of the basic features of how interest rates move over time, and its parameters are estimated based on historical observations of long-term rates. Subsequent work on this topic, most notably Panipoulou et al. (2004), uses more general models of interest rate dynamics to allow for better forecasts. Specifically, the volatility of interest rates depends on whether rates are currently low or high and variation in the level of persistence over time.

While Newell and Pize r (2003) and Panipoulou et al. (2004) attempt fo rmally to model uncertainty in the discount rate, others argue fo r a declining scale of di scount rates applied over time ( e.g. , Weitzman 2001, and the UK’s “Green Book” for regulatory analysis). This approach uses a higher discount rate initia lly, but applies a graduated scal e of lower discount rates further

out in time. x 

### A key question that has emerged with rega rd to both of these approaches is the

w Stern (2008) argues that building in a positive rate of exogenous technical change over time reduces the implied savings rate and that η at or above 2 are inconsistent with observed behavior with regard to equity. (At the same time, adding exogenous technical change—all else equal—would increase g as well.)

x For instance, the UK applies a discount rate of 3.5 percent to the first 30 years; 3 percent for years 31–75; 2.5 percent for years 76–125; 2 percent for years 126–200; 1.5 percent for years 201–300; and 1 percent after 300 years. As a sensitivity, it recommends a discount rate of 3 percent for the first 30 years, also decreasing over time.

EA-SCC.23

### trade-off between potential time inconsistency and giving greater weight to far future outcomes (see the EPA Science Advisory Board’s recent comments on this topic as part of its review of

their Guidelines for Economic Analysis ). y



### EA-SCC.4.6.4 The Discount Rates Selected for Estimating SCC

In light of disagreement in the literature on the appropriate market interest rate to use in this context and uncertainty about how interest rates may change over time, we use three discount rates to span a plausible range of cert ainty-equivalent consta nt discount rates: 2.5, 3, and 5 percent per year. Based on the review in the previous sections, the interagency workgroup

determined that these three rates reflect reasonable judgments under both descriptive and prescriptive approaches.

The central value (3 percent) is consis tent with estimates pr ovided in the economics literature and OMB’s Circular A-4 guidance for the consumption rate of interest. As previously mentioned, the consumption rate of interest is the correct discounting concept to use when future damages from elevated temperatures are estimated in consumption-equivalent units. Further, 3 percent roughly corresponds to the after-tax riskle ss interest rate. The upper value of 5 percent is included to represent the possibility that climate damages are positively correlated with market returns. Additionally, this discount rate may be justified by the high interest rates that many consumers use to smooth consumption across periods.

The low value (2.5 percent) is included to in corporate the concern that interest rates are highly uncertain over time. It represents the av erage certainty-equivalent rate using the meanreverting and random walk approaches from Newe ll and Pizer (2003) startin g at a discount rate of 3 percent. Using this approach, the certainty equivalent is about 2.2 percent using the random walk model and 2.8 percent using the mean reverting approach. z 

### Without giving preference to a particular model, the average of the two rates is 2.5 percent. Further, a rate below the riskless rate would be justified if climate investments are negatively correlated with the overall market

rate of return. Use of this lower value also re sponds to certain judgments using the prescriptive or normative approach and to ethical objections that have been raised abou t rates of 3 percent or higher.

EA-SCC.5 REVISED SCC ESTIMATES

Our general approach to estimating SCC values is to run the three integrated assessment models (FUND, DICE, and PAGE) using the following inputs agreed upon by the interagency

group:

y Uncertainty in future damages is distinct from uncertainty in the discount rate. Weitzman (2008) argues that Stern’s choice of a low discount rate was “right for the wrong reasons.” He demonstrates how the damages from a low probability, catastrophic event far in the future dominate the effect of the discount rate in a present value calculation and result in an infinite willingness-to-pay for mitigation today. Newbold and Daigneault, (2009) and Nordhaus (2009) find that Weitzman’s result is sensitive to the functional forms chosen for climate sensitivity, utility, and consumption. Summers and Zeckhauser (2008) argue that uncertainty in future damages can also work in the other direction by increasing the benefits of waiting to learn the appropriate level of mitigation required.

z Calculations done by Pizer et al . using the original simulation program from Newell and Pizer (2003).

EA-SCC.24

### • A Roe and Baker distribution for the clima te sensitivity parameter bounded between 0

and 10 with a median of 3 °C and a cumula tive probability between 2 and 4.5 °C of twothirds.

• Five sets of GDP, population and carbon emissions trajectories based on EMF-22.

• Constant annual discount rate s of 2.5, 3, and 5 percent.

Because the climate sensitivity parameter is modeled probabilis tically, and because PAGE and FUND incorporate uncertainty in other model pa rameters, the final output from each model run is a distribution over the SCC in year t

.

For each of the IAMS, the basic computational steps for calculating the SCC in a particular year t

are:

1. Input the path of emissions, GDP, and popula tion from the selected EMF-22 scenarios, and the extrapolations based on th ese scenarios for post-2100 years.

2. Calculate the temperature effects and (consumption-equivalent) damages in each year resulting from the baseline path of emissions.

a. In PAGE, the consumption-equivalent damages in each period are calculated as a fraction of the EMF GDP forecast, depending on the temperature in that period relative to the pre-industrial average temperature in each region.

b. In FUND, damages in each period depe nd on both the level and the rate of temperature change in that period.

c. In DICE, temperature affects both consumpti on and investment, so we first adjust the EMF GDP paths as follows: Using the C obb-Douglas production function with the DICE2007 parameters, we extract the path of exogenous technical change implied by the EMF GDP and population paths, then we recalculate the baseline GDP path taking into account climate damages re sulting from the baseline emissions path.

3. Add an additional unit of carbon emissions in year t . (The exact unit varies by model.)

4. Recalculate the temperature effects and damages expected in all years beyond t resulting from this adjusted path of emissions, as in step 2.

5. Subtract the damages computed in step 2 from those in step 4 in each year. (DICE is run in 10 year time steps, FUND in annual time st eps, while the time steps in PAGE vary.)

6. Discount the resulting path of marginal damage s back to the year of emissions using the agreed upon fixed discount rates.

7. Calculate the SCC as the net present value of the discounted path of damages computed in step 6, divided by the unit of carbon emissi ons used to shock the models in step 3.

EA-SCC.25

### 8. Multiply by 12/44 to convert from dollars per ton of carbon to dollars per ton of CO 2 

### (2007 dollars) in DICE and FUND. (All calculations are done in tons of CO 2 

### in PAGE).

The steps above were repeated in each mode l for multiple future years to cover the time horizons anticipated for upcoming rulemaking analysis. To maintain consistency across the three IAMs, climate damages are cal culated as lost consumption in each future year.

