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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.

The following documents are available as Adobe Acrobat PDFs. Download Adobe

Reader.

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

Printable Version

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Content Last Updated: 03/25/2010

Appliances and Commercial Equipment Standards: Fluorescent Lamp Ball... http://www2.eere.energy.gov/buildings/appliance_standards/residential/f...

1 of 1 3/25/2010 4:43 PM

EERE-2007-BT-STD-0016 COMMENT 20
 

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 Commercial Equipment Standards 

Washington, DC 20585 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 

EERE-2007-BT-STD-0016 COMMENT 20
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 Analyses.......................................................................................... 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 Non-Representative Product 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 Ballast 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 

EERE-2007-BT-STD-0016 COMMENT 20
LIST OF TABLES 

Table ES.2.1 Scope of Coverage for Fluorescent Lamp Ballast Rulemaking.................................3
 

Table ES.2.2 Product Classes for Fluorescent Lamp Ballasts.........................................................4
 

Table ES.2.3 Summary of Baselines and Candidate Standard Levels for Fluorescent 

Lamp Ballast Representative Product Classes.........................................................5
 

Table ES.2.4 Summary of Incremental Manufacturer Selling Prices Over the Baseline for 

Fluorescent Lamp Ballast Representative Product Classes .....................................6
 

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

Table ES.2.6 Annual Energy Consumption by Ballast Product Class............................................7
 

Table ES.2.7 Markups for Ballasts .................................................................................................8
 

Table ES.2.8 Life-Cycle Cost and Payback Period Results for Ballasts ........................................9
 

Table ES.2.9 Cumulative National Energy Savings for Ballasts Under the Existing
 

Technologies, Shift Scenario (2014–2044)............................................................16
 

Table ES.2.10 Cumulative National Energy Savings for Ballasts Under the Emerging
 

Technologies, Roll-Up Scenario (2014–2044) ......................................................17
 

Table ES.2.11 Cumulative NPV Results for Ballasts Under the Existing Technologies, 

Shift Scenario (2014–2044) ...................................................................................18
 

Table ES.2.12 Cumulative NPV Results for Ballasts 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 Shipments for Ballasts Operating Four-Foot MBP
 

Lamps (Commercial Sector, Existing and Emerging Technologies 

Scenarios)...............................................................................................................11
 

Figure ES.2.3 Base-Case Forecasted Shipments for Ballasts Operating Eight-Foot RDC 

HO Lamps (Excluding Sign Ballasts)....................................................................12
 

Figure ES.2.4 Base-Case Forecasted Shipments for Ballasts Operating Eight-Foot SP
 

Slimline Lamps ......................................................................................................12
 

Figure ES.2.5 Base-Case Forecasted Shipments for Ballasts Operating Four-Foot T5 

MiniBP SO and HO Lamps (Existing and Emerging Technologies 

Scenarios)...............................................................................................................13
 

Figure ES.2.6 Base-Case Forecasted Shipments for Ballasts Operating Four-Foot MBP
 

Lamps in the Residential Sector ............................................................................14
 

Figure ES.2.7 Base-Case Forecasted Shipments for Sign Ballasts Operating Eight-Foot 

RDC HO Lamps.....................................................................................................14
 

ES-ii 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 chapter 2 of the preliminary technical support document 

(TSD). 

Figure ES.1.1 presents a summary of the analytical 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 parties 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 

EERE-2007-BT-STD-0016 COMMENT 20
Figure ES.1.1 Flow Diagram of Analyses for the Fluorescent Lamp Ballast Rulemaking 

Process 

 ES-2 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

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 Conservation Act of 1975 (EPCA) direct DOE to 

determine whether to amend energy conservation standards for fluorescent 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 additional ballasts for consideration, 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 summarizes 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 characterizes 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

 

 

 

 

 

 

Table ES.2.2 Product Classes for Fluorescent Lamp Ballasts 

Ballast and Lamp Number of Lamps 

Type 

Starting 

Method* 

Ballast 

Factor** One Two Three Four Five Six 

High 1 2 3 4 5 6 

IS and RS Normal 7 8 9 10 11 12

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 

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

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 

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

4-Foot MBP and 2­

Foot U-Shaped 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 product efficiency, and (3) trends in product 

characteristics and retail markets. This information provides data and resource material 

throughout the analysis. 

DOE reviews literature and interviews manufacturers to develop 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 technologies and combinations of technologies manufacturers use to 

attain higher performance levels. In consultation with interested parties, DOE develops a list of 

technologies to be considered. The identified technologies initially include all those DOE 

believes are technologically feasible. 

 ES-4 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

ES.2.3 Screening Analysis 

DOE develops an initial list of options for enhancing efficiency from the technologies 

that the technology assessment identified as feasible. In consultation with interested parties, DOE 

reviews the list to assess whether the technologies are practicable to manufacture, install, and 

service; would adversely affect product utility or availability; or would have adverse impacts on 

health and safety. In the subsequent engineering 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 efficiency. 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 bill of materials pricing into 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 candidate standard level 

(CSL) in the engineering analysis. Table ES.2.4 presents the incremental MSP for each of these 

more efficient options. 

Table ES.2.3 Summary of Baselines and Candidate 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

Table ES.2.4 Summary of Incremental Manufacturer Selling Prices Over 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 Characterization 

The energy use characterization, which assesses the potential energy savings resulting 

from amended efficiency standards, provides the basis 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 input 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-Ballast 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 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 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

Table ES.2.6 Annual Energy Consumption by Ballast Product Class 

Representative Product Class 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 manufacturer 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 party in the distribution channel, as well as the 

appropriate sales tax. 

 ES-7 

EERE-2007-BT-STD-0016 COMMENT 20
Two types of distribution channels describe how most ballasts pass from the 

manufacturer to the end-user (Figure ES.2.1). The first distribution channel 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 ballast then passes 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 manufacturer sells the ballast to a 

distributor, who sells it to a contractor, who sells it to the end-user. 

Figure ES.2.1 Ballast Distribution Channels 

DOE developed separate markups for baseline products and for the cost increase 

associated with improvements required to produce more-efficient products. Table ES.2.7 

summarizes the markups developed 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 results in an increase in purchase price and a 

decrease in operating expenses. DOE analyzed the net effect of amended standards on consumers 

by evaluating the net LCC using the cost-efficiency relationship derived in the engineering 

analysis, as well as the energy costs derived from the energy use characterization analysis. All 

 ES-8 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

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 typically 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 installed 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 results. Table ES.2.8 presents the key findings. 

Table ES.2.8 Life-Cycle Cost and Payback 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-9 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

Renovation 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 consumer costs and savings, and future manufacturer 

cash flows for each ballast product class under consideration. DOE followed a three-step process 

 ES-10 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

to forecast ballast shipments. First, DOE used historical shipment data from the U.S. Census 

Bureau to estimate the total historical shipments 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 and new construction/renovation 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 from the 2006 installed 

stock based on 1990–2005 historical shipments. Estimated historic shipment numbers for ballasts 

exhibited some variation on a year-to-year basis. Preliminary assumptions regarding ballast 

lifetime and failure distributions 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 Shipments for Ballasts Operating Four-Foot MBP 

Lamps (Commercial Sector, Existing and Emerging Technologies Scenarios) 

 ES-11 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

0 

50,000 

100,000 

150,000 

200,000 

250,000 

300,000 

350,000 

Shipments 

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 Shipments for Ballasts Operating Eight-Foot RDC 

HO Lamps (Excluding Sign Ballasts) 

2,500,000
 

2,000,000
 

Shipments 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 Shipments for Ballasts Operating Eight-Foot SP 

Slimline Lamps 

 ES-12 

EERE-2007-BT-STD-0016 COMMENT 20
0 

5,000,000 

10,000,000 

15,000,000 

20,000,000 

25,000,000 

30,000,000 

35,000,000 

40,000,000 

45,000,000 

Shipments 

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 Shipments for Ballasts Operating Four-Foot T5 

MiniBP SO and HO Lamps (Existing and Emerging Technologies Scenarios) 

 ES-13 

EERE-2007-BT-STD-0016 COMMENT 20
 

0 

5,000,000 

10,000,000 

15,000,000 

20,000,000 

25,000,000 

30,000,000 

35,000,000 Shipments 

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 Shipments 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 

4,500,000 

Shipments 

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 

EERE-2007-BT-STD-0016 COMMENT 20
energy savings due to standards, (3) increased total 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 difference between national energy consumption in 

the base case (without amended energy conservation standards) and in each higher efficiency 

standard case. DOE estimated energy consumption and savings based on site energy and 

converted the electricity consumption 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 cumulative NES results under the existing 

technologies shift scenario, which reflects the upper 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 the 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 savings 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

Table ES.2.9 Cumulative National Energy Savings for Ballasts 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

Table ES.2.10 Cumulative National Energy Savings for Ballasts 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 between total savings in operating costs and 

increases in total installed costs in the base case 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 

EERE-2007-BT-STD-0016 COMMENT 20
Table ES.2.11 Cumulative NPV Results for Ballasts 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 

EERE-2007-BT-STD-0016 COMMENT 20
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, shipments, and research and development 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

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 evaluates the effects of energy conservation 

standards on various national 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 employment (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 energy 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 that 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 following ballasts in its scope of coverage: 

(1) ballasts that operate one, two, three, four, five, or six 4-foot medium bipin lamps with 

a rated wattagea

 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 

EERE-2007-BT-STD-0016 COMMENT 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 voltage at or between 120V and 277V; 

(5) ballasts that operate one or two 4-foot miniature bipin standard 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 miniature 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 medium bipin lamps with 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 that are designed 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 extending 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) 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. Using the statutory criteria described above (i.e., type of 

energy consumed or capacity or other performance-related feature affecting efficiency), DOE 

eliminated many of these. DOE defined 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 ES.2.2. DOE seeks 

comments on these product classes – including comments on the appropriate 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 option eliminated during the screening analysis. 

ES.3.6 Candidate Standard Levels for Representative Product Classes 

DOE tested many manufacturers’ product offerings for BEF and ballast efficiency to 

determine their efficiency. DOE identified the most prevalent BEF values in the range of 

 ES-21 

EERE-2007-BT-STD-0016 COMMENT 20
available products and established CSLs based on those products. Within 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 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 maximum technologically feasible ballast efficiency 

and its associated MSP. 

ES.3.8 Manufacturer Production Costs 

To estimate MPCs for fluorescent lamp ballasts, DOE conducted a teardown analysis for 

many high-volume ballasts. Given the large number 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 manufacturer markups. DOE requests comments on its 

estimates of manufacturer production 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 classes and compared these values to the representative classes 

to create scaling relationships. These scaling relationships were used to create CSLs for those 

product classes not directly analyzed. DOE requests 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 manufacturers of multiple, product-specific regulatory 

actions in the NOPR. DOE invites comment on regulations applicable to ballast manufacturers 

that contribute to their cumulative regulatory burden. 

 ES-22 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

In addition to existing regulation, several possible upcoming regulations could affect the 

engineering and life-cycle cost analysis for fluorescent lamp ballasts. DOE requests comments 

on how safety requirements for system interconnects, safety requirements for lamp end-of-life 

protection, electromagnetic field requirements, and hazardous material 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 product 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 operating 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 that PS ballasts operating 

four-foot medium bipin lamps in the commercial sector are controlled with occupancy sensors, 

resulting in reduced annual operating hours. However, 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 chapter 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 wholesaler 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. 

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EERE-2007-BT-STD-0016 COMMENT 20
ES.3.14 Electricity Prices for LCC and PBP Analyses 

DOE estimates electricity prices for commercial, 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 demand 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 observed that energy efficient ballasts should operate cooler, 

which would result in longer operating life. Another commenter remarked that ballasts are 

generally operating at higher temperatures due to the trend toward smaller fixtures and ballast 

enclosures. DOE acknowledges the general trend toward smaller fixtures and ballast enclosures, 

and assumed ballast operating temperatures equal to or greater than those for current ballast 

designs, with no extended life for energy efficient 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 ballast 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 type analyzed, which required 

disaggregating the Census data and adjusting it to include estimated non-NEMA shipments. 

DOE seeks actual, disaggregated ballast and residential fixture shipments data to help verify its 

shipments analysis. See chapter 2 of the preliminary TSD for details. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

ES.3.18 Shipment Trends 

DOE modeled ballast purchasing events (e.g., replacement and new construction) and 

applied growth rate, replacement rate, and emerging technologies (i.e., solid-state lighting) 

penetration rate assumptions to develop annual shipment projections. DOE based future ballast 

shipment trends on manufacturer interviews and market trends 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 greenhouse 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 lamp 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 operate 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 invites 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 identification 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 Emission Reductions 

DOE will conduct an environmental assessment as part of the next phase of the standards 

rulemaking, the NOPR. The primary environmental effects of energy conservation standards for 

ballasts are to reduce 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 (CO2), sulfur dioxide (SO2), nitrogen oxides (NOX), and mercury (Hg). 

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EERE-2007-BT-STD-0016 COMMENT 20
 

DOE also plans on monetizing the emission reductions due to standards consistent with methods 

used in recent DOE standards rulemakings pertaining to commercial clothes washers and other 

consumer products and commercial equipment. For example, in the case of CO2, the most recent 

interagency estimates of the potential global benefits resulting from reduced CO2 emissions in 

2010 were $4.7, $21.4, $35.1, and $64.9 per metric ton in 2007 dollars. DOE invites comments 

on the approaches for monetizing the emission savings due to energy conservation standards. 

 ES-26 

EERE-2007-BT-STD-0016 COMMENT 20
CHAPTER 1. INTRODUCTION 

TABLE OF CONTENTS 

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

1.2 OVERVIEW OF THE APPLIANCES AND COMMERCIAL EQUIPMENT 

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

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

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

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

LIST OF TABLES 

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

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CHAPTER 1. INTRODUCTION 

1.1 PURPOSE OF THE DOCUMENT 

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

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

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

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

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

preliminary analysis.a 

1.2	 OVERVIEW OF THE APPLIANCES AND COMMERCIAL EQUIPMENT 

STANDARDS PROGRAM 

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

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

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

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

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

document. 

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

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

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

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

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

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

seven factors: 

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

products subject to the standard; 

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

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

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

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

imposition of the standard; 

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

imposition of the standard; 

a

 The preliminary analysis can be found here: 

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

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

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

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

(6) the need for national energy conservation; and 

(7) other factors the Secretary considers relevant. 

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

1.3 OVERVIEW OF FLUORESCENT LAMP BALLAST STANDARDS 

Amendments to EPCA in the National Appliance Energy Conservation Amendments of 

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

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

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

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

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

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

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

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

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

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

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

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

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

under 10 CFR 430.32(m)(3). 

Congress promulgated new energy conservation standards for certain fluorescent lamp 

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

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

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

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

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

b

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

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

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

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

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

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

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

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

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

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

pumps, and packaged terminal air conditioners and heat pumps. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

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

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

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

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

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

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

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

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

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

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

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

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

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

 (3) ballasts with a power factor of 

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

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

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

(m)(7). 

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

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

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

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

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

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

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

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

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

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

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

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

standards analysis is applicable. 

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

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

c

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

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

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

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

temperatures of negative 20 degrees F or less. 

d

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

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

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

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

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

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EERE-2007-BT-STD-0016 COMMENT 20
should be made applicable to additional fluorescent lamp ballasts as stated under section 

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

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

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

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

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

consumption. 

1.4 PROCESS FOR SETTING ENERGY CONERVATION STANDARDS 

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

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

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

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

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

standards rulemaking. 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

described above. 

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

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

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

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

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

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

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

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

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

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EERE-2007-BT-STD-0016 COMMENT 20
revised analysis of the impacts of standards; DOE’s weighing of the impacts; the standards 

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

Table 1.4.1 Analyses Under the Process Rule 

Preliminary Analysis NOPR Final Rule* 

Market and technology assessment Revised ANOPR analyses Revised analyses 

Screening analysis Life-cycle cost sub-group analysis 

Engineering analysis Manufacturer impact analysis 

Energy use characterization Utility impact analysis 

Product price determination Employment impact analysis 

Life-cycle cost and payback period analyses Environmental assessment 

Shipments analysis Regulatory impact analysis 

National impact analysis 

Preliminary manufacturer impact analysis 

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

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

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

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

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

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

PDF copy of the framework document is available at 

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

011408.pdf 

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

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

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

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

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

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

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

other material associated with the public meeting are available at 

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

html 

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

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

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

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

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

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

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

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

electricity rates. Stakeholder comments submitted during the framework document comment 

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EERE-2007-BT-STD-0016 COMMENT 20
 

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

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

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

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

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

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

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

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

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

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

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

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

contains a complete copy of the interview guide. 

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

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

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

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

during the NOPR phase. 

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

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

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

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

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

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

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

s.html 

1.5 STRUCTURE OF THE DOCUMENT 

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

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

Chapter 1 Introduction: provides an overview of the appliance standards 

program and how it applies to the rulemaking for fluorescent lamp 

ballasts, and outlines the structure of the document 

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

overview of each analysis, and discusses comments received during 

the framework document public meeting comment period. 

Chapter 3 Market and Technology Assessment: characterizes the fluorescent 

lamp ballast market and the technologies available for increasing 

ballast efficacy factor and outlines product classes 

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EERE-2007-BT-STD-0016 COMMENT 20
 

Chapter 4 Screening Analysis: determines which technology design options are 

viable for consideration in the engineering analysis 

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

analysis and discusses how manufacturer costs and selling prices relate 

to ballast efficacy factor 

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

developing energy use estimates for fluorescent lamp ballasts 

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

markups manufacturer selling price to installed customer prices. 

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

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

without higher energy conservation standards 

Chapter 9 Shipments Analysis: discusses the methods used for forecasting 

shipments with and without higher energy conservation standards 

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

consumption, efficiency of new ballasts, and annual fluorescent lamp 

ballast sales in the absence or presence of new standards 

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

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

lamp ballast consumers and compares the LCC and PBP of product 

with and without higher efficiency standards for these consumers 

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

study the effects of standards on the finances and profitability of 

fluorescent lamp ballasts, and presents preliminary manufacturer 

impact analysis results 

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

effects of standards on electric utilities 

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

analyze the effects of standards on national employment 

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

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

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

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

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

conservation standards 

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

abbreviations used throughout the TSD. 

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

Federal Regulations: provides a set of existing statutory and 

regulatory definitions and requirements for fluorescent lamp 

ballasts 

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

manufacturer selling price of ballasts 

Appendix 5B T5 Magnetic Miniature Bipin Magnetic Baseline Ballasts: 

describes the methodology behind developing T5 magnetic ballast 

model 

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

the fluorescent lamp ballast engineering analysis 

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

ballasts and estimates their potential efficiency impact 

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

Spreadsheet 

Appendix 10A User Instructions for Shipments and NIA Spreadsheet 

Appendix 12A Preliminary Manufacturer Interview Guide 

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

Executive Order 12866 

1-8 

EERE-2007-BT-STD-0016 COMMENT 20
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 Fluorescent 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-Regulatory 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 Product Classes ......................................................................... 2-36
 

2.6.3	 Baseline Ballasts and Candidate Standard Levels Analyzed............................. 2-37
 

2.6.4	 Results................................................................................................................ 2-40
 

2.6.5	 Scaling Between Product 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 Subgroup Analysis ...................................................................... 2-56
 

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EERE-2007-BT-STD-0016 COMMENT 20
 

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 Emissions 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 this 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 detail on key issues 

identified in the executive summary. Finally, chapter 2 provides citations and crossreferences to the other chapters of the preliminary 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 technologies and designs that improve ballast 

efficiency; 

•	 a screening analysis that reviews technology 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) and 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 throughout 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 purchase 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; 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

•	 a national impact analysis (NIA) that assesses the aggregate impacts at the 

national level of potential energy 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 include those listed below: 

•	 an LCC subgroup analysis that evaluates the economic impacts on identifiable 

groups of customers of fluorescent lamp ballasts, 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 calculates 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 ballasts and reduced customer spending on 

energy; 

•	 an environmental assessment to provide estimates of the effects of amended 

energy conservation standards on emissions of carbon (CO2), sulfur dioxide 

(SO2), nitrogen oxides (NOX), 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 framework 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. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

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 key comments DOE received, describes DOE’s 

responses, and summarizes any significant changes in the analytical approach made since 

DOE published the framework document. Lastly, in the executive summary of the 

preliminary TSD, DOE identifies issues on which 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 Conservation Amendments of 1988 (NAECA 1988), Pub. 

L.100-357, established energy conservation standards 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 determine 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 applicable to additional fluorescent 

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

On September 19, 2000, DOE published a final rule in the Federal Register (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 fluorescent lamp ballasts. These standards 

eliminated certain “magnetic” ballasts, which operate lamps at line frequency (60 Hertz) 

and are less efficient than electronic ballasts, which operate lamps 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 Regulations (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, dishwashers, 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. “Part 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). 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

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 percent or less of its maximum output; 

•	 ballasts designed for use with two F96T12HO lamps at ambient temperatures 

of -20 degrees Fahrenheit (°F) or less and for use in an outdoor sign or ballasts 

designed for use with two F96T12HO/ES lamps at ambient temperatures of 

20°F or less and for use in an outdoor sign;e 

•	 ballasts with a power factor of less than 0.90 and designed and labeled for use 

only in residential building applications; and 

• replacement ballasts as defined 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 fluorescent 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 criteria to be considered a 

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

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

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

excluded. (10 CFR 430.32(m)(4)(ii)(A)) See appendix A for the exact language of the exclusion for 

replacement ballasts. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

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

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

published a 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 requirement is applicable. 

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

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

whether the standards should apply to additional 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 energy 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 lamp 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 those 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 proposed a test procedure to measure only 

standby mode energy consumption. Standby 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 lamp ballast energy conservation standards 

rulemaking. The comments from this meeting prompted DOE to initiate a separate 

rulemaking to revise the existing test procedure for active mode energy consumption. 

The section contains comments regarding the active mode test procedure that are also 

relevant to this energy conservation standards 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

observed on the market today. The measurement 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 several sources, such as lamp manufacturing 

variations (as the test procedure requires photometric measurements), lamp filament 

heating, and differences between high-frequency 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 are luminaire manufacturers. (Acuity Brands 

Lighting, Public Meeting Transcript, 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 metric. (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 have such standards. (NEMA, No. 11 at p. 3) 

The Joint Comment stated that any alternate 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. (NYSERDA, 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 RSE metric would reflect individual lamp 

characteristics; thus, these metrics could be used to compare ballasts that operate 

different lamp types. NYSERDA supported a metric that could be normalized to allow 

for comparison among different ballast types. (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 manufacturing variability of lamps used during 

ballast testing, can interact to produce measurement uncertainty. As discussed in the 

active mode test procedure NOPR, DOE is proposing 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). 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

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 procedure that requires the measurement of an 

alternate metric unrelated to lamp lumen output, along with a correlation to BEF that 

takes lamp filament effects into account. (NEMA, Public Meeting Transcript, No. 9 at pp. 

32, 37-38) DOE is investigating the implementation of an alternate metric and a set of 

correlation functions so that BEF values can 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 encourage 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 and 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 ballasts that were labeled 

as compliant in the marketplace. (Acuity Brands Lighting, Public Meeting Transcript, 

No. 9 at pp. 88-89; Osram Sylvania, Public Meeting Transcript, No. 9 at p. 90) Acuity 

Brands Lighting suggested that DOE should share the legal responsibility for enforcing 

compliance with standards. (Acuity Brands Lighting, 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 standards 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 energy 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 prescribed a separate standby mode test 

procedure and determined that fluorescent lamp ballasts do not exhibit off mode energy 

use. In addition, DOE stated that the only 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 section 310(3) of EISA 2007 direct that 

any final rule establishing or revising a standard 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 separate 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 efficiency 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 standby 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 energy 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 consumption 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, Public 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 ballast currently being considered for amended 

2-8 

EERE-2007-BT-STD-0016 COMMENT 20
 

energy conservation standards, DOE tentatively 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 whether current standards should 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 amended 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 promulgated 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 covered ballasts that operate F40T12, F96T12, and 

F96T12HO lamps, but included several exemptionsh

. Additional energy conservation 

standards from the 2000 Ballast Rule apply to replacement F40T12 ballasts and F34T12 

ballasts and take effect in 2010. EPACT 2005 prescribed energy conservation standards 

specific to ballasts designed for lower wattage applications that have an initial effective 

date of July 1, 2009. These prescribed standards cover ballasts designed to operate 

F34T12 lamps, F96T12/ES lamps, and 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 which 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 fluorescent 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 “fluorescent 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” fluorescent 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 fluorescent 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 amended 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 considers potential energy savings, 

technological feasibility and economic justification when determining the scope of 

coverage. DOE assessed the potential energy savings from market share estimates, 

potential ballast designs that improve ballast efficiency, and 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 manufacturer 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.” 

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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 energy 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 improvements 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 independently conducting its preliminary determination analysis, 

DOE considered comments on the additional ballasts it should cover. The following 

subsections provide a discussion of the ballasts considered for coverage and related 

comments. DOE invites comments on the rationale for coverage presented in this 

preliminary determination. DOE also invites comments on the scope of coverage 

proposed in this preliminary determination. 

2.3.4 Analysis of Individual Ballast Types 

As stated in section 2.2.1, current ballast standards cover ballasts 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 ballasts 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 types that operate the 

lamps covered in the recently published rulemaking for general service fluorescent lamps. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

The scope of coverage outlined in the energy conservation standards rulemaking for 

general service fluorescent and incandescent 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 lamps with a rated wattage ≥ 25 and < 28; 

•	 4-foot T5 miniature bipin straight-shaped 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 the 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 savings (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 previous 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 designed for foreign markets, such as 347V 

ballasts for the Canadian market. DOE’s preliminary determination of scope includes 

ballasts designed only for operation within 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 determination of technological feasibility for a 

ballast product. (NEMA, Public Meeting Transcript, No. 9 at p. 116) DOE understands 

that a product contained in a mature ANSI standard would likely belong to a welldeveloped product line, but believes that investigating product offerings currently sold by 

manufacturers is a better method to determine technological feasibility. DOE establishes 

technological feasibility by understanding the range 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. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

energy conservation standards are technologically 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 feasibility. The following sections discuss each 

additional ballast type and determine whether each type should be extended coverage. 