It is important to note that each of the three models has a different default end year. The default time horizon is 2200 for PAGE, 2595 for DICE , and 3000 for the latest version of FUND. This is an issue for the multi-model approach because differences in SCC estimates may arise simply due to the model time horizon. Many consider 2200 too short a time horizon because it could miss a significant fraction of damages unde r certain assumptions about the growth of marginal damages and discounting, so each model is run here through 2300. This step required a small adjustment in the PAGE model only. This step also required assumptions about GDP, population, and greenhouse gas emission trajectories after 2100, the last year for which these data are available from the EMF-22 models. (A mo re detailed discussion of these assumptions is included in the Appendix.)

This exercise produces 45 separate distribu tions of the SCC for a given year, the product of 3 models, 3 discount rates, a nd 5 socioeconomic scenarios. This is clearly too many separate

distributions for consideration in a regulatory impact analysis.

To produce a range of plausible estimates that still reflects the uncertainty in the estimation exercise, the distributi ons from each of the models and scenarios are equally weighed and combined to produce three separate probability distributions for SCC in a given year, one for

each assumed discount rate. These di stributions are then used to de fine a range of point estimates for the global SCC. In this way, no integrated assessment model or socioeconomic scenario is given greater weight than another. Because the literature shows that the SCC is quite sensitive to assumptions about the discount ra te, and because no consensus exists on the appropriate rate to use in an intergenerational context, we present SCCs based on the average values across models

and socioeconomic scenarios for each discount rate.

The interagency group selected four SCC valu es for use in regulatory analyses. Three values are based on the average SCC across mode ls and socio-economic and emissions scenariosat the 2.5, 3, and 5 percent discount rates. The fourth value is included to represent the higherthan-expected economic impacts from climate change further out in the tails of the SCC distribution. For this purpose, we use the SCC value for the 95 th 

### percentile at a 3 percent discount rate. (The full set of distributions by model and scenario combination is included in the Appendix.) As noted above, the 3 percent discount rate is the central value, and so the central value that emerges is the average SCC across models at the 3 percent discount rate. For purposes of capturing the uncertainties involved in re gulatory impact analysis, we emphasize the importance and value of considering the full range.

As previously discussed, low probability, high impact events are incorporated into the SCC values through explicit consideration of their effects in two of the three models as well as the use of a probability density function for equilibrium climate sensitivity. Treating climate

EA-SCC.26

### sensitivity probabilistically results in more high temperature outcomes, which in turn lead to higher projections of damages. Although FUND does not include catastrophic damages (in contrast to the other two models), its probabilistic treatment of the equilibrium climate sensitivity parameter will directly affect the non-catastrophic damages that are a function of the rate of temperature change.

In Table 5.1, we begin by presenting SCC estimates for 2010 by model, scenario, and discount rate to illustrate the variability in the SCC across each of these input parameters. As expected, higher discount rates consistently result in lower S CC values, while lower discount rates result in higher SCC values for each socioeconomic trajectory. It is also evident that there are differences in the SCC estimated across the three main models. For these estimates, FUND produces the lowest estimates, while PAGE generally produces the highest estimates.

Table 5.1. Disaggregated Social Cost of CO 2 

### Values by Model, Soci o-Economic Trajectory, and Discount Rate for 2010 (2007$)

Discount rate: 5% 3% 2.5% 3%

Model Scenario Avg Avg Avg 95th

DICE IMAGE 10.8 35.8 54.2 70.8

MERGE 7.5 22.0 31.6 42.1 Message 9.8 29.8 43.5 58.6

MiniCAM 8.6 28.8 44.4 57.9

550 Average 8.2 24.9 37.4 50.8

PAGE IMAGE 8.3 39.5 65.5 142.4

MERGE 5.2 22.3 34.6 82.4 Message 7.2 30.3 49.2 115.6

MiniCAM 6.4 31.8 54.7 115.4 550 Average 5.5 25.4 42.9 104.7

FUND IMAGE -1.3 8.2 19.3 39.7

MERGE -0.3 8.0 14.8 41.3 Message -1.9 3.6 8.8 32.1

MiniCAM -0.6 10.2 22.2 42.6 550 Average -2.7 -0.2 3.0 19.4



### These results are not surprising when compared to the estimates in the literature for the latest versions of each model. For example, adjusting the values from the literature that were used to develop interim SCC va lues to 2007 dollars for the year 2010 (assuming, as we did for the interim process, that SCC grows at 3 per cent per year), FUND yields SCC estimates at or near zero for a 5 percent discount rate and ar ound $9 per ton for a 3 percent discount rate. There are far fewer estimates using the latest versions of DICE and PAGE in the literature: Using similar adjustments to genera te 2010 estimates, we calculate a SCC from DICE (based on Nordhaus 2008) of around $9 per ton for a 5 percent discount rate, and a SCC from PAGE (based on Hope 2006, 2008) close to $8 per ton fo r a 4 percent discount rate. Note that these comparisons are only approximate since the litera ture generally relies on Ramsey discounting,

while we have assumed constant discount rates. aa

aa Nordhaus (2008) runs DICE2007 with ρ = 1.5 and η = 2. The default approach in PAGE2002 (version 1.4epm)

treats ρ and η as random parameters, specified using a triangular distribution such that the min, mode, and max = 0.1, 1, and 2 for ρ , and 0.5, 1, and 2 for η , respectively. The FUND default value for η is 1, and Tol generates SCC

estimates for values of ρ = 0, 1, and 3 in many recent papers ( e.g. , Anthoff et al . 2009). The path of per-capita

EA-SCC.27

### The SCC estimates from FUND are sensitive to differences in emissions paths but relatively insensitive to differences in GDP paths across scenarios, while the reverse is true for DICE and PAGE. This likely occurs because of several structural differences among the models. Specifically in DICE and PAGE, the fraction of economic output lost due to climate damages increases with the level of temperature alone, wh ereas in FUND the fractional loss also increases with the rate of temperature change. Further, in FUND increases in income over time decrease vulnerability to climate change (a form of adaptation), whereas this does not occur in DICE and

PAGE. These structural differences among the models make FUND more sensitive to the path of emissions and less sensitive to GDP compared to DICE and PAGE.

Figure 5.1 shows that IMAGE has the highest GDP in 2100 while MERGE Optimistic has the lowest. The ordering of global GDP le vels in 2100 directly corresponds to the rank ordering of SCC for PAGE and DICE. For FUND , the correspondence is less clear, a result that is to be expected given its less direct re lationship between its da mage function and GDP.

450

400

350

Global 300 GDP (trillions 250

of U.S. dollars) 200

150

100

50

0

2000 2010 2020 2030 2050 2100 IMAGE

MERGE Optimistic

MESSAGE

MiniCAM

3.7 W/m2 radiative forcing



### Figure 5.1. Level of Global GDP Across EMF Scenarios

Table 5.2 shows the four selected SCC valu es in 5-year increments from 2010 to 2050. Values for 2010, 2020, 2040, and 2050 are calculated by first combining all outputs (10,000 estimates per model run) from all scenarios and models for a given discount rate. Values for the years in between are calculated using a simple linear interpolation.