Dimming ballasts. DOE received comments from ASAP at the framework public 

meeting and in the Joint Comment recommending expanding the scope of coverage to 

include dimming ballasts. (ASAP, Public Meeting Transcript, No. 9 at pp. 62, 69, 108; 

Joint Comment, No. 12 at pp. 2-3) The current 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, although 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 rulemaking 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 standards 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 has determined it is not precluded from 

considering previously exempt ballasts as “additional fluorescent ballasts.” Data from the 

2005 U.S. Census reveal that dimming ballasts have less than 1 percent market share.k 

Although some manufacturers do not report their shipments, after interviewing ballast 

manufacturers, DOE concluded the current market share is likely close to the market 

share indicated by the U.S. Census. Therefore, DOE has tentatively determined not to 

include these ballasts in the scope of coverage for this rulemaking 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 standards and currently represent a small ballast 

market segment. Therefore, DOE does not plan 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. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

Mini-ballasts. The Joint Comment requested that DOE consider mini-ballasts 

used in under-cabinet fixtures. (Joint Comment, 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 found 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. The 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 because 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 lamps 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 conservation standards rulemaking. Cold temperature 

ballasts for outdoor signs were originally excluded 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 rulemaking. (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 could 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 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

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

justified. 

Cold temperature ballasts for outdoor signs are typically designed to operate a 

range of lamp lengths and numbers of lamps. Based on product catalogs and 

conversations with manufacturers, DOE found that sign ballasts can be designed to 

operate HO lamps between 1.5 and 10 feet and between 1 and 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 encouraged 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, NEMA 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 Transcript, 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 rapidly taking market share from metal halide 

systems used in high bay industrial applications. DOE concluded that T5 ballasts are a 

growing market segment of significant size and represent significant potential energy 

savings. In its interviews, DOE learned that some ballast manufacturers 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 savings. 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 technologically 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 become 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 wattages 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 ballasts 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. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

Low power factor ballasts. Low power factor ballasts have a power factor less 

than 0.9 and are typically used in residential 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 evaluate 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 removed due to improvements in electronic ballast technology 

and reduced production costs. Additionally, the 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 magnetic ballasts held steady at about 7 percent between 1995 and 

2002, and then decreased to about 1.5 percent in 2005. DOE believes the 2005 market 

share and total shipments to be much higher. Electronic ballasts are a common option for 

residential fluorescent lighting fixtures, but they are not reported in the Census data. 

Also, many residential ballasts are manufactured overseas by foreign companies that do 

not share shipment data with the U.S. Census. Because of these omissions, DOE believes 

residential ballasts represent a sizeable portion of the overall ballast market. 

Residential ballasts do exhibit variation in energy efficiency. Residential ballasts 

can be magnetic or electronic and also exist 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 the 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 subject to standards in the 2009 Lamps Rule. 

DOE received several comments in support of covering 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, Public 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-shaped lamps exhibit a range of efficiencies, 

thereby satisfying the technological feasibility requirement. Partly because of energy 

conservation standards promulgated for T12 ballasts, shipments of T8 ballasts have been 

increasing. T8 ballasts are being purchased and installed in applications previously 

popular for T12 systems. There is potential for significant energy savings by regulating 

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EERE-2007-BT-STD-0016 COMMENT 20
 

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-wattage lamps. (Joint 

Comment, No. 12 at p. 3) After investigating the ballast market, DOE agrees. DOE does 

not want to create a potential loophole where the standard-wattage 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 operates 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 bases 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 T12 ballasts had about 3 percent. While the 

market share for 8-foot SP slimline T8 ballasts 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 addition, 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 ballasts 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 sign 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 comments 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 covering these ballasts 

will prevent potential negative substitution effects. There is a range of efficiency levels 

for 8-foot T8 HO ballasts currently in the market; therefore, energy conservation 

standards are technologically feasible. In addition, preliminary analysis in the LCC and 

NIA demonstrated the potential for significant 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 length of 48 inches, a rated wattagel

 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 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 contact 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 miniature 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; 

l

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

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EERE-2007-BT-STD-0016 COMMENT 20
(6) ballasts that operate one, two, three, or four straight-shaped lamps 

(commonly referred to as 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-shaped lamps 

(commonly referred to as 4-foot medium 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 high 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 outside of the covered range. 

2.4 MARKET AND TECHNOLOGY ASSESSMENT 

When DOE begins an energy conservation standards rulemaking, it gathers 

information that provides an overall picture of the market for the products concerned, 

including the nature and market characteristics 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, shipments of covered products, regulatory and nonregulatory programs, and technologies that could be used to improve the efficiency of 

fluorescent lamp ballasts. This information serves as a resource throughout the 

rulemaking. 

DOE reviewed existing literature and spoke with manufacturers to gain an 

understanding of the fluorescent lamp ballast industry in the United States. Industry 

publications (e.g., manufacturer catalogs, trade journals), government agencies, and trade 

organizations provided the bulk of the information. Using this information, DOE assessed 

the overall state of the industry, ballast manufacturing and market shares, shipments by 

ballast type, general technical information on ballasts, and industry trends. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

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 assessment (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 information and data supplied by manufacturers and 

other interested parties. The market assessment also includes information about 

manufacturers of fluorescent lamp ballasts, product classes, 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 Industrial 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 addition to ballasts listed under this rulemaking, 

the lighting divisions of several of these companies 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 market is predominantly supplied by large 

manufacturers, DOE intends to conduct a study 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 lamp ballasts under the North American 

Industry Classification System product code 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. 

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names and contact information for any small businesses that manufacture fluorescent 

lamp ballasts and should be consulted before DOE publishes a NOPR. 

2.4.1.2 Product Classes 

In general, when evaluating and establishing energy conservation standards, DOE 

divides covered product into classes by (1) the type of energy used; (2) the capacity of the 

product; or (3) any other performance-related feature that affects energy efficiency and 

justifies different standard levels, considering factors such as consumer utility. (42 U.S.C. 

6295(q)) Different energy conservation standards may apply to different product classes. 

In the framework document, DOE considered amending the existing product 

classes for fluorescent lamp ballasts. DOE believed that the existing class divisions did 

not properly account for expected market changes 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 several comments on its approach to defining 

product classes. 

The Joint Comment argued that DOE should 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 required to satisfy the proposed scope 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 diameter. (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 measurement to a reported BEF value. Though 

DOE did not consider product classes for fluorescent lamp ballasts in the context of an 

RSE standard, DOE did consider the four product 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) the 

lumen 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 application for which other ballasts 

are not suitable. The potential class-setting factors DOE considered for the preliminary 

analysis are addressed below. 

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The fluorescent ballasts considered for coverage are designed to operate lamps with 

lengths of 4 or 8 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 length 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 lamps and 4-foot 

lamps are not always substitutable for each other. 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 that 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 separate product classes based on the 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 mode test procedure NOPR), DOE found that 

ballasts with high or low ballast factors have lower BEFs than ballasts with a normal 

ballast factor.n

 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-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 effect 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 systems with different lumen packages for 

different applications was also observed for ballasts that operate certain types of lamps. 

For example, high output systems may be installed in certain high-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. 

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has tentatively decided to establish 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 ballasts for T8 and T12 lamps in the same 

product class because T8 systems are inherently 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 believe that this alone justifies creating separate product 

classes for ballasts 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-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 include ballasts that operate T8 and T12 lamps 

in the same product class. 

However, DOE has decided to establish a separate product class for ballasts that 

operate T5 lamps. All else being equal, 4-foot T5 ballasts 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 classes for ballasts that operate T5 lamps. 

DOE received several comments encouraging the consideration of more than just 

ballast efficiency when creating product classes. 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 classes 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 each consumer subgroup could be analyzed separately. 

Thus, for example, the LCC results are reported separately for baseline ballasts that operate T8 and T12 

lamps. 

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NEMA, No. 11 at p. 5) For example, programmed 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 programmed 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 harvesting 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, 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. 

As DOE did not extend coverage to dimming ballasts in this preliminary analysis 

(section 2.3.4), DOE did not study how to incorporate daylight harvesting into a ballast 

efficiency metric. Should dimming 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, Acuity Brands Lighting commented that if 

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

residential market and its consumers are very different from their commercial 

counterparts. (Acuity Brands Lighting, Public Meeting Transcript, No. 9 at pp. 110-111) 

As discussed in section 2.3, DOE has initially included them in its expanded scope of 

coverage. As discussed in chapter 3, separate 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) power factor requirements. These differing 

requirements between commercial and residential 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 applications. Therefore, DOE has 

tentatively decided to establish a separate product classes for ballasts that operate in the 

residential sector and commercial sector. 

Ballasts that are designed for use in cold 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 classified 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 numerous 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 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 initially established 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 operate at multiple input voltages (e.g., 120V and 

277V). To accommodate multiple voltages, 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 serve as 

replacements for multiple ballasts. This allows distributors to stock fewer types of 

ballasts and allows contractors to keep fewer on hand for maintenance. Consolidation of 

products creates economies of scale for manufacturers, 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 voltage and found that there was 

not a significant difference in BEF between the two. Therefore, DOE does not consider 

operating at multiple voltages to be a factor in determining 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 more 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 

Ballast and Lamp Number of Lamps 

Type 

Starting 

Method 

Ballast 

Factor One Two Three Four Five Six 

High 1 2 3 4 5 6 

IS and RS Normal 7 8 9 10 11 12

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 

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

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 

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

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 

Residential Ballast, 4­ IS and RS All 57 58 59 60 N/A N/A 

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 from 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 representative 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 ballasts were shipped in the United States in 

2005.p

 The U.S. Census data is organized into 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. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

magnetic versus electronic type ballasts. Under each technology type, the shipments are 

categorized by a variety of characteristics including 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 characteristics. The shipment data does not 

include specific information for every permutation 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-ballast 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 increase in shipments, partly because F54T5HO 

ballasts are being used as substitutes for high 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, NAECA 1988 expanded DOE’s authority to 

regulate the energy efficiency of several products, including fluorescent lamp ballasts. 

NAECA 1988 prescribed standards and required DOE to conduct two rulemakings on 

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fluorescent lamp ballasts. The first of these two rulemakings was completed in 2000 (the 

2000 Ballast Rule); the second is this rulemaking. In addition, EPACT 2005 prescribed 

energy conservation standards for additional fluorescent lamp ballasts. 

In Canada, the Natural Resources Canada (NRCan) Office of Energy Efficiency 

regulates the energy efficiency of fluorescent 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 promulgated 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 European Parliament 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. 

2.4.2 Technology Assessment 

In the technology assessment, DOE identifies technology options that appear to be 

a feasible means of improving product efficiency. This assessment provides the technical 

background and structure on which DOE bases its screening and engineering analyses. 

The following discussion provides an overview 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 discussion 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 designs. 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; NEMA, Public Meeting Transcript, No. 9 at 

p. 113) DOE agrees that cathode cut out technology can be used to increase the efficiency 

of a ballast by removing filament heating after the lamp has started. Therefore, DOE is 

considering this a method to improve a ballast’s BEF in the 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 electronic ballast efficiency level for all ballasts 

when DOE proposes a standard in the fluorescent lamp ballast NOPR. 

NEMA commented that the use of integrated circuits by themselves do not 

directly influence ballast efficacy 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 components should be considered a technology 

option because these components can reduce energy loss. NEMA also noted that DOE 

should evaluate the cost impact of such 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 reduce 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 ballasts would increase ballast losses. (NEMA, 

No. 11 at p. 4; NEMA, Public Meeting Transcript, 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 can increase a ballast’s 

BEF and therefore maintains improved circuit designs as a technology option. 

In discussing improved circuit designs, NEMA stated that it was unaware of any 

emerging technology that promises to lower ballast losses while maintaining the same 

level of performance as today’s state-of-the-art ballast designs. (NEMA, Public Meeting 

Transcript, No. 9 at pp. 114, 118; NEMA, No. 11 at p. 4) DOE appreciates NEMA’s 

comment on the existence of emerging technologies. 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 

q

 International Rectifier. International Rectifier Introduces Robust 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. 

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

DOE invites comments on all of the technology 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 assessment. In the context of commenting on 

technology options, DOE also requests information 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 considers 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 distinguishably 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 options to consider further and which options to 

screen out. DOE consults with industry, technical experts, and other interested parties in 

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EERE-2007-BT-STD-0016 COMMENT 20
 

developing a list of design options. DOE then applies the following set of screening 

criteria to determine which design options are 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 prototypes to be technologically feasible. 

•	 Practicability to Manufacture, Install, and Service: If mass production of a 

technology in commercial equipment and reliable installation and 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 performance 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 consider technology options with significant 

adverse impacts on health and safety. (NEMA, 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 technology 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 screening analysis, NEMA stated that the only 

technologies that have been shown to be practical 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 available only for those products that have been 

commercially available. (Acuity Brands Lighting, Public Meeting Transcript, No. 9 at pp. 

118-119) ASAP disagreed, arguing that DOE should not screen out a technology based 

on whether that technology has gained market acceptance. (ASAP, Public Meeting 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

Transcript, No. 9 at p. 119) NYSERDA also noted 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 application. (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 ballast efficiency by employing an inductor 

composed of laminated sheets of amorphous steel did not meet the screening criteria. 