Table 5.2. Social Cost of CO 2 

### , 2010–2050 (2007$)

Discount Rate 5% 3% 2.5% 3%

Year Avg Avg Avg 95th

2010 4.7 21.4 35.1 64.9

2015 5.7 23.8 38.4 72.8

2020 6.8 26.3 41.7 80.7

consumption growth, g, varies over time but is treated deterministically in two of the three models. In DICE, g is endogenous. Under Ramsey discounting, as economic growth slows in the future, the large damages from climate change that occur far out in the future are discounted at a lower rate than impacts that occur in the nearer term.

EA-SCC.282025 8.2 29.6 45.9 90.4

2030 9.7 32.8 50.0 100.0

2035 11.2 36.0 54.2 109.7

2040 12.7 39.2 58.4 119.3

2045 14.2 42.1 61.7 127.8

2050 15.7 44.9 65.0 136.2



### The SCC increases over time because future e missions are expected to produce larger incremental damages as physical and economic systems become more stressed in response to greater climatic change. Note that this approach allows us to estimate the growth rate of the SCC directly using DICE, PAGE, and FUND rather than assuming a constant annual growth rate as was done for the interim estimates (using 3 percent) . This helps to ensure that the estimates are internally consistent with ot her modeling assumptions. Table 5.3 illustrates how the growth rate

for these four SCC estimates varies over time . The full set of annua l SCC estimates between 2010 and 2050 is reported in the Appendix.

Table 5.3. Changes in the Average Annual Growth Rates of SCC Estimates between 2010

and 2050

Average Annual

Growth Rate 5% 3% 2.5% 3.0%

Year Range Avg Avg Avg 95th

2010–2020 3.6 2.1 1.7 2.2

2020–2030 3.7 2.2 1.8 2.2

2030–2040 2.7 1.8 1.6 1.8

2040–2050 2.1 1.4 1.1 1.3



### While the SCC estimate grows over time, the future monetized value of emissions reductions in each year (the SCC in year t multiplied by the change in emissions in year t ) must be discounted to the present to de termine its total net present value for use in regulatory analysis. Damages from future emissions should be discounted at the same rate as that used to calculate the SCC estimates themselves to ensure internal consistency— i.e. , future damages from climate change, whether they result from emissions today or emissions in a later year, should be discounted using the same rate. For example, clima te damages in 2020 that are calculated using a SCC based on a 5 percent discount rate also should be discounted back to the analysis year using a 5 percent discount rate. bb



### EA-SCC.6 LIMITATIONS OF THE ANALYSIS

As noted, any estimate of the SCC must be taken as provisional and subject to further refinement (and possibly significant change) in accordance with evolvi ng scientific, economic, and ethical understandings. During the course of our modeling, it became a pparent that there are several areas in partic ular need of additional explorati on and research. These caveats and additional observations in the following section ar e necessary to consider when interpreting and applying the SCC estimates.

bb However, it is possible that other benefits or costs of proposed regulations unrelated to CO 2 emissions will be discounted at rates that differ from those used to develop the SCC estimates.

EA-SCC.29

### Incomplete treatment of non-catastrophic damages . The impacts of climate change are expected to be widespread, diverse, and hetero geneous. In addition, the exact magnitude of these impacts is uncertain because of the inherent co mplexity of climate processes, the economic

behavior of current and future populations, and our inability to accurately forecast technological change and adaptation. Current IAMs do not assi gn value to all of the important physical, ecological, and economic impacts of climate change recognized in the climate change literature (some of which are discussed above) because of lack of precise information on the nature of damages and because the science incorporated in to these models understandably lags behind the most recent research. Our ability to quantif y and monetize impacts will undoubtedly improve with time. It is also likely that even in future applications, a number of potentially significant damage categories will rema in non-monetized. (Ocean acidifi cation is one example of a potentially large damage from CO 2 

### emissions not quantified by any of the three models. Species and wildlife loss is another example that is exceedingly difficult to monetize.)

Incomplete treatment of potential catastrophic damages . There has been considerable recent discussion of the risk of catastrophic impacts and how best to account for extreme scenarios, such as the collapse of the Atlantic Meridional Overturning Circulation or the West Antarctic Ice Sheet, or large releases of methane from melting permafrost and warming oceans. Weitzman (2009) suggests that catastrophic damages are extremely large—so large, in fact, that the damages from a low probability, catastrophic ev ent far in the future dominate the effect of the discount rate in a present value calculation an d result in an infinite willingness-to-pay for mitigation today. However, Nordhaus (2009) concluded that the conditions under which Weitzman’s results hold “are limited and do not apply to a wide range of potential uncertain

scenarios.”

Using a simplified IAM, Newbold and Daig neault (2009) confirmed the potential for large catastrophe risk premiums but also show ed that the aggregate benefit estimates can be highly sensitive to the shapes of both the climate sensitivity distribution and the damage function at high temperature changes. Pindyck (2009) also used a simplified IAM to examine high-impact low-probability risks, using a right-skewed gamma distribution for climate sensitivity as well as an uncertain damage coefficient, but in most cas es found only a modest risk premium. Given this difference in opinion, further research in this area is needed before its practical significance can be fully understood and a reasonable approach devel oped to account for such risks in regulatory analysis. (The next section discusses the scie ntific evidence on catastrophic impacts in greater detail.)

Uncertainty in extrapolation of damages to high temperatures . The damage functions in these IAMs are typically calibrated by estimating damages at moderate temperature increases ( e.g. , DICE was calibrated at 2.5 °C) and extrapolat ed to far higher temperatures by assuming that damages increase as some power of the temperature change. Hence, estimated damages are

far more uncertain under more extrem e climate change scenarios.

Incomplete treatment of adaptation and technological change . Each of the three integrated assessment models used here assumes a certain degree of low- or no-cost adaptation. For instance, Tol assumes a great deal of adapta tion in FUND, including widespread reliance on

EA-SCC.30

### air conditioning, so much so that the largest si ngle benefit category in FUND is the reduced electricity costs from not havi ng to run air conditioning as intensively (NRC 2009).

Climate change also will increase returns on investment to develop technologies that allow individuals to cope with adverse climate conditions, and IAMs to do not adequately

account for this directed technological change. cc 

### For example, scientists may develop crops that are better able to withstand higher and more variable temperatures. Although DICE and FUND have both calibrated their agricultural sectors unde r the assumption that farmers will change land use practices in response to climate change (M astrandrea 2009), they do not take into account technological changes that lower the cost of this adaptation over time. On the other hand, the calibrations do not account for increases in climate variability, pests, or diseases, which could make adaptation more difficult than assumed by the IAMs for a given temperature change. Hence, models do not adequately account for poten tial adaptation or technical change that might alter the emissions pathway and resulting damages. In this respect, it is difficult to determine whether the incomplete treatment of adaptation and technological change in these IAMs under or overstate the likely damages.

Risk aversion . A key question unanswered during this interagency process is what to

assume about relative risk aversi on with regard to high-impact outcomes. These calculations do not take into account the possibility that individuals may have a higher willingness to pay to reduce the likelihood of low-probability, high-impact damages than they do to reduce the likelihood of higher-probability but lower-impact damages with the same expected cost. (The

inclusion of the 95 th 

### percentile estimate in the final set of SCC values was largely motivated by this concern.) If individuals do show such a higher willingness to pay, a further question is

whether that fact should be taken into account fo r regulatory policy. Even if individuals are not risk-averse for such scenarios, it is possible th at regulatory policy should include a degree of

risk-aversion.