DOE screened out this technology option because this method increases the size and 

weight of the ballast. Therefore, DOE believes this option is not practicable to 

manufacture, install, and service. Employing 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 option 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 option is technologically feasible or has 

adverse impacts on health or safety because it is not commercially available. 

In summary, after examining all of the 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 the energy efficiency of ballasts. The 

relationship 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 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 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 preliminary TSD). Additional inputs include cost 

and efficiency data derived from the physical teardowns and test data from independent 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

labs. The primary output of the engineering analysis 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 determine customer prices for each product by applying the 

appropriate distribution channel markups. 

2.6.1 Preliminary Engineering Analysis Approach 

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; or (3) the 

reverse engineering cost-assessment approach, 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 meeting, DOE proposed using an efficiency 

level approach that included basing its determination of the end-user retail prices for 

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

 DOE received 

several comments on this methodology. At the public 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 Brands 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 components 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 estimating 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 observation of the components), DOE conducted 

teardowns for only unpotted ballasts and ballasts removed from 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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EERE-2007-BT-STD-0016 COMMENT 20
 

 

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 product has multiple product classes, 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 classes to other product classes. 

Baseline ballasts: For each representative product class, DOE establishes baseline 

ballasts. The baseline serves as a reference 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 energy conservation standards 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 lowest 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 ballast 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 voltage to characterize the most common 

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

consideration of different ballast types and their associated consumer economics. 

Candidate lamp-and-ballast designs: DOE selects commercially available ballasts 

with a higher BEF as replacements for each baseline ballast in the representative product 

classes by considering the design options identified in the technology 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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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

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 results are presented in appendix 5C. 

Because fluorescent lamp ballasts are designed to operate fluorescent lamps, DOE 

pairs each ballast with the most common fluorescent lamp in its respective product class. 

DOE develops the engineering analysis based on two substitution cases. In the first case, 

the consumer is not allowed to change the spacing 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 only 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 criteria are used in commercially available 

ballasts or working prototypes and therefore 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 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 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 the market. DOE requests comments on this 

analysis. 

NEMA argued that DOE should not establish 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 Meeting 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. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

and considers proprietary designs in its engineering analysis only if there are other 

technology pathways to meet that efficiency level. DOE does not regard a standard level 

that can be met by only one proprietary design to be economically justified. DOE 

believes, however, that no CSL in this rulemaking requires the use of a proprietary 

technology. DOE requests comments on its conclusions 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 describe 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 efficiency 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 technology assessment (preliminary TSD chapter 

3), DOE revised the existing product classes for 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 MBP and 2-foot U-shaped lamps), DOE choose to analyze 

multiple representative product classes. DOE based the representative product classes on 

the most common lamp-and-ballast configurations. Although DOE did not create a 

separate engineering analysis for every product class, DOE established standards for 

these product classes based on the representative product classes directly analyzed. For 

instance, DOE extended its proposal for ballasts 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 determining an appropriate scaling factor. Section 2.6.5 and chapter 5 

of the preliminary TSD provide more information on extending standards to the product 

classes DOE did not analyze. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

 

 

 

 

 

Table 2.6.1 Representative and Scaled Product Classes for Fluorescent Lamp 

Ballasts 

Ballast and Lamp Number of Lamps 

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 Scaled 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. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

DOE considered the ballast’s characteristics 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 factor (BF), input power, BEF, and whether the ballast can 

operate at multiple voltagesv (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 products and established CSLs based on those 

products. Because the baseline ballasts have different BEF values 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 efficient 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 requirements 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 and RS 4-foot MBP product class. For this product class, 

DOE chose to analyze two baseline ballasts. Census data indicates that 2001 shipments of 

4-foot and 2-foot U-shaped MBP T12 ballasts represented 14 percent of all shipments, 

while 4-foot and 2-foot U-shaped MBP T8 ballasts represented 86 percent of all 

shipments.w Therefore, DOE analyzed both a T12 and 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 this 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 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 

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 electronic 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. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

DOE also chose a ballast that has an input voltage of 277V ballast because the majority 

of ballasts operate in commercial 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 ballast 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 Two-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 electronic ballast, improvements required 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 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 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

 

 

This level affects 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: 92.0 percent 

This level again affects both baseline ballasts and represents the maximum 

technologically feasible level. This level represents a modest improvement in efficiency 

over CSL2. Ballasts at this level again use slightly better components 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 representative 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 evaluated multiple baseline ballasts for the relevant 

product classes to provide a comprehensive understanding of the consumer economics. 

DOE based its engineering analysis on two substitution cases. In the first case, the 

consumer is not allowed to change the spacing 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. Percentage change in mean lumen 

output is show in each table below. 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, 

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: 

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EERE-2007-BT-STD-0016 COMMENT 20
MLOBaseline NormalizedInputPower = ∗ InputPower S tan dardsCase S tan dardsCase MLOS tan dardsCase 

Equation 2.6.1 

NormalizedInputPowerS = Input power of the standards-case system that tan dardsCase 

matches the light output of the baseline system 

MLOBaseline = Mean lumen output of the baseline system 

MLOS = Mean lumen output of the standards-case system tan dardsCase 

InputPowerS 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 the 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 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. 

For all F32T8 ballasts, DOE generated an MSP from teardowns. As shown in 

Table 2.6.5, physical teardown information suggests 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. 

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EERE-2007-BT-STD-0016 COMMENT 20
Table 2.6.4 Two-Lamp Four-Foot MBP RS and IS 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

V W lm lm 

Baseline 

/CSL1 

Two F32T8 

Lamps Electronic IS 277 Single >0.98 <20% 0.88 60.4 1.450 85.4%* 5,250 4,988 

CSL2 Two F32T8 Lamps Electronic IS 277 Universal >0.98 <10% 0.86 56.0 1.535 90.5% 5,161 4,903 CSL3 Two F32T8 Lamps Electronic IS 277 Universal >0.97 <10% 0.87 56.4 1.561 92.0% 5,242 4,980 

*DOE was unable to test the efficiency of these particular ballasts. DOE estimates are based on the relationship between BEF and balla

active mode test procedure. For the IS and RS representative product class, the BEF of a ballast is related to ballast efficiency in the fol

Table 2.6.5 presents the engineering characteristics of the ballast replacement options for the baseline F34T12 sy4-foot MBP normal BF RS and IS product class. If a direct substitution is made, mean lumen output does not chapercent from that of the baseline system. For the F34T12 baseline ballast, DOE used the online price scaling techprice. DOE found that the MSP for the F34T12 ballast was higher than for any of the F32T8 ballasts. The F34T1sold at lower volumes than the electronic F32T8 ballasts represented by CSL1, CSL2, and CSL3. DOE attributes volume to its high cost relative to efficiency. 2-42 

EERE-2007-BT-STD-0016 COMMENT 20
Table 2.6.5 Two-Lamp Four-Foot MBP RS and IS 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

V W lm lm 

Baseline 2 F34T12 Lamps Electronic RS 277 Single >0.98 <20% 0.86 63.5 1.359 80.1%* 5,412 4,872 

CSL1 2 F32T8 Lamps Electronic IS 277 Single >0.98 <20% 0.88 60.4 1.450 85.4%* 5,250 4,988 CSL2 2 F32T8 Lamps Electronic IS 277 Universal >0.98 <10% 0.86 56.0 1.535 90.5% 5,161 4,903 

CSL3 2 F32T8 Lamps Electronic IS 277 Universal >0.97 <10% 0.87 56.4 1.561 92.0% 5,242 4,980 

*DOE was unable to test the efficiency of these particular ballasts. DOE estimates are based on the relationship between BEF and balla

active mode test procedure. For the IS and RS representative product class, the BEF of a ballast is related to ballast efficiency in the fol

BEF=1.697*BE. 

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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 analytical 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 other covered product classes that 

were not analyzed. 

At the public meeting, DOE discussed scaling to other product classes and requested 

comments. NEMA advised DOE to be careful when 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 operating 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. Therefore, 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 scaling 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 develop the manufacturer product costs and a markup 

analysis to arrive at the MSP. Figure 2.6.1 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 manufacturing production cost, and the nonproduction cost. The non-production cost is equal to the manufacturer markup minus profits. 

DOE totaled the cost of materials, 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 sum of all material, labor, and overhead costs equals the 

company’s sales cost, also referred to as the cost of goods sold (COGS). 

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Figure 2.6.1 Full 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.). 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 fluctuated 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 price index (spanning 2004 through 2008) for each 

component from the Bureau of Labor Statistics 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 difference 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 among ballasts that differed by only one 

characteristic (such as starting method or input voltage). Ballasts are described by a long list of 

specifications, so DOE concentrated on the specifications that were expected to have the greatest 

impact on efficiency—high versus regular advertised efficiency, maximum number of lamps 

driven, starting method, and universal versus single 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 Statistics, Producer Price Indices. Last accessed May 13, 2009. 

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

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DOE was able to select only unpotted ballasts 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 relating 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 income 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 goods 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 cost 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 revealed pricing for the 2000 Ballast Rule to 

calibrate the accuracy of DOE price predictions. 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 efficiency standard. (Joint Comment, No. 12 at p. 

13) 

DOE believes that it should not calibrate prices based on revealed historical pricing for 

two reasons. First, DOE is not using same pricing methodology as it used in the 2000 Ballast 

Rule. The methodology in the 2000 Ballast Rule relied on surveying distributors of magnetic and 

electronic ballasts to determine the appropriate distributor price 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 significantly 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> 

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than they are today. For example, there have been 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 chapter 5 of the preliminary TSD. 

2.6.7 Other Key Issues 

NEMA expressed concern that several possible 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 field requirements, and hazardous 

material regulation. NEMA stated that these potential 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 system interconnects and lamp end-of-life might 

lower the efficiency of commercially available ballasts. 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 requirements will affect the efficiency of 

commercially available ballasts. DOE also requests information on how safety requirements may 

affect the cost of both low and high efficiency ballasts so that DOE can assess how these 

requirements might affect payback calculations. 

NEMA also expressed concern about possible electromagnetic field regulations. 

Specifically, NEMA is concerned that current internationally accepted electromagnetic 

interference (EMI) levels may be modified. (NEMA, 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 may 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 requirements 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 implemented, NEMA believes these regulations 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 believes hazardous material regulations may be 

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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 estimates, DOE multiplied annual 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 input power of the complete lamp-and-ballast 

system is considered for the energy use analysis 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 characterize the country’s average use of lamp-andballast systems for a typical year, DOE developed 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 Building 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 other ballast product classes 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 would be significantly different from LMC, which 

was published in 2002. Further, DOE believes the overall national level of penetration 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 would 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, particularly on the type, prevalence, and operating 

hour reductions due to lighting controls used separately in the commercial, industrial, and 

residential sectors. 

In the case of PS ballasts operating 4-foot MBP T8 lamps, DOE assumed these lamp-andballast systems are operated on occupancy sensors 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> 

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

characterization. 

2.8 MARKUPS ANALYSIS 

In this rulemaking, DOE performed teardown 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 sales 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 distribution 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, 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 installed 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 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 comprehensive 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 fixture manufacturers and electrical wholesalers, 

respectively. DOE assumed a contractor markup consistent 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 equipment 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 from 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. Chapter 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 events by adding 2.5 minutes of 

labor time for installing a luminaire disconnect in the new construction/renovation case. This 

additional labor time and cost are not related to ballast design, but instead reflect current 

National Electric Code requirements 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 lamp is its disposal cost. Ballast recycling rate 

data were not available, so DOE conservatively assumed 5 percent of ballasts used in the 

commercial and industrial sectors 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; Joint 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 discussed how DOE’s approach to forecasting 

energy prices does not consider impacts of amended standards on utility infrastructure, natural 

gas demand, or overall electricity costs. (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 from changes in product efficiency. DOE also 

considered reporting overall natural gas and electricity price impacts but found that the 

uncertainty of price projections, together with the fairly small anticipated impact of the amended 

standards relative to total electricity demand, makes 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 decision concerning the standard level. 

Several commenters noted that DOE should consider 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 also 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 extended 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 value of cash flows to be derived from a typical 

company project or investment. Most companies 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 referred to as the weighted-average cost of capital. 

DOE used currently available economic data in developing discount rates and will update the 

data as appropriate for the NOPR 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, principally interest charges on debt; or (2) the opportunity cost of any equity 

used to purchase residential products, principally interest earnings on household equity. 

Household equity is represented by holdings in assets such as stocks and bonds, as well as the 

return on homeowner equity. DOE obtained data required to determine the 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 national 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 shipments. 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 stock 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 annual shipment projections. 