Assuming a risk-neutral representative agent is consistent with OMB’s Circular A-4,

which advises that the estimates of benefits and costs used in regulatory analysis are usually based on the average or the expected value and that “emphasis on these expected values is appropriate as long as society is ‘risk neutral’ with respect to the regulatory alternatives. While this may not always be the case, [analysts] shoul d in general assume ‘risk neutrality’ in [their] analysis.”

Nordhaus (2008) points to the need to expl ore the relationship between risk and income in the context of climate change across models and to explore the role of uncertainty regarding various parameters in the results. Using FUND, Anthoff et al. (2009) explored the sensitivity of the SCC to Ramsey equation parameter assumpti ons based on observed behavior. They conclude that “the assumed rate of risk aversion is at least as important as the assumed rate of time preference in determining the social cost of ca rbon.” Since Circular A-4 allows for a different assumption on risk preference in regulatory analysis if it is adequately justified, we plan to continue investigating this issue.

cc However these research dollars will be diverted from what ever their next best use would have been in the absence of climate change (so productivity/GDP would have been still higher).

EA-SCC.31

### EA-SCC.7 A FURTHER DISCUSSION OF CATASTROPHIC IMPACTS AND

DAMAGE FUNCTIONS

As noted above, the damage functions underlying the three IAMs used to estimate the SCC may not capture the economic effects of all possible adverse consequences of climate change and may therefore lead to underestimate s of the SCC (Mastrandr ea 2009). In particular, the models’ functional forms may not adequately capture: (1) pot entially discontinuous “tipping point” behavior in Earth systems; (2) inter-sectoral and inter-regional interactions, including global security impacts of high-end warming; and (3) limited near-term substitutability between damage to natural systems a nd increased consumption.

It is the hope of the interagency group that over time researchers a nd modelers will work to fill these gaps and that the SCC estimates used for regulatory analysis by the Federal government will continue to evolve with improvements in modeling. In the meantime, we

discuss some of the available evidence.

EA-SCC.7.1 Extrapolation of Climate Damage s to High Levels of Warming

The damage functions in the models are calibrated at moderate levels of warming and should therefore be viewed cautiously when extra polated to the high temperatures found in the upper end of the distribution. Recent science su ggests that there are a number of potential climatic “tipping points” at which the Earth system may exhibit discontinuous behavior with potentially severe social a nd economic consequences ( e.g. , Lenton et al. 2008, Kriegler et al. 2009). These tipping points include the disrupti on of the Indian Summer Monsoon, dieback of the Amazon Rainforest and boreal forests, colla pse of the Greenland Ice Sheet and the West Antarctic Ice Sheet, reorganization of the Atlantic Meridional Ov erturning Circulation, strengthening of El Niño-Southern Oscilla tion, and the release of methane from melting permafrost. Many of these tippi ng points are estimated to have thresholds between about 3 °C and 5 °C (Lenton et al. 2008). Probabilities of se veral of these tipping points were assessed through expert elicitatio n in 2005–2006 by Kriegler et al. (2009); results from this study are highlighted in Table 7.1. Ranges of probability ar e averaged across core experts on each topic.

Table 7.1. Probabilities of Various Tipping Points from Expert Elicitation

Possible Tipping Points Duration before effect is fully realized

years Additional Warming by 2100

%

0.5–1.5 C 1.5–3.0 C 3–5 C Reorganization of Atlantic Meridional Overturning Circulation about 100 0–18 6–39 18–67

Greenland Ice Sheet Collapse at least 300 8–39 33–73 67–96 West Antarctic Ice Sheet Collapse at least 300 5–41 10–63 33–88

Dieback of Amazon rainforest about 50 2–46 14–84 41–94 Strengthening of El Niño-Southern

Oscillation about 100 1–13 6–32 19–49

Dieback of Boreal Forests about 50 13–43 20–81 34–91

Shift in Indian Summer Monsoon about 1 not formally assessed Release of Methane from Melting

Permafrost less than 100 not formally assessed

EA-SCC.32

### As previously mentioned, FUND does not in clude potentially catastrophic effects. DICE assumes a small probability of ca tastrophic damages that increase s with increased warming, but the damages from these risks are incorporated as expected values ( i.e. , ignoring potential risk aversion). PAGE models catastrophic impacts in a probabilistic framework (Figure 1), so the high-end output from PAGE potentially offers the best insight into the SCC if the world were to experience catastrophic climate change. For instance, at the 95 th 

### percentile and a 3 percent discount rate, the SCC estimated by PAGE ac ross the five socio- economic and emission trajectories of $113 per ton of CO 2 

### is almost double the value estimated by DICE, $58 per ton in2010. We cannot evaluate how well the three models account for catastrophic or noncatastrophic impacts, but this estimate highlights the sensitivity of SCC values in the tails of the distribution to the assumptions made about catastrophic impacts.

PAGE treats the possibility of a catastrophic event probabilistically, while DICE treats it deterministically ( i.e. , by adding the expected value of the damage from a catastrophe to the aggregate damage function). In part, this results in different probabilities being assigned to a catastrophic event across the two models. For inst ance, PAGE places a probability near zero on a catastrophe at 2.5 °C warming, while DICE assu mes a 4 percent probability of a catastrophe at

2.5 °C. By comparison, Kriegler et al. (2009) estimate a probability of at least 16

– 

### 36 percent of crossing at least one of their primary climatic tipping points in a scenario with temperatures

about 2

– 

### 4 °C warmer than pre-Industrial levels in 2100.

It is important to note that crossing a climatic tipping point will not necessarily lead to an economic catastrophe in the sense used in the IA Ms. A tipping point is a critical threshold across which some aspect of the Earth system starts to shifts into a qualitatively different state (for instance, one with dramatically reduced ice sheet volumes and higher sea levels). In the IAMs, a catastrophe is a low-probability environmen tal change with high economic impact.

EA-SCC.7.2 Failure to Incorporate Inter-Sectoral and Inter-Regional Interactions

The damage functions do not fully incorpor ate either inter-sectoral or inter-regional interactions. For instance, while damages to the agricultural sector are incorporated, the effects of changes in food supply on human health are not fully captured and depend on the modeler’s choice of studies used to calibrate the IAM. Likewise, the effects of climate damages in one region of the world on another region are not incl uded in some of the models (FUND includes the effects of migration from sea level rise). Th ese inter-regional interactions, though difficult to quantify, are the basis for climate-induced national and economic security concerns ( e.g. , Campbell et al. 2007; U.S. Department of Defense 2010) and are particularly worrisome at higher levels of warming. High-end warming scen arios, for instance, project water scarcity affecting 4.3

– 

### 6.9 billion people by 2050, food scarcity affecting about 120 million additional people by 2080, and the creation of millions of climate refugees (Easterling et al. 2007; Campbell et al . 2007).