At the public meeting, Philips and Osram Sylvania commented on anticipated impacts of 

emerging technologies (e.g., solid-state lighting), lighting controls, and daylight harvesting on 

future ballast shipments. (Philips, Public Meeting Transcript, No. 9 at pp. 176, 189–191; Osram 

Sylvania, Public Meeting Transcript, No. 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 those used for daylight harvesting. Acuity Brands 

Lighting commented that DOE should consider the 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 interviews 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 transparent to all interested parties, 

DOE prepared an NES spreadsheet model to forecast 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 acknowledges 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 invites 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 energy 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, which represents the age of the ballasts) by the 

unit energy consumption (also by vintage). Then, DOE calculated national annual energy savings 

from the difference between national energy consumption in the base case (without amended 

efficiency standards) and in each higher-efficiency standards case. DOE estimated energy 

consumption and savings based on site energy, and converted the 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 installed 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 each year as the difference between total operating 

cost savings and increases in total installed costs (including equipment price and installation 

cost). DOE calculates savings over the life of the 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 costs as the product of the difference in the 

total installed cost between the 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 operating 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 primary weight to NPV results based on the 3­

percent discount factor, citing academic research that indicates appropriate 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-percent 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, “Identifying and Measuring Benefits and Costs”) Consistent with this 

guidance, DOE will use 3-percent and 7-percent real discount rates for relevant calculations in 

the NOPR stage of this rulemaking. 

2.11.3 Efficiency Scenarios and Trends 

Several of the inputs for the determination of NES (e.g., the annual energy consumption 

per unit) and NPV (e.g., the total annual installed cost and the total annual operating cost 

savings) depend on equipment efficiency. Thus, DOE developed base case and standards case 

efficiency trends. These trends specified the annual historical and forecasted shipment-weighted 

average equipment efficiencies. 

For ballasts, DOE developed two 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 standard 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 the 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 particular 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 increases in the consumer price of the considered 

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products as it wishes to avoid a negative economic 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 likely 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 ballasts. The Process Rule gives guidelines for 

considering financial impacts and a wide range of quantitative and qualitative industry impacts 

that might occur after adoption of a standard. For 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 issues 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 manufacturers, and assesses the impacts of standards 

both quantitatively and qualitatively. 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 after 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 provide important information 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 gathered 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 prefers an interactive interview 

process, rather than a written response to a questionnaire, because it helps clarify responses and 

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identify additional issues. Before the interviews, 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 revenues; manufacturer costs, including cost of 

goods sold, depreciation, research and development, 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 standards. The financial impact of 

amended energy conservation standards is the difference 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 structure 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 industry 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 financial information and impacts. 

2.13.5 Cumulative Regulatory 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 manufacturers raised concerns about existing 

regulations. Advance stated that California is very active and aggressive in writing legislation for 

energy efficiency for lighting products. Manufacturers 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 General 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 Lighting suggested that DOE obtain an exemption 

from the Buy American provision of EISA 2007 for certain lighting equipment. (Acuity Brands 

Lighting, Public Meeting Transcript, 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 plans to further investigate overlapping burdens 

on the manufacturers of fluorescent lamp ballasts. 

2.13.6 Preliminary Results for the Manufacturer Impact Analysis 

DOE conducted a series of preliminary interviews 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 returns to consumers, and (c) product innovation. 

2.13.7 Impacts on Profitability

 Some manufacturers commented that profit margins would decrease with the 

implementation of amended energy conservation standards, especially 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 ballasts. Manufacturers also noted that pricing 

is extremely variable depending on the application (commodities, old 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 lines. 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, consumers 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 product innovation. Because personnel may be spending more time 

redesigning products to comply with standards, the resources available 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 gas 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 the 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 produces a widely-recognized baseline energy 

forecast for the United States through 2030. The typical NEMS outputs include forecasts of 

electricity sales, prices, and 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 conservation 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, Public 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 impacts 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 uncertain. As a result, DOE believes that changes to 

energy commodity prices should not be weighed heavily 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 effects of amended standards on external 

benefits such as energy security (e.g., reduced natural gas usage), utility infrastructure, and 

pollution reductions. (ASAP, Public 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 tools 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 interested parties on the potential use of other 

tools for such analysis. 

As discussed in section 0, DOE acknowledges 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 nature 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 employment both directly and 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 NOPR 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 simple economic multiplier approaches, 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 consider the environmental 

effects of amended energy conservation standards 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 (CO2), nitrogen oxides (NOX), and 

mercury (Hg). The environmental assessment also considers impacts on SO2 emissions. After a 

brief discussion of general methodology, this section will address each of the relevant emissions. 

This section then explains how DOE plans to monetize the benefits associated with emissions 

reductions. 

2.16.1 Carbon Dioxide 

In the absence of any Federal emissions control regulation of power plant emissions of 

CO2, a DOE standard is likely to result in reductions of these emissions. The CO2 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 CO2 emissions using a detailed module that provides 

results with broad coverage of all sectors and inclusion of interactive effects. 

2.16.2 Sulfur Dioxide 

DOE has preliminarily determined that SO2 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 SO2 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 Air Act sets an annual emissions cap on SO2 for all affected 

EGUs. SO2 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 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 EPA regulations, any excess SO2 emission allowances resulting from the lower 

electricity demand caused by the imposition of an efficiency standard could be used to permit 

offsetting increases in SO2 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 SO2 emissions from the standards. While there remains some uncertainty about the 

ultimate effects of efficiency standards on SO2 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 physical reductions in power sector emissions would occur for SO2. 

Even if there is no significant reduction in the overall emissions of SO2 that results from 

the standard, there may still be some economic benefit from reduced demand for SO2 emission 

allowances that is not fully reflected in the cost savings experienced by individual consumers. 

Electricity savings that decrease the overall demand for SO2 emissions allowances could lower 

allowance prices and thereby result in some economic 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 particular benefit because the effect on the SO2 

allowance price from any single energy conservation standard is likely to be small and highly 

uncertain. 

2.16.3 Nitrogen Oxides 

NEMS-BT also has an algorithm for estimating NOX 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 

NOX in 28 eastern states and the District of Columbia. 70 FR 25162 (May 12, 2005). 

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Much like SO2 emissions, a cap on NOX 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 CAIR has been remanded to the EPA by the DC 

Circuit, it will remain in effect until it is replaced by a rule consistent 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 

NOX 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 environmental-related economic 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 SO2 allowance prices, DOE does not plan to monetize 

this particular benefit because the effect on the NOX allowance price from any single energy 

conservation standard is likely small and highly uncertain. 

Earth Justice requested that DOE quantify NOX 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 estimate the emissions reductions from possible 

standards in the 22 States where emissions are not capped. 

2.16.4 Mercury 

Similar to emissions of SO2 and NOX, future emissions of Hg would have been subject to 

emissions caps. In May 2005, EPA issued the 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 the CAMR. 517 F.3d 574 (DC Cir. 2008). EPA has 

decided to develop emissions standards for power plants under the Clean Air Act (Section 112), 

consistent with the DC Circuit’s opinion on the CAMR. See 

http://www.epa.gov/air/mercuryrule/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 standard 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 impacts 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 usually 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 does not separate direct PM emissions from power plants from the 

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sulfate particulates indirectly produced through complex atmospheric chemical reactions. The 

great majority of PM emissions from power plants are of these secondary particles (secondary 

sulfates). Thus, it is not useful to examine how the amended standard impacts direct PM 

emissions independent of indirect PM production and atmospheric dynamics. Therefore, DOE is 

not planning to assess the impact of these standards on particulate emissions. Further, even the 

cumulative impact of PM emissions from power plants and indirect emissions of pollutants from 

other sources is unlikely to be significant. 

2.16.6 Monetization of Emissions Reduction Benefits 

Several commenters noted that there are also external benefits to pollutant emission 

reductions that should be monetized and weighed in DOE’s determination 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 emission reductions are 

anticipated (CO2, Hg, and NOX 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 

CO2 emissions, it is DOE’s intent to use in its analysis the most current Social Cost of Carbon 

(SCC) values developed and/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 ecosystem 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 quantification and monetization, 

the SCC can be used to provide estimates of the social benefits of reductions in GHG emissions. 

At the time of this notice, the most recent interagency estimates of the potential global 

benefits resulting from reduced CO2 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 percent 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 range 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 knowledge continues to evolve rapidly as to 

the contribution of CO2 and other GHG to changes in the future global climate and the potential 

resulting damages to the world economy. Thus, these values are subject to change. 

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DOE also intends to estimate the potential monetary benefit of reduced NOX, and Hg 

emissions resulting from the standard levels it considers. For NOX emissions, available estimates 

suggest a very wide range of monetary values for NOX emissions, ranging from $370 per ton to 

$3,800 per ton of NOX from stationary sources, measured in 2001$ (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 Congress on the Costs and Benefits of Federal Regulations and 

Unfunded Mandates on State, Local, and Tribal Entities,” for additional information. 

For Hg emissions reductions, DOE has previously determined that the impact of mercury 

emissions from power plants on humans is considered 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 lifetime economic productivity 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 exposure to mercury of U.S. power plant origin 

($1.3 billion per year in year 2000$), which works 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 $0.66 million per ton emitted (in 2004$) 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 mercury. See Ted Gayer 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 published 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 monetary benefits derived using each of the economic values 

used for NOX 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 Office 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). 

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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 the 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 two sources of market failures: lack of 

consumer information and/or information processing 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 failures 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 address all barriers identified in the paper. These 

include financial procedures (or the time horizon of management) that over-emphasize initial 

costs and de-emphasize operating costs (as discussed in the Joint Comment), small per unit 

savings, limited stocking of efficient 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 assumptions about the marketplace. (ASAP, Public 

Meeting Transcript, No. 9 at p. 93) DOE agrees and therefore is continuing to seek data that 

would enable it to conduct tests of these market 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>. 

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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 Market 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 Efficiency Standards ................................................... 3-5
 

3.2.3.4 European Energy Efficiency 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 Commercial 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 Fluorescent 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 Interference ................................................................. 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
 

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EERE-2007-BT-STD-0016 COMMENT 20
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 Fluorescent 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 Slimline 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 Program 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 Fluorescent Lamp Nomenclature ................................................ 3-17
 

Associated Characteristics ......................................................................................................... 3-25
 

.................................................................................................................................................... 3-30
 

30
 

Table 3.4.3 Preliminary Product 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 Electronic Ballast Market Share ..................................................... 3-12
 

Figure 3.2.3 Shipments of Ballasts that Operate Four-Foot MBP Lamps................................. 3-13
 

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EERE-2007-BT-STD-0016 COMMENT 20
Figure 3.2.4 Shipments of Eight-Foot Slimline T8 and Eight-Foot SP Slimline T12 Ballasts . 3-14
 

Figure 3.2.5 Shipments of Residential 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
 

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EERE-2007-BT-STD-0016 COMMENT 20
 

CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT 

3.1 INTRODUCTION 

This chapter details the market and technology assessment that the U.S. Department of 

Energy (DOE) has conducted in support of the ongoing energy conservation standards and test 

procedure rulemakings for fluorescent lamp ballasts. 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 assessment provides an overall picture of the 

market for the products concerned, including the nature of the products, industry structure, and 

manufacturer market shares; regulatory and non-regulatory efficiency improvement programs; 

and market trends and quantities of products sold. The technology assessment identifies a 

preliminary list of technologies to consider in the screening analysis. The product classes section 

discusses the product classes DOE considered using for this rulemaking and how they were 

developed. 

The information DOE gathers from the market and technology assessment serves as 

resource material for use throughout the rulemaking. DOE considers both quantitative and 

qualitative information from publicly available 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 fluorescent lamp ballasts in 10 CFR 430.2. Appendix 3A 

lists these terms and their definitions. 

As part of this energy conservation standards rulemaking, DOE is considering extending 

coverage to additional fluorescent lamp ballasts. (42 U.S.C. 6295(g)(7)(B)) The following 

sections describe in more detail the definitions in EPCA for fluorescent lamp ballasts and note 

DOE’s interpretation of the definitions. Please see chapter 2 of this preliminary technical support 

document (TSD) for more discussion on DOE’s consideration of additional fluorescent lamp 

ballasts and its interpretation 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. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

DOE is conducting concurrent rulemakings for 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 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 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 nominal 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 nominal overall length 

between 45 and 48 inches and rated wattage of 26 or more; and 

(6) any straight-shaped lamp (commonly referred to 4-foot miniature bipin high 

output lamps) with miniature bipin bases 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 

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EERE-2007-BT-STD-0016 COMMENT 20
 

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 standards 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 length of 48 inches, a rated wattagec

 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) with 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 contact 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 miniature 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-shaped lamps (commonly 

referred to as 4-foot medium 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 (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 lamps) 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 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. 

c

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

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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 intended to be operated. 

3.2 MARKET ASSESSMENT 

The following market assessment identifies the manufacturer trade association and 

domestic manufacturers of fluorescent lamp ballasts; discusses 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 Systems 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 and educational markets.1

 In 

addition to ballasts, NEMA’s Lighting Systems 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 include2 

•	 “[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 and 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 transformation and environmental groups to advance market use of 

energy-efficient lighting technologies; 

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EERE-2007-BT-STD-0016 COMMENT 20
•	 advising DOE and the U.S. Environmental Protection Agency (EPA) on ENERGY STAR 

Buildings and ENERGY STAR voluntary product labeling programs; and 

•	 advocating market-based approaches to enhance the use and penetration of energyefficient technologies.” 

3.2.2 Manufacturers and Market Share 

The following list contains the names of manufacturers 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 domestic market share of fluorescent lamp ballasts 

•	 GE Consumer and Industrial of General 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 companies 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 affected by the promulgation of minimum energy 

conservation standards for fluorescent lamp ballasts. The Small Business Administration (SBA) 

lists small business size standards that are matched to industries as they are described in the 

North American Industry Classification System (NAICS). A size standard is the largest that a 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

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 size standard is matched 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 summarizes 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 action related to fluorescent lamp 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 EPCA 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; and (2) for each rulemaking cycle, determine 

whether the standards in effect for fluorescent lamp ballasts should be amended so that they 

would be applicable to additional fluorescent lamp ballasts. (42 U.S.C. 6295(g)(7)(A)(B)) 

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 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,” 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 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 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. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

Application 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 advocacy 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 efficient 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, Congress promulgated new energy conservation 

standards for certain fluorescent lamp ballasts 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 ballast 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). 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

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 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 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 regulation 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 residential 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 ballasts 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 directed 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 criteria 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. 

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mode energy use in any amended or new standard adopted after July 1, 2010. Because this 

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

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

standards analysis is applicable. 

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 energy use is only applicable to ballasts with a 

lighting control system. One example of these new ballast designs is a DALIi-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 active, even when the ballast is not driving any 

lamps. DOE noted that fluorescent lamp ballasts 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 standards 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 offering 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, 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, published in November 1994.5

 An amendment published in April 

2003 updated Canada’s regulations to the minimum levels 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. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

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 3.2.48 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 1j

 Level 2k 

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 addition to 120V and 277V, which is 

consistent with the Canadian electrical distribution network. Canadian 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. 

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minimum power factor of 0.9 (consistent with U.S. standards) for all ballasts except residential 

ballasts. 

3.2.3.4 European Energy Efficiency Standards 

Directive 2005/32/EC of the European Parliament 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, and 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 Efficiency 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 EPACT 1992 encourages energy efficient Federal 

procurement. Section 104 of EPACT 2005 requires that each agency incorporate energy 

efficiency criteria consistent with ENERGY STAR and FEMP-designated products for “...all 

procurements involving energy consuming products and systems, including guides 

specifications, project specifications, 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 efficient fluorescent ballasts, including the products 

shown in Table 3.2.5.9

 FEMP offers buyers support tools such as efficiency guidelines, costeffectiveness examples, and a cost calculator. FEMP also offers training, on-site audits, 

demonstrations, and design assistance. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

Table 3.2.5 Federal Energy Management Program 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 initiative in November 2004 to help 

identify and select energy efficient commercial lighting products and practices. Initial efforts 

focused on designating high-performance T8 lighting products. In January 2007, the initiative 

was expanded to include reduced-wattage T8 products. Table 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 Specifications10 

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% 

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EERE-2007-BT-STD-0016 COMMENT 20
 

Table 3.2.7 CEE Reduced Wattage T8 Ballast Specifications11 

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 based on ballast factor, 

which compares the ratio of light output of lamps operated by a specific ballast to the light 

output of the same lamps operated by a standard reference ballast. However, CEE chose not to 

create standards by ballast factor for reduced-wattage ballasts. Additionally, 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 ballasts manufactured by Acuity Brands Lighting, 

Advance, American Ballast, Espen Technologies, GE, Osram Sylvania, Robertson Worldwide, 

Technical Consumer Products, and Universal 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 released state-level shipment data that showed 

an increase in NEMA Premium motor shipments 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 residential lighting fixtures, which contain 

three parts: a lamp, a ballast, and the fixture that holds the lamp and ballast. Products that qualify 

for the ENERGY STAR label may not use magnetic ballasts in indoor fixtures. The ENERGY 

STAR specifications also define criteria for lamp start time, power factor, lamp current crest 

factor, ballast operating temperature, electromagnetic interference, frequency, transient 

protection, end of life protection, dimming, and safety.15 

3.2.4.5 Energy Efficient Commercial Building Deduction 

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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 partial 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, and other initiatives, such as Efficiency Vermontl 

and the Long Island Power Authority, to promote efficient lighting products.17, 18 

3.2.5 Historical Shipments 

Awareness of annual product shipment trends is an important 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 recent 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 candidate standard levels. 

The historical shipment data for ballasts is broken down into many subcategories 

beginning with magnetic versus electronic type 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. 

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EERE-2007-BT-STD-0016 COMMENT 20
defined by starting method (section 3.3.3.1), maximum number of lamps 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 shipment 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 ballasts, 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 ballast category to extrapolate the disaggregation 

of shipments for 2005. This estimation provided data points for 4- and 8-foot magnetic T12 

ballasts as well as 8-foot HO magnetic 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 magnetic ballasts, as seen in Figure 3.2.2. In 1990, 

magnetic ballasts represented about 96 percent of shipments, while the 2005 magnetic ballast 

market share dropped to 27 percent. This trend was in part due to energy conservation standards 

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EERE-2007-BT-STD-0016 COMMENT 20
 

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 replacement 4-foot T12 MBP, 8-foot T12 single pin 

(SP) slimline, and 8-foot HO magnetic 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 the 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 increase 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. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

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 2006 

Shipments 

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. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

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) 43,265 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 reported in 1997 or from 2001 to 2005. DOE estimated the 

2005 market share using the method described earlier. A portion of the ballasts listed in Table 

3.2.10 are rated for cold-temperature outdoor signage 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 RDC 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 they 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 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

Unit 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 magnetic residential ballast shipments have 

decreased from 1995 to 2004.m Shipments data for this category were unavailable for 2005. 

Because the major manufacturers in the residential sector are not members of NEMA, shipments 

in the residential sector are likely larger than those reported in the U.S. Census data. Residential 

ballasts have been excluded from energy conservation standards to date. 

14,000 

12,000 

10,000 

8,000

Shipments 

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. 

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EERE-2007-BT-STD-0016 COMMENT 20
T5 ballasts have been growing steadily since 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 ballast manufacturers indicated some growth in normal output T5 ballasts 

due to replacements of 4-foot electronic T8 ballasts. In addition, 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 construction 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 letters 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 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

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 diameter, lamp length, and lamp 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, electrodes, base, gas fill, and 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 alkaline oxides. A base provides an electrical connection 

to these electrodes and also supports the lamp. Depending on the start 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 coating 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 ground 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 has to be excited, ionized, and broken down (to 

become a virtual negative resistance, almost a short 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. 

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Current (I)

Voltage (V)

Arc

Abnormal Glow

Glow

Townsend

Target

Region

Undesirable

Region

Current (I)

Voltage (V)

Arc

Abnormal Glow

Glow

Townsend

Target

Region

Undesirable

Region

Figure 3.3.1 Electrical Characteristic 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 start (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 ion 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 lamp 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 basic ballast operation and the two 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 start and ignite the lamp, 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

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 main 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 parameters are briefly discussed below. 

3.3.3.1 Starting Method 

Fluorescent ballasts can be categorized by the 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 than the starting technique of an IS ballast. For 

example, if the lamp is switched on and off every 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 lamp filaments to a certain temperature 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 ignition (also known as cathode cut-out), resulting in 

some energy savings over other PS systems. However, due to added internal circuitry, PS 

ballasts cannot be as efficient as IS ballasts. 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 arc instantly, without the need for heating the 

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electrodes. Because IS electronic ballasts do not provide lamp electrode heating, these ballasts 

are inherently more efficient, saving approximately 2 watts of energy per lamp compared to RS 

ballasts. However, due to the high applied voltage necessary to start 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 depending 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 ballast factor affects the light output of the system, manufacturers 

design ballasts with a range of ballast factors to allow consumers to vary the light output (and 

thus power consumed) of a fluorescent 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 factor 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: 

BEF = 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 reference ballast, expressed as a percent; and 

InputPower = the power consumption in watts of a ballast 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 wave 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, 

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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 factor of 1 indicates that the voltage and 

current wave forms are in phase and not distorted. 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 one-half the current of NPF ballasts. The primary 

cause of low power factor in magnetic 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, commercial ballasts must have a HPF while 

residential fluorescent ballasts (with an input power 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 oscillate at integer multiples 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 non-linear system operation, generating noise and 

wasted power. Total harmonic distortion 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) =

I1

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 devices produces a magnetic field, which in turn induces an AC voltage in a 

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nearby electronic device. Electromagnetic interference (EMI) takes two forms: conducted or 

radiated. Conducted EMI occurs when electronic devices induce currents in the local power 

network that in turn negatively affect other devices on that network. Radiated EMI is associated 

with the electric and magnetic field inherent in electronic devices. 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 the lamp will have no adverse 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 overheating of the lamp electrodes. This can be avoided 

through additional circuitry that provides end-of-life (EOL) protection. 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 ballasts regardless of lamp diameter 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 major 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 magnetic 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 operate 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 such as silica and housed in a steel case. Figure 3.3.2 presents 

a labeled graphic of the interior of a standard magnetic ballast. 

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Figure 3.3.2 Cutaway View of a Typical 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 from 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 ballasts 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 plastic 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, rectifies it, and converts it into 

a high frequency using an oscillator circuit. 

Higher operating frequency generates greater 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. 

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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 have additional blocks of electronic components. Figure 3.3.4 

shows the interior of an electronic ballast. 

Figure 3.3.4 Cutaway View of an Electronic Fluorescent Ballast 

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Figure 3.3.5 presents an example of a functional 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 input current, a direct-current (DC) filter, a direct-current to alternatingcurrent (DC-AC) inverter, a feedback/controller for high-frequency operation, and a final output 

stage to power the lamp. 

Figure 3.3.5 Fixed-Light Output Electronic 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 waveform 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 

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Input 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 

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and 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 diameter 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 increase 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 opposing 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 T12 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 consumer 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 holders due to differences in lamp length and base 

type. In addition, 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. As such, ballasts 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 

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A common way to increase the efficiency of both magnetic and electronic ballasts is to 

improve the quality of their components. Transformers, 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), and 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 magnetic 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 using amorphous materials. To further increase the 

efficiency of the ballast using amorphous materials, 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 individually insulated magnet wires twisted or braided into a uniform 

pattern. Skin effect refers to the 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 inverts 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 

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drop of about 0.6 V. Using Schottky diodesn reduces the voltage drop across the diodes by about 

0.3 V to 0.4 V. 

Capacitors: In both magnetic and electronic ballasts, 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 dissipates energy due to its drain-tosource resistance (RDS_ON) when the current flows through the transistor to the transformer. 

Using transistors with low RDS_ON can reduce this loss. For example, the efficiency of electronic 

ballast’s bipolar transistors can be improved by using metal-oxide-semiconductor field-effect 

transistors (MOSFETs), a transistor with a lower drain-to-source resistance. 

3.3.4.5 Improved Circuit Design 

Another method of increasing the efficiency of both magnetic and electronic ballasts is to 

improve the ballast’s circuit design. Examples of improved circuit design include cathode cutout 

technology, integrated circuits, improved starting method, and synchronous rectification. 

Cathode Cutout: Both rapid start and programmed start 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. Removing 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 substituting 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 filament 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 technology 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. 

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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. However, lamps operated on RS ballasts 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 occupancy 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 considers 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 ballasts to develop product classes for this preliminary TSD. This 

section describes the product classes DOE considers for this rulemaking. 

In amending EPCA, NAECA 1988 established eight 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 

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277 120 

Two F96T12 HO/ES Lamps 120 190 

277 190 

In addition to the lamps and lamp ballasts identified 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 fluorescent lamp-and-ballast systems are gaining in 

market share, whereas T12 systems are becoming 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 EPACT 2005 for replacement ballasts will expire. The 

standard levels established by the 2000 Ballast Rule and EPACT 2005 for fluorescent lamp 

ballasts are difficult to meet using magnetic ballast technology. Because 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 considering 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 constraints of the lamp-and-ballast system; and (3) the 

use of the ballast in an application for which other 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 lamps 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 efficient than T12 lamp-and-ballast 

systems and T8 ballasts generally have higher BEFs than T12 ballasts. DOE does not, however, 

believe that this alone justifies creating separate product classes for ballasts 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 

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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 ballasts that operate T8 and T12 lamps in the same product class. 

However, DOE has decided to establish a separate product class for ballasts that operate 

T5 lamps. All else being equal, 4-foot T5 ballasts 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 classes 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 amended 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 example, 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, respectively. This difference in operating design 

increases the quantity of light per unit of lamp length. 

High output lamps generally operate at higher 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. 

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In addition, consumers tend to use systems with different lumen packages for different 

applications. For example, high-lumen-output systems may be installed in certain high-ceiling or 

outdoor applications where large quantities of light are 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 application of ballasts designed to operate SO lamps versus HO lamps 

indicate a difference in utility. 

Therefore, given the observed utility distinctions and notable efficacy differences, DOE 

is establishing separate product classes for ballasts that operate SO lamps and 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 can 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 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 separate product classes based on 

the maximum number of lamps a ballast operates. 

3.4.6 Starting Method 

As discussed in section 3.3.3.1, the starting method 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 during lamp operation (using the cathode 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 operate only at 277V, DOE found that there was not a significant 

3-33 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

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 determining product class. 

3.4.8 Universal Voltage 

Universal voltage ballasts can operate at multiple input voltages (e.g., 120V and 277V). 

To accommodate multiple voltages, 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 serve as replacements for 

multiple ballasts. This allows distributors to stock fewer types of ballasts and allows contractors 

to keep fewer on hand for maintenance. Consolidation of products creates economies of scale for 

manufacturers, 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 voltage 

and found that there was not a significant difference 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 minimum allowable) power factor requirementsp

. These 

differing requirements between commercial and residential 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 applications. Therefore, DOE has tentatively decided to 

establish a separate product classes for ballasts that operate in the residential sector and 

commercial sector. 