EA-SCC.7.3 Imperfect Substitutability of Environmental Amenities

Data from the geological record of past climate changes suggests that 6 °C of warming may have severe consequences for natural syst ems. For instance, during the Paleocene-Eocene Thermal Maximum about 55.5 million years ago, when the Earth experienced a geologically

EA-SCC.33

### rapid release of carbon associated with an approximately 5 °C increase in global mean temperatures, the effects included shifts of about 400

– 

### 900 miles in the range of plants (Wing et
al. 2005), and dwarfing of both land mammals (Gingerich 2006) and soil fauna (Smith et al. 2009).

The three IAMs used here assume that it is possible to compensate for the economic consequences of damages to natural systems through increas ed consumption of non-climate goods, a common assumption in many economic m odels. In the context of climate change, however, it is possible that the damages to na tural systems could become so great that no increase in consumption of non-climate goods would provide complete compensation (Levy et
al. 2005). For instance, as water supplies become s carcer or ecosystems become more fragile and less bio-diverse, the services they provide may become increasingly more costly to replace. Uncalibrated attempts to incorporate the imperfect substitutability of such amenities into IAMs (Sterner and Persson 2008) indicate that the optimal degree of emissions abatement can be considerably greater than is commonly recognized.

EA-SCC.8 CONCLUSION

The interagency group selected four SCC estimates for use in regulatory analyses. For 2010, these estimates are $4.7, $21.4, $35.1, and $64.9 ( 2007$). The first three estimates are based on the average SCC across models and soci o-economic and emissions scenarios at the 5, 3, and 2.5 percent discount rates, resp ectively. The fourth value is included to represent the higherthan-expected impacts from temperature change furt her out in the tails of the SCC distribution. For this purpose, we use the SCC value for the 95 th 

### percentile at a 3 percent discount rate. The central value is the average SCC across models at the 3 percent discount rate. For purposes of capturing the uncertainties involved in regulatory impact analysis, we emphasize the importance and value of considering the full range. These SCC estimates also grow over time. For instance, the central value increases to $24 per ton of CO 2 

### in 2015 and $26 per ton of CO 2 

### in 2020.

We noted a number of limitations to this analysis, including the incomplete way in which the integrated assessment models capture cat astrophic and non-catastrophic impacts, their incomplete treatment of adaptation and technological change, uncertainty in the extrapolation of damages to high temperatures, and assumptions regarding risk aversion. The limited amount of research linking climate impact s to economic damages makes this modeling exercise even more difficult. It is the hope of the interagency gr oup that over time research ers and modelers will work to fill these gaps and that the SCC estimates used for regulatory analysis by the Federal government will continue to evolve with improvements in modeling.

EA-SCC.34

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EA-SCC.40

### EA-SCC.9 APPENDIX

This Appendix provides additional technical info rmation about the non-CO 2 

### emission projections used in the modeling and the method for extrapolating emissions forecasts through 2300, and shows the full distribution of 2010 SCC es timates by model and s cenario combination. Annual SCC values for the next 40 years are provided in Table 9.1.

Table 9.1. Annual SCC Values: 2010–2050 (2007$)

Discount Rate 5% 3% 2.5% 3%

Year Avg Avg Avg 95th

2010 4.7 21.4 35.1 64.9

2011 4.9 21.9 35.7 66.5

2012 5.1 22.4 36.4 68.1

2013 5.3 22.8 37.0 69.6

2014 5.5 23.3 37.7 71.2

2015 5.7 23.8 38.4 72.8

2016 5.9 24.3 39.0 74.4

2017 6.1 24.8 39.7 76.0

2018 6.3 25.3 40.4 77.5

2019 6.5 25.8 41.0 79.1

2020 6.8 26.3 41.7 80.7

2021 7.1 27.0 42.5 82.6

2022 7.4 27.6 43.4 84.6

2023 7.7 28.3 44.2 86.5

2024 7.9 28.9 45.0 88.4

2025 8.2 29.6 45.9 90.4

2026 8.5 30.2 46.7 92.3

2027 8.8 30.9 47.5 94.2

2028 9.1 31.5 48.4 96.2

2029 9.4 32.1 49.2 98.1

2030 9.7 32.8 50.0 100.0

2031 10.0 33.4 50.9 102.0

2032 10.3 34.1 51.7 103.9

2033 10.6 34.7 52.5 105.8

2034 10.9 35.4 53.4 107.8

2035 11.2 36.0 54.2 109.7

2036 11.5 36.7 55.0 111.6

2037 11.8 37.3 55.9 113.6

2038 12.1 37.9 56.7 115.5

2039 12.4 38.6 57.5 117.4

2040 12.7 39.2 58.4 119.3

2041 13.0 39.8 59.0 121.0

2042 13.3 40.4 59.7 122.7

2043 13.6 40.9 60.4 124.4

2044 13.9 41.5 61.0 126.1

2045 14.2 42.1 61.7 127.8

2046 14.5 42.6 62.4 129.4

2047 14.8 43.2 63.0 131.1

2048 15.1 43.8 63.7 132.8

2049 15.4 44.4 64.4 134.5

2050 15.7 44.9 65.0 136.2

EA-SCC.41

### EA-SCC.9.1 Other (non-CO 2 

### ) Gases

In addition to fossil and industrial CO 2 

### emissions, each EMF scenario provides projections of methane (CH 4 

### ), nitrous oxide (N 2 

### O), fluorinated gases, and net land use CO 2 

### emissions to 2100. These assumptions are used in all three IAMs while retaining each model’s default radiative forcings (R F) due to other factors ( e.g. , aerosols and other gases). Specifically,

to obtain the RF associated with the non-CO 2 

### EMF emissions only, we calculated the RF associated with the EMF atmospheric CO 2 

### concentrations and subtracted them from the EMF

total RF. dd 

### This approach respects the EMF scenarios as much as possible and at the same time takes account of those components not included in the EMF projections. Since each model treats

non-CO 2 

### gases differently ( e.g. , DICE lumps all other gases into one composite exogenous input), this approach was applied slightly differently in each of the models.