3.4.10 Sign Ballasts 

Ballasts that are designed for use in cold 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 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 temperature environments and to be able to handle 

numerous 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 

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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

 

 

 

 

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 standard levels. 

Table 3.4.3 Preliminary Product Classes for Fluorescent Lamp Ballasts 

Ballast and Lamp Number of Lamps 

Type 

Starting 

Method 

Ballast 

Factor One Two Three Four Five Six 

High 1 2 3 4 5 6 

IS and RS Normal 7 8 9 10 11 12

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 

Eight-Foot RDC IS and RS All 53 54 N/A N/A N/A N/A 

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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

REFERENCES 

1

 Ron Runkles. NEMA Premium Efficiency 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 Ballasts. 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

<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 Energy. 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 Application. 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 Docket # 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_Sylvania/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>. 

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EERE-2007-BT-STD-0016 COMMENT 20
25 National Lighting Product Information Program. Lighting Answers: Electromagnetic 

Interference Involving Fluorescent Lighting Systems. 1995. (Last accessed June 29, 2009). 

<http://www.lrc.rpi.edu/programs/NLPIP/lightinganswers/pdf/view/LAEMI.pdf>. 

26International Rectifier. International Rectifier Introduces Robust Self-Oscillating Electronic 

Ballast Lighting Control IC. 2009. (Last accessed June 29, 2009.) <http://www.irf.com/whatsnew/nr051122.html>. 

3-38 

EERE-2007-BT-STD-0016 COMMENT 20
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 

EERE-2007-BT-STD-0016 COMMENT 20
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 interested 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 promulgation of new or revised efficiency 

standards. These procedures elaborate on the statutory criteria provided in 42 U.S.C. 

6295(o) and, in part, eliminate 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 provide guidance to DOE for determining which design options 

are unsuitable for further consideration: 

1.	 Technological feasibility. DOE will consider technologies incorporated in 

commercial products or in working prototypes to be technologically feasible. 

2.	 Practicability to manufacture, install, and service. If mass production and 

reliable installation and servicing 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 product availability. If DOE determines 

a technology would have significant adverse 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 characteristics (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 

EERE-2007-BT-STD-0016 COMMENT 20
 

Section 4.2 discusses the technology options 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 consideration 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 ballast. For magnetic ballasts, 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 steel, 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 problems in installing and servicing ballasts 

because the ballast could be too large to fit in a fixture. DOE also believes this 

technology option could have 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 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 Part 430, Subpart C, Appendix A, (4)(a)(4) and 5(b), DOE is 

considering the design options in the following 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

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. 

4-3 

EERE-2007-BT-STD-0016 COMMENT 20
5-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 OPERATE TWO FOUR-FOOT MBP AND TWO-FOOT USHAPED 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 USHAPED 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 LAMPS .......... 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 LAMPS.......... 5-49

5.10.1 Baseline Models ................................................................................................. 5-49

5.10.2 Candidate Standard Levels ................................................................................ 5-50

5.10.3 Lamp and Ballast Prices..................................................................................... 5-52

EERE-2007-BT-STD-0016 COMMENT 20
5-ii

5.10.4 Results5-52

5.11 BALLASTS THAT OPERATE TWO FOUR-FOOT MBP AND TWO-FOOT USHAPED 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 Results5-58

5.12 BALLASTS THAT OPERATE FOUR EIGHT-FOOT HO LAMPS IN COLD 

TEMPERATURE APPLICATIONS OR OUTDOOR SIGNS ..................................... 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 Results5-64

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 Scaling5-68

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

Table 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 Representative 

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 ....................................................................................................... 5-22

EERE-2007-BT-STD-0016 COMMENT 20
5-iii

Table 5.6.2 Baseline Ballasts for the IS 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/ES Ballasts ............................................. 5-30

Table 5.7.4 Ballast Designs for the Eight-Foot SP Slimline Representative Product Class ...... 5-32

Table 5.7.5 Manufacturing 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 Class 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 Representative 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 Representative 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 MiniBP 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 ............................................................... 5-50

EERE-2007-BT-STD-0016 COMMENT 20
5-iv

Table 5.10.4 Ballast Designs for the Four-Foot T5 MiniBP HO Representative Product Class5-51

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 Representative 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 F34T12 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 Ballast 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 RDC 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 Ballasts 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 ................... 5-25

EERE-2007-BT-STD-0016 COMMENT 20
5-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 Candidate 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 Levels for the Sign Ballast Representative Product Class .. 5-63

EERE-2007-BT-STD-0016 COMMENT 20
5-1 

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 markups. 

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 

study, 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 to 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.

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Select Baseline Ballasts: For each representative product class, DOE establishes baseline 

ballasts. Generally, a baseline ballast is a commercially available ballast 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 5C presents the test 

results. DOE selects specific characteristics such as starting method, ballast factor (BF), and 

input 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 replacements for each baseline ballast in the representative product 

classes by considering the design options identified in the technology assessment and screening 

analysis (preliminary TSD chapter 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 ballast 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 these test results. All BEF and BE values 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 analysis. 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 Levels. 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 maximum 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. 

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product classes. The BOMs describe 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 manufacture a product in order to calculate the MPC.d

 Section 5.3.1 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 all 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 

company’s sales cost, also referred to as the cost of goods sold (COGS).

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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 

conducted 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 commented 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 component 

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 

was 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 labor costs associated with the assembly of the product. Separate 

labor rates were used for components that required manual (hand) insertion versus those that 

were 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 financial 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. 

EERE-2007-BT-STD-0016 COMMENT 20
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 heat 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 ballasts 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 tear down 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 Universal HE

10 and 11 IS 2 F59T8 Universal HE

12 IS 2 F59T8 Single REG

13 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 at 

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5-6 

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 

investments, 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 manufacturer 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 analysis, 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 the 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: 

EERE-2007-BT-STD-0016 COMMENT 20
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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

IndustryWeighted 

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 the 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, DOE 

EERE-2007-BT-STD-0016 COMMENT 20
5-8 

asked manufacturers 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 distributor. 

 

 DOE supplemented the information provided in Table 5.3.3 by estimating a weightedaverage 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 efficient 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 

fluorescent lamp ballast industry was appropriate. 

5.3.3 MSP Scaling

To estimate MSPs 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 database 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 ballasts 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 contain 70 product classes (

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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 (MBP) 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 start (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 commone. 

DOE estimates the majority of ballasts that operate 4-foot T5 miniature bipin (MiniBP) 

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 lamps 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 analyzed. 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.

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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 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

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 USHAPED 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 active mode test procedure 

unless otherwise specified.

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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

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.

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 for 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 

represented 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 because 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 in choosing the most appropriate F32T8 and 

F34T12 ballasts for the IS and RS product class. These characteristics included 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 voltagesg

 

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.

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5-12

energy conservation 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 baseline 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 F34T12 

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 but 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 Voltage >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 ballasts. 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. 

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. 

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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 85

* 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 installations. 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 

baseline 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 ballast 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 

corresponding 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 the 

EERE-2007-BT-STD-0016 COMMENT 20
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baseline ballasts have different BEF values and represent various design options, 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 of 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 fluorescent 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 product 

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 currently 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 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 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: 92.0 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. 

EERE-2007-BT-STD-0016 COMMENT 20
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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 1.535

CSL3 1.561

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 35

Ballast Efficacy Factor (BEF)

Nominal Lamp Wattage (W)

CSL3

CSL2

CSL1

EPCA

F32T8 F34T12

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.

EERE-2007-BT-STD-0016 COMMENT 20
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CSL1. BEF: 1.518; 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 33

Ballast 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 engineering 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 representative 

product class, the ballast characteristics are very similar.

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Table 5.5.6 Ballast Designs for the IS and RS Representative Product Class 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

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 ballasts. 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 5.5.7 Ballast Designs for the PS Representative Product Class 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

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 for the 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 less costly than the less efficient CSL2 ballast, but both 

CSL2 and CSL3 are more costly than CSL1. 

EERE-2007-BT-STD-0016 COMMENT 20
5-18

 

Table 5.5.8 Summary of the Manufacturing Selling Prices for the IS and RS 

Representative Product Class

Candidate 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 appropriate 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 competes 

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 

classes to provide a comprehensive understanding of the consumer economics. DOE based its 

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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 

S dardsCase

S dardsCase

Baseline

S dardsCase InputPower MLO

MLO NormalizedInputPower tan

tan

tan = ∗

S dardsCase NormalizedInputPower tan = Input power of the standards-case system that 

matches the light output of the baseline system

MLOBaseline = Mean lumen output of the baseline system 

MLOS tan dardsCasee = Mean lumen output of the standards-case system

S dardsCasee InputPower tan = Input power of the standards-case system

Table 5.5.11 through 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 system, 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. 

EERE-2007-BT-STD-0016 COMMENT 20
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Table 5.5.11 IS and RS Representative 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 

Power

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 ballasts. 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 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 

Power

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 63.5

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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 ballasts. DOE estimates are based on the relationship between BEF and ballast efficiency determined by the active mode t

ballast is related to ballast efficiency in the following manner: BEF=1.697*BE. 

Table 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 Class 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 

Power

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 1.518 90.2% 5,176 4,917 -3.8 12.49 5.65 59.1 

EERE-2007-BT-STD-0016 COMMENT 20
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5.6 BALLASTS THAT OPERATE FOUR FOUR-FOOT MBP AND TWO-FOOT USHAPED 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

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.

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 IS 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). 

Furthermore, 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. 

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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 ballast 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 

Operation 

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 both 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 Type 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 

baseline F32T8 IS ballast and approximately 9,863 mean lumens (and 10,382 initial lumens) for 

the baseline F32T8 PS ballast. 

EERE-2007-BT-STD-0016 COMMENT 20
5-24

5.6.2 Candidate Standard Levels

The following discussion identifies the steps and technologies associated with each CSL 

DOE considered for the 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 baseline 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 33

Ballast 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 Class

EERE-2007-BT-STD-0016 COMMENT 20
5-25

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 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.

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 33

Ballast 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 analysis and subsequent analyses. In general, for the IS and RS 

EERE-2007-BT-STD-0016 COMMENT 20
5-26

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, 

the ballast characteristics are also very similar.

Table 5.6.5 Ballast Designs for the IS and RS Representative Product Class 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

V W 

Baseline 4 F32T8

Lamps Electronic IS 277 Single >0.98 <10% 0.84 111.5 0.768 90.5%

CSL1 4 F32T8 

Lamps Electronic IS 277 Universal >0.98 <10% 0.87 114.4 0.781 92.0%

Table 5.6.6 Ballast Designs for the PS Representative Product Class 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

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 Ballast Prices

DOE analyzed each CSL for the IS and RS representative product class to develop 

appropriate MSPs. The baseline MSP was calculated using the online price scaling technique 

described in section 5.3.3 whereas the CSL1 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 $11.88

EERE-2007-BT-STD-0016 COMMENT 20
5-27

DOE analyzed each CSL for the PS representative product class to develop appropriate 

MSPs. The 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 product 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 percent relative to the mean lumen output of the baseline system.

EERE-2007-BT-STD-0016 COMMENT 20
5-28

Table 5.6.10 Four-Lamp Four-Foot MBP RS and IS 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 

Power

V W lm lm % $ $ W 

Baseline 4 F32T8 

Lamps Electronic IS 277 Single 0.98 <10% 0.84 111.5 0.768 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 0.781 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 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 

Power

V W lm lm % $ $ W 

Baseline 4 F32T8 

Lamps Electronic PS 277 Single 0.99 <10% 0.87 120.3 0.708 83.9% 10,382 9,863 N/A 10.72 11.29 120.3

CSL1 4 F32T8 

Lamps Electronic PS 277 Universal 0.98 <10% 0.88 116.1 0.755 89.4% 10,555 10,028 1.7% 14.20 11.29 114.2

EERE-2007-BT-STD-0016 COMMENT 20
5-29

5.7 BALLASTS THAT OPERATE TWO EIGHT-FOOT SP SLIMLINE LAMPS

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 class), 

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 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 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 baseline 

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.

EERE-2007-BT-STD-0016 COMMENT 20
5-30

chose 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, DOE 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 ballast 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% 0.790 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 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 Efficacy* 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 the 

EERE-2007-BT-STD-0016 COMMENT 20
5-31

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 circuit 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 technologically 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.

EERE-2007-BT-STD-0016 COMMENT 20
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 61

Ballast 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 ballast 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 ballast.

Table 5.7.4 Ballast Designs for the Eight-Foot SP Slimline Representative Product Class 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

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 0.790 90.0%

EERE-2007-BT-STD-0016 COMMENT 20
5-33

Lamps

CSL1 2 F96T8 

Lamps Electronic IS 277 Universal >0.98 <10% 0.87 108.0 0.809 92.2%

*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 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.