FUND : Rather than relying on RF for these gases, the actual emissions from each scenario were used in FUND. The model default trajectories for CH 4 

### , N 2 

### O, SF 6 

### , and the CO 2 

### emissions from land were replaced with the EMF values.

PAGE : PAGE models CO 2 

### , CH 4 

### , sulfur hexafluoride (SF 6 

### ), and aerosols and contains an “excess forcing” vector that includes the RF for everything else. To include the EMF values, we

removed the default CH 4 

### and SF 6 

### factors, ee 

### decomposed the excess forcing vector, and constructed a new excess forcing vector that includes the EMF RF for CH 4 

### , N 2 

### O, and fluorinated gases, as well as the model default values fo r aerosols and other factors. Net land use CO 2 

### emissions were added to the fossil and industrial CO 2 

### emissions pathway.

DICE : DICE presents the greatest challenge because all forcing due to factors other than

industrial CO 2 

### emissions is embedded in an exogenous non-CO 2 

### RF vector. To decompose this exogenous forcing path into EMF non-CO 2 

### gases and other gases, we relied on the references in DICE2007 to the Intergovernmental Panel on C limate Change’s (IPCC) Fourth Assessment Report (AR4) and the discussion of aerosol fo recasts in the IPCC’s Third Assessment Report (TAR) and in AR4, as explained below. In DICE 2007, Nordhaus assumes that exogenous forcing

from all non-CO 2 

### sources is -0.06 W/m 2 

### in 2005, as reported in AR4, and increases linearly to

0.3 W/m 2 

### in 2105, based on GISS projections, and th en stays constant after that time.

According to AR4, the RF in 2005 from CH 4 

### , N 2 

### 0, and halocarbons (approximately similar to the F-gases in the EMF-22 scenarios) was 0.48 + 0.16 + 0.34 = 0.98 W/m 2 

### and RF

from total aerosols was -1.2 W/m 2 

### . Thus, the -.06 W/m 2 

### non-CO 2 

### forcing in DICE can be decomposed into: 0.98 W/m 2 

### due to the EMF non-CO 2 

### gases, -1.2 W/m 2 

### due to aerosols, and the remainder, 0.16 W/m 2 

### , due to other residual forcing.

dd

Note EMF did not provide CO 2 concentrations for the IMAGE reference sc enario. Thus, for this scenario, we fed the fossil, industrial and land CO 2 emissions into MAGICC (considered a “neutral arbiter” model, which is tuned to emulate the major global climate models) and the resulting CO 2 concentrations were used. Note also that MERGE assumes a neutral biosphere so net land CO 2 emissions are set to zero for all years for the MERGE Optimistic reference scenario, and for the MERGE component of the average 550 scenario ( i.e. , we add up the land use emissions from the other three models and divide by 4).

ee Both the model default CH 4 emissions and the initial atmospheric CH 4 is set to zero to avoid double counting the effect of past CH 4 emissions.

EA-SCC.42

### For subsequent years, we calculated the DICE default RF from aerosols and other nonCO 2 

### gases based on the following two assumptions:

(1) RF from aerosols declines linearly from 2005 to 2100 at the rate projected by the TAR and then stays constant thereafter, and

(2) With respect to RF from non-CO 2 

### gases not included in the EMF-22 scenarios, the share of non-aerosol RF matches the share implicit in the AR4 summary sta tistics cited above and

remains constant over time.

Assumption (1) means that the RF from aerosols in 2100 equals 66 percent of that in 2000, which is the fraction of the TAR projection of to tal RF from aerosols (including sulfates, black carbon, and organic carbon) in 2100 vs. 2000 under th e A1B SRES emissions scenario. Since the SRES marker scenarios were not updated for th e AR4, the TAR provides the most recent IPCC projection of aerosol forcing. We rely on the A1B projection from the TAR because it provides one of the lower aerosol forecasts among the SRES marker scenarios and is more consistent with the AR4 discussion of the post-SRES literature on aerosols:

Aerosols have a net cooling effect and the re presentation of aerosol and aerosol precursor emissions, including sulphur dioxide, black carbon and organic carbon, has improved in the post-SRES scenarios. Generally, these emissions are projected to be lower than reported in SRES. {WGIII 3.2, TS.3, SPM}. ff



### Assuming a simple linear decline in aerosols from 2000 to 2100 also is more consistent

with the recent literature on these emissions. Fo r example, Figure 9.1 shows that the sulfur dioxide emissions peak over the short-term of some SRES scenarios above the upper bound

estimates of the more recent scenarios. gg 

### Recent scenarios project sulfur emissions to peak earlier and at lower levels compared to the SRES in pa rt because of new information about present and planned sulfur legislation in some developing countries, such as India and China. hh 

### The lower bound projections of the recent literature have also shifted downward slightly compared to the SRES scenario (IPCC 2007).

With these assumptions, the DICE aerosol forcing changes from -1.2 in 2005 to -0.792 in

2105 W/m 2 

### ; forcing due to other non-CO 2 

### gases not included in the EMF scenarios declines from

0.160 to 0.153 W/m 2



### .

ff

AR4 Synthesis Report, p. 44, http://www.ipcc.ch/pdf/assessment-report/ar4/syr/ar4_syr.pdf

gg

See Smith, S.J., R. Andres, E. Conception, and J. Lurz. 2004. “Historical sulfur dioxide emissions, 1850-2000: methods and results.” Joint Global Research Institute, College Park, 14 pp.

hh See Carmichael, G., D. Streets, G. Calori, M. Amann, M. Jacobson, J. Hansen, and H. Ueda. 2002. “Changing trends in sulphur emissions in Asia: implications for acid deposition, air pollution, and climate.” Environmental Science and Technology 36(22):4707- 4713; Streets, D., K. Jiang, X. Hu, J. Sinton, X.-Q. Zhang, D. Xu, M. Jacobson, and J. Hansen. 2001. “Recent reductions in China’s greenhouse gas emissions.” Science 294(5548):1835­

1837.

EA-SCC.43

### .

Figure 9.1. Sulphur Dioxide Emission Scenarios
Notes: Thick colored lines depict the four SRES mark er scenarios and black dashed lines show the median,

5 th and 95 th percentile of the frequency distribution for the full ensemble of 40 SRES scenarios. The blue area (and the thin dashed lines in blue) illustrates individual scenarios and the range of Smith et al. (2004).

Dotted lines indicate the minimum and maximum of SO 2 emissions scenarios developed pre-SRES. Source: IPCC (2007), AR4 WGIII 3.2, http://www.ipcc.ch/publications_and_data/ar4/wg3/en/ch3-ens3-2

­ 2-4.html

.



### Although other approaches to decomposin g the DICE exogenous forcing vector are possible, initial sensitivity analysis suggests that the differences among reasonable alternative approaches are likely to be minor. For example, adjusting the TAR aerosol projection above to

assume that aerosols will be maintained at 2000 levels throug h 2100 reduces average SCC values (for 2010) by approximately 3 percent (or less than $2); assuming all aerosols are phased out by 2100 increases average 2010 SCC values by 6–7 percent (or $0.50–$3), depending on the discount rate. These differences increase slightly for SCC values in late r years but are still well within 10 percent of each other as far out as 2050.

Finally, as in PAGE, the EMF net land use CO 2 

### emissions are added to the fossil and

industrial CO 2 

### emissions pathway.

EA-SCC.9.2 Extrapolating Emissions Projections to 2300

To run each model through 2300 requi res assumptions about GDP, population, greenhouse gas emissions, and radi ative forcing trajectories afte r 2100, the last year for which these projections are available from the EMF-22 models. These inputs were extrapolated from

2100 to 2300 as follows:

1. Population growth rate declines linearly, reaching zero in 2200.

2. GDP/per capita growth rate declines linearly, reaching zero in 2300.

3. The decline in the fossil and industrial carbon intensity (CO 2 

### /GDP) growth rate over 2090-2100 is maintained from 2100 through 2300.

EA-SCC.44

### 4. Net land use CO 2 

### emissions decline linearly, reaching zero in 2200.

5. Non-CO 2 

### radiative forcing remains constant after 2100.

Long run stabilization of GDP per capita was viewed as a more realistic simplifying assumption than a linear or exponential extrapol ation of the pre-2100 economic growth rate of each EMF scenario. This is based on the idea that increasing scarcity of natural resources and the degradation of environmental sinks ava ilable for assimilating pollution from economic production activities may eventually overtake the rate of technological progress. Thus, the overall rate of economic growth may slow over the very long run. The interagency group also considered allowing an exponential decline in the growth rate of GDP per capita. However, since this would require an additional assumption about how close to zero the growth rate would get by 2300, the group opted for the simpler and more transparent linear extrapolation to zero by

2300.

The population growth rate is also assumed to decline linearly, reaching zero by 2200. This assumption is reasonably c onsistent with the United Nations long run population forecast, which estimates global population to be fairly stable after 2150 in the medium scenario (UN 2004). ii 

### The resulting range of EMF population traject ories (Figure A2) also encompass the UN medium scenario forecasts through 2300 – gl obal population of 8.5 billion by 2200, and 9 billion by 2300.

Maintaining the decline in the 2090–2100 carbon intensity growth rate ( i.e. , CO 2 

### per dollar of GDP) through 2300 assumes that tec hnological improvements and innovations in the areas of energy efficiency and other carbon re ducing technologies (possibly including currently unavailable methods) will continue to proceed at roughly the same pace that is projected to occur towards the end of the forecast period for each EMF scenario. This assumption implies that total cumulative emissions in 2300 will be between 5,000 and 12,000 GtC, which is within the range of the total potential global carbon stock estimated in the literature.

Net land use CO 2 

### emissions are expected to stabilize in the long run, so in the absence of any post 2100 projections, the group assumed a linear decline to zero by 2200. Given no a priori reasons for assuming a long run increase or decline in non-CO 2 

### radiative forcing, it is assumed to remain at the 2100 levels for each EMF scenario through 2300.

Figure 9.2 through Figure 9.7 show the paths of global population, GDP, fossil and

industrial CO 2 

### emissions, net land CO 2 

### emissions, non-CO 2 

### radiative forcing, and CO 2 

### intensity (fossil and industrial CO 2 

### emissions/GDP) resulting from these assumptions.

ii United Nations. 2004. World Population to 2300

. http://www.un.org/esa/population/publications/longrange2/worldpop2300final.pdf

.

EA-SCC.455.5 6.5 7.5 8.5 9.5 10.5 11.5

2000 2050 2100 2150 2200 2250 2300 IMAGE

MERGE

MESSAGE

MiniCAM

5th scenario

ExtrapolationsGlobalPopulation[billion]

Year



### Figure 9.2. Global Population, 2000–2300 (post-2100 extrapolations assume the population growth rate changes lin early to reach a zero growth rate by 2200)
Note: In the fifth scenario, 2000–2100 population is equal to the average of the population under the 550 ppm CO 2 e, full-participation, not-to-e xceed scenarios considered by each of the four models.

0 500 1000 1500 2000

2000 2050 2100 2150 2200 2250 2300 IMAGE

MERGE

MESSAGE

MiniCAM

5th scenario

Extrapolations

YearWorldGDP[$trillion]



### Figure 9.3. World GDP, 2000-2300 (post-2100 extr apolations assume GDP per capita growth declines linearly, reaching zero in 2300)
Note: In the fifth scenario, 2000–2100 GDP is equal to the average of the GDP under the 550 ppm CO 2 e, full-participation, not-to-exceed scenarios co nsidered by each of the four models.

EA-SCC.46Fossil&IndustrialCO2Emissions[GtCO2/decade] 200

150

100

50

0 IMAGE

MERGE

MESSAGE

MiniCAM

5th scenario

Extrapolations

2000 2050 2100 2150 2200 2250 2300

Year



### Figure 9.4. Global Fossil and Industrial CO 2 

### Emissions, 2000-2300 (post-2100 extrapolations assume growth rate of CO 2 

### intensity (CO 2 

### /GDP) over 2090–2100 is maintained through 2300)
Note: In the fifth scenario, 2000–2100 emissions are equal to the average of the emissions under the 550 ppm CO2e, full-participation, not-to-exceed scenario s considered by each of the four models.

‐ 3.00 ‐ 2.00 ‐ 1.00 0.00 1.00 2.00 3.00 4.00

2000 2050 2100 2150 2200 2250 2300 IMAGE

MERGE

MESSAGE

MiniCAM

5th scneario

ExtrapolationsNetlandCO2emissions[GtCO2/yr]

Year z



### Figure 9.5. Global Net Land Use CO 2 

### Emissions, 2000–2300 (post-2100 extrapolations

assume emissions decline lin early, reaching zero in 2200) jj

Note: In the fifth scenario, 2000–2100 emissions are equal to the average of the emissions under the 550 ppm CO2e, full-participation, not-to-exceed scenar ios considered by each of the four models.

jj MERGE assumes a neutral biosphere so net land CO 2 emissions are set to zero for all years for the MERGE Optimistic reference scenario, and for the MERGE component of the average 550 scenario ( i.e. , we add up the land use emissions from the other three models and divide by 4).

EA-SCC.470.00 0.75 1.50 2.25 3.00 3.75

2000 2050 2100 2150 2200 2250 2300 IMAGE

MERGE

MESSAGE

MiniCAM

5th scenario

ExtrapolationsnonCO2RF[W/m^2]

Year



### Figure 9.6. Global Non-CO 2 

### Radiative Forcing, 2000–2300 (post-2100 extrapolations

assume constant non-CO 2 

### radiative forcing after 2100)
Note: In the fifth scenario, 2000–2100 emissions are equal to the average of the emissions under the 550 ppm CO2e, full-participation, not-to-exceed scenario s considered by each of the four models.

0 0 0 0 0 1 1 1 1

2000 2050 2100 2150 2200 2250 2300 IMAGE

MERGE

MESSAGE

MiniCAM

5th scenario

ExtrapolationsFossil&IndustrialCO2intensity[GtCO2/trillion$]

Year



### Figure 9.7. Global CO 2 

### Intensity (fossil & industrial CO 2 

### emissions/GDP), 2000–2300 (post

2100 extrapolations assume decline in CO 2 

### /GDP growth rate over 2090–2100 is maintained through 2300)
Note: In the fifth scenario, 2000–2100 emissions are equal to the average of the emissions under the 550 ppm CO 2 e, full-participation, not-to-e xceed scenarios considered by each of the four models.

EA-SCC.48

### Table 9.2. 2010 Global SCC Estimates at 2.5 Percent Discount Rate (2007$/ton CO 2 

### )

Percentile 1st 5th 10th 25th 50th Avg 75th 90th 95th 99th

Scenario PAGE

IMAGE 3.3 5.9 8.1 13.9 28.8 65.5 68.2 147.9 239.6 563.8 MERGE optimistic 1.9 3.2 4.3 7.2 14.6 34.6 36.2 79.8 124.8 288.3 Message 2.4 4.3 5.8 9.8 20.3 49.2 50.7 114.9 181.7 428.4

MiniCAM base 2.7 4.6 6.4 11.2 22.8 54.7 55.7 120.5 195.3 482.3

5th scenario 2.0 3.5 4.7 8.1 16.3 42.9 41.5 103.9 176.3 371.9

Scenario DICE

IMAGE 16.4 21.4 25 33.3 46.8 54.2 69.7 96.3 111.1 130.0 MERGE optimistic 9.7 12.6 14.9 19.7 27.9 31.6 40.7 54.5 63.5 73.3 Message 13.5 17.2 20.1 27 38.5 43.5 55.1 75.8 87.9 103.0

MiniCAM base 13.1 16.7 19.8 26.7 38.6 44.4 56.8 79.5 92.8 109.3

5th scenario 10.8 14 16.7 22.2 32 37.4 47.7 67.8 80.2 96.8

Scenario FUND

IMAGE -33.1 -18.9 -13.3 -5.5 4.1 19.3 18.7 43.5 67.1 150.7 MERGE optimistic -33.1 -14.8 -10 -3 5.9 14.8 20.4 43.9 65.4 132.9 Message -32.5 -19.8 -14.6 -7.2 1.5 8.8 13.8 33.7 52.3 119.2

MiniCAM base -31.0 -15.9 -10.7 -3.4 6 22.2 21 46.4 70.4 152.9

5th scenario -32.2 -21.6 -16.7 -9.7 -2.3 3 6.7 20.5 34.2 96.8



### Table 9.3. 2010 Global SCC Estimates at 3 Percent Discount Rate (2007$/ton CO 2 

### )

Percentile 1st 5th 10th 25th 50th Avg 75th 90th 95th 99th

Scenario PAGE

IMAGE 2.0 3.5 4.8 8.1 16.5 39.5 41.6 90.3 142.4 327.4 MERGE optimistic 1.2 2.1 2.8 4.6 9.3 22.3 22.8 51.3 82.4 190.0 Message 1.6 2.7 3.6 6.2 12.5 30.3 31 71.4 115.6 263.0

MiniCAM base 1.7 2.8 3.8 6.5 13.2 31.8 32.4 72.6 115.4 287.0

5th scenario 1.3 2.3 3.1 5 9.6 25.4 23.6 62.1 104.7 222.5

Scenario DICE

IMAGE 11.0 14.5 17.2 22.8 31.6 35.8 45.4 61.9 70.8 82.1 MERGE optimistic 7.1 9.2 10.8 14.3 19.9 22 27.9 36.9 42.1 48.8 Message 9.7 12.5 14.7 19 26.6 29.8 37.8 51.1 58.6 67.4

MiniCAM base 8.8 11.5 13.6 18 25.2 28.8 36.9 50.4 57.9 67.8

5th scenario 7.9 10.1 11.8 15.6 21.6 24.9 31.8 43.7 50.8 60.6

Scenario FUND

IMAGE -25.2 -15.3 -11.2 -5.6 0.9 8.2 10.4 25.4 39.7 90.3 MERGE optimistic -24.0 -12.4 -8.7 -3.6 2.6 8 12.2 27 41.3 85.3 Message -25.3 -16.2 -12.2 -6.8 -0.5 3.6 7.7 20.1 32.1 72.5

MiniCAM base -23.1 -12.9 -9.3 -4 2.4 10.2 12.2 27.7 42.6 93.0

5th scenario -24.1 -16.6 -13.2 -8.3 -3 -0.2 2.9 11.2 19.4 53.6



### Table 9.4. 2010 Global SCC Estimates at 5 Percent Discount Rate (2007$/ton CO 2 

### )

Percentile 1st 5th 10th 25th 50th Avg 75th 90th 95th 99th

Scenario PAGE

IMAGE 0.5 0.8 1.1 1.8 3.5 8.3 8.5 19.5 31.4 67.2 MERGE optimistic 0.3 0.5 0.7 1.2 2.3 5.2 5.4 12.3 19.5 42.4 Message 0.4 0.7 0.9 1.6 3 7.2 7.2 17 28.2 60.8

MiniCAM base 0.3 0.6 0.8 1.4 2.7 6.4 6.6 15.9 24.9 52.6

5th scenario 0.3 0.6 0.8 1.3 2.3 5.5 5 12.9 22 48.7

Scenario DICE

IMAGE 4.2 5.4 6.2 7.6 10 10.8 13.4 16.8 18.7 21.1 MERGE optimistic 2.9 3.7 4.2 5.3 7 7.5 9.3 11.7 12.9 14.4

EA-SCC.49Message 3.9 4.9 5.5 7 9.2 9.8 12.2 15.4 17.1 18.8

MiniCAM base 3.4 4.2 4.7 6 7.9 8.6 10.7 13.5 15.1 16.9

5th scenario 3.2 4 4.6 5.7 7.6 8.2 10.2 12.8 14.3 16.0

Scenario FUND

IMAGE -11.7 -8.4 -6.9 -4.6 -2.2 -1.3 0.7 4.1 7.4 17.4 MERGE optimistic -10.6 -7.1 -5.6 -3.6 -1.3 -0.3 1.6 5.4 9.1 19.0 Message -12.2 -8.9 -7.3 -4.9 -2.5 -1.9 0.3 3.5 6.5 15.6

MiniCAM base -10.4 -7.2 -5.8 -3.8 -1.5 -0.6 1.3 4.8 8.2 18.0

5th scenario -10.9 -8.3 -7 -5 -2.9 -2.7 -0.8 1.4 3.2 9.2

0 2000 4000 6000 8000 10000 12000 14000 16000‐25‐12114274053667992105118131144157170183196209222235248261274

All 2010, 5.0% All 2010, 3.0% All 2010, 2.5%



### Figure 9.8. Histogram of Global SCC Estimates in 2010 (2007$/ton CO 2 

### ), by Discount Rate*

* The distribution of SCC values ranges from -$5,192 to $66,116, but the X-axis has been truncated at approximately the 1 st and 99 th percentiles to better show the data.



### Table 9.5. Additional Summary Statisti cs of 2010 Global SCC Estimates

Discount

Rate 5% 3% 2.5%

Scenario Mean Variance Skewness Kurtosis Mean Variance Skewness Kurtosis Mean Variance Skewness Kurtosis

DICE 9.0 13.1 0.8 0.2 28.3 209.8 1.1 0.9 42.2 534.9 1.2 1.1

PAGE 6.5 136.0 6.3 72.4 29.8 3,383 .7 8.6 151.0 49.3 9,546.0 8.7 143.8

FUND -1.3 70.1 28.2 1,479.0 6.0 16,382.5 128.0 18,976.5 13.6 150,732.6 149.0 23,558.3

EA-SCC.50