5.7.3 Lamp and Ballast Prices

DOE analyzed each CSL for the 8-foot SP slimline representative product class to 

develop appropriate MSPs. Both 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 found 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 19.34

CSL1 F96T12/ES 26.27

Baseline F96T8 15.55

CSL1 F96T8 9.27

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 5.7.6 Retail Prices for Eight-Foot SP Slimline Fluorescent Lamps

Lamp Type

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 product 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 is 

EERE-2007-BT-STD-0016 COMMENT 20
5-34

made, mean lumen output does not change by more than 0.1 percent relative to the mean lumen 

output of the baseline system. 

EERE-2007-BT-STD-0016 COMMENT 20
5-35

Table 5.7.7 Eight-Foot SP Slimline Representative Product Class with F96T12/ES 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 

Power

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 ballasts. 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 baseline system.

Table 5.7.8 Eight-Foot SP Slimline Representative Product Class with F96T8 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 

Power

V W lm lm % $ $ W 

Baseline 2 F96T8 

Lamps Electronic IS 277 Universal >0.98 <10% 0.87 109.7 0.790 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 0.809 92.2% 10,317 9,491 1.0% 9.27 11.84 106.9

EERE-2007-BT-STD-0016 COMMENT 20
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EERE-2007-BT-STD-0016 COMMENT 20
5-37

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 procedure 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 Two 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 class 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 (excluding 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 ballasts 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 magnetic 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.

EERE-2007-BT-STD-0016 COMMENT 20
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 F96T8HO 

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, THD

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 ballasts. 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 representative product class, the 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 24,000 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 16,339 initial lumens) for the 

baseline F96T12HO/ES ballast, approximately 12,496 mean lumens (and 13,904 initial lumens) 

for the baseline F96T8HO ballast. 

EERE-2007-BT-STD-0016 COMMENT 20
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 (preliminary TSD chapter 4), DOE used design options that achieved 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 technologically 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.

EERE-2007-BT-STD-0016 COMMENT 20
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 96

Ballast Efficacy Factor (BEF)

Nominal Lamp Wattage (W)

CSL2

CSL1

F96T8HO F96T12HO/ES

F96T8HO Baseline

F96T12HO/ES Baseline

Figure 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 

the 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 Eight-Foot RDC HO Representative Product Class 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

V W 

Baseline 2 F96T12HO/ES 

Lamps Magnetic RS 277 Single ≥0.90 <18% 0.92 208.4 0.440 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%*

EERE-2007-BT-STD-0016 COMMENT 20
5-41

CSL2 2 F96T8HO 

Lamps Electronic IS 277 Single >0.98 <10% 0.68 142.8 0.549 89.4%

*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 the active mode test procedure. For the 8-foot RDC HO representative product 

class, the 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 baseline, 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 table 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

Baseline/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.

EERE-2007-BT-STD-0016 COMMENT 20
5-42

Table 5.8.7 Eight-Foot RDC HO Representative Product Class with F96T12HO/ES 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 

Power

V W lm lm % $ $ W 

Baseline 2 F96T12HO/ES 

Lamps Magnetic RS 277 Single 0.90 <18% 0.92 208.4 0.440 71.6%* 16,339 14,705 N/A 22.80 24.70 208.4 

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 24.70 183.4

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% 0.68 142.8 0.549 89.4% 10,682 9,600 -34.7% 24.38 13.13 218.8

*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 the active 

mode test procedure. For the 8-foot RDC HO representative product class, the 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 F96T8HO 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.

EERE-2007-BT-STD-0016 COMMENT 20
5-43

Table 5.8.8 Eight-Foot RDC HO Representative Product Class with F96T8HO 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 

Power

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 13.13 160.0 

CSL2 2 F96T8HO 

Lamps Electronic IS 277 Single 0.98 <10% 0.68 142.8 0.549 89.4% 10,682 9,600 -23.2% 24.38 13.13 185.9

*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 representative product class, the BEF of a ballast is related to ballast efficiency in the following manner: BEF=0.614*BE. 

EERE-2007-BT-STD-0016 COMMENT 20
5-44

5.9 BALLASTS THAT OPERATE TWO FOUR-FOOT MINIBP T5 SO LAMPS

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

Currently 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 MiniBP 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 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.

 Therefore, DOE has chosen to only 

analyze the F28T5 baseline ballast. 

Table 5.9.2 Baseline Ballast 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 79.1%* 1.309 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 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).

EERE-2007-BT-STD-0016 COMMENT 20
5-45

ballast efficiency 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 Efficacy* 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.

EERE-2007-BT-STD-0016 COMMENT 20
5-46

1.250

1.300

1.350

1.400

1.450

1.500

1.550

1.600

1.650

1.700

27 28 29

Ballast Efficacy Factor (BEF)

Nominal Lamp Wattage (W)

CSL1

F28T5 Baseline

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 Class 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

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%

EERE-2007-BT-STD-0016 COMMENT 20
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 active mode test procedure. For the 4-foot T5 MiniBP SO representative 

product class, the 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 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. 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. 

EERE-2007-BT-STD-0016 COMMENT 20
5-48

Table 5.9.7 Four-Foot T5 MiniBP SO Representative Product Class with F28T5 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 

Power

V W lm lm % $ $ W

Baseline 2 F28T5 

Lamps Magnetic 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, the BEF of a ballast is related to ballast efficiency in the following manner: 

BEF=1.655*BE. 

EERE-2007-BT-STD-0016 COMMENT 20
5-49

5.10 BALLASTS THAT OPERATE TWO FOUR-FOOT MINIBP T5 HO LAMPS

In this section, DOE analyzes the representative product 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 Operate Two Four-Foot 

MiniBP T5 HO 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 product 

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 minimum 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 ballasts 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-

foot 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 74.2%* 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 that is not a F54T5HO. One manufacturer 

sells a reduced wattage (F51T5HO). Another manufacturer sells a F49T5HO.

EERE-2007-BT-STD-0016 COMMENT 20
5-50

procedure. For the 4-foot T5 MiniBP HO representative product class, the 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 F54T5HO 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 the 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 

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 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 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: 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 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.

EERE-2007-BT-STD-0016 COMMENT 20
5-51

0.650

0.700

0.750

0.800

0.850

0.900

53 54 55

Ballast Efficacy Factor (BEF)

Nominal Lamp Wattage (W)

CSL1

F54T5HO Baseline

CSL2

Figure 5.10.1 Candidate 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 

Class 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

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 0.837 90.3%

EERE-2007-BT-STD-0016 COMMENT 20
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 magnetic 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. Using this 8-foot HO ratio, 

DOE adjusted the price assigned to CSL1 to calculate the price for the model magnetic T5 HO 

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 appropriate 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 F54T5HO 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.

EERE-2007-BT-STD-0016 COMMENT 20
5-53

Table 5.10.7 Four-Foot T5 MiniBP HO Representative Product Class with F54T5HO 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 

Power

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 0.837 90.3% 10,152 9,340 2.8% 18.27 8.56 119.1

EERE-2007-BT-STD-0016 COMMENT 20
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5.11 BALLASTS THAT OPERATE TWO FOUR-FOOT MBP AND TWO-FOOT USHAPED LAMPS 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 otherwise 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 

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

Shading indicates a representative product class.

5.11.1 Baseline Models 

For the Residential 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 by 

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 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 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 the 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.

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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 

Efficiency 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% 1.457 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, the BEF of a ballast is related to ballast 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 lamp 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 approximately 3,310 mean lumens (and 3,676 initial lumens) for the 

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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 steps and technologies associated with each CSL 

DOE considered for the residential 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 residential 

representative product class, DOE identified two CSLs. CSL2 represents the maximum 

technologically 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 ballasts. The plot 

also shows the replacement ballasts DOE is considering at CSL1 and CSL2.

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1.25

1.30

1.35

1.40

1.45

1.50

1.55

31 32 33 34 35

Ballast Efficacy Factor (BEF)

Nominal Lamp Wattage (W)

CSL2

CSL1

F32T8 F34T12

F32T8 Baseline

F34T12 Baseline

Figure 5.11.1 Candidate Standard Levels for the Residential Representative Product Class

Table 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 Class 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

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 1.457 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. DOE estimates are based on the relationship 

between BEF and ballast efficiency determined by the active mode test procedure. For the residential representative 

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product class, the 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 residential 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 fixture. 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 appropriate 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 residential representative product class. Because the BF of 

the standards-case system is 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 can 

increase by as much as 43 percent over the mean lumen output of the baseline system because of 

the difference in ballast 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 will 

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not purchase direct ballast replacements, but rather replacement fixtures. Therefore, the 

normalized input power is the most relevant scenario because fixture spacing can be easily 

adjusted when a new fixture is installed. 

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5-60

Table 5.11.7 Residential Representative 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 

Power

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 F32T8 

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 the engineering characteristics of the ballast replacement options for the baseline F32T8 system in the 

residential 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 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 

Power

V W lm lm % $ $ W 

Baseline/CSL1 2 F32T8 

Lamps Electronic IS 120 Single N/A N/A 0.78 53.1 1.457 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 51.8

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5.12 BALLASTS THAT OPERATE FOUR EIGHT-FOOT HO LAMPS IN COLD 

TEMPERATURE APPLICATIONS OR OUTDOOR SIGNS 

In 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 common 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 Sign 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, 0.77 393.6 74.4%* 0.196 N/A

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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 class, the 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 Temperature 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 discussion 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 CSL1.

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0.00

0.04

0.08

0.12

0.16

0.20

0.24

0.28

109 110 111

Ballast 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 Class 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

V W

Baseline 2 F96T12HO 

Lamps Magnetic RS 120 Single N/A N/A 0.77 393.6 0.196 74.4%*

CSL1 2 F96T12HO 

Lamps Electronic IS 120 Universal N/A N/A 0.63 264.0 0.238 90.4%*

*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 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.

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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 and 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 that 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 Ballast 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 Price 

(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.

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Table 5.12.7 Sign Ballast Representative Product Class with F96T12HO 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 

Power

V W lm lm % $ $ W

Baseline 4 F96T12HO 

Lamps Magnetic RS 120 Single N/A N/A 0.77 393.6 0.196 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 0.63 264.0 0.238 90.4%* 21,599 17,495 -18.5% 35.58 19.34 324.1

*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 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. 

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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 operate different numbers of lamps, have different 

ballast factors, or have 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 chose 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 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

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 available 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 lamps and cold temperature 

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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 operate 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 

Total Rated Lamp Power-0.942 Ballast Efficacy Factor = Coefficient ∗ 

 To determine the appropriate coefficient in the equation above, DOE relied on the 

analysis performed for each representative 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 larger for higher CSLs. 

5.13.2 Starting Method

As discussed in preliminary TSD chapter 3, the starting method of a ballast affects its 

efficiency. Rapid start and programmed start ballasts are inherently less efficient than instant 

start ballasts, as these ballasts use 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 ballasts 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 BEF than 

ballasts with a normal ballast factor.

12

 

12 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 factor ballasts typically have a ballast factor of 1.10 

or higher.

 To determine how to scale to product classes containing 

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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 calculated 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 shading 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.

 When necessary, DOE then scaled based on starting method. For ballasts 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. 

EERE-2007-BT-STD-0016 COMMENT 20
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 shading 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 with CSLs scaled based on the starting 

method relationship.

 Last, when required, DOE scaled based on ballast factor. As discussed in section 5.13.3, 

DOE developed scaling factors for both high and low BF ballasts. For ballasts 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 factor 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 shading 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 

indicates 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. 

EERE-2007-BT-STD-0016 COMMENT 20
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 

Method

Ballast 

Factor CSL Number of Lamps

One Two Three Four Five Six

4-Foot MBP, 

and 2-Foot UShaped

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 0.533

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.

EERE-2007-BT-STD-0016 COMMENT 20
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 Residential Ballasts That Operate Four-Foot MBP and TwoFoot 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 UShaped

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 Outdoor 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.

EERE-2007-BT-STD-0016 COMMENT 20
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> 

EERE-2007-BT-STD-0016 COMMENT 20
CHAPTER 6. ENERGY USE CHARACTERIZATION 

TABLE OF CONTENTS
 

6.1 PURPOSE OF THE DOCUMENT .................................................................................... 6-1 

6.2 LAMP AND BALLAST SYSTEM 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 MBP 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 Operating 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 Operating 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 Operating 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 Operating 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 Consumption, 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 Consumption, Industrial Sector .................... 6-7 

6-i 

EERE-2007-BT-STD-0016 COMMENT 20
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 Consumption, 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 Consumption, 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 Distribution 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 Operating Hour Distribution by Building Type ............. 6-4 

6-ii 

EERE-2007-BT-STD-0016 COMMENT 20
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 fluorescent lamp-and-ballast system designs DOE 

considers in the ballast rulemaking analyses. Because 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 ballast 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 the 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 determine the potential energy and operating cost 

savings to consumers from the use of more efficient equipment. 

DOE determines the annual energy consumption 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 develop 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, and Pacific) and large States (California, 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 building 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 (assembly, athletic, bathroom, boarding, class, dining, display, 

exit, exterior-architectural, exterior-parking, exit-sign, exterior, food preparation, hall, 

healthcare, office, ship/rec, shop, storage, task, unknown, and utility) for the commercial and 

6-1 

EERE-2007-BT-STD-0016 COMMENT 20
industrial sectors and room type (bathroom, bedroom, 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 operating hours by census division and large States. 

This allows DOE to correlate the electricity price distribution (chapter 8), and sales tax 

distribution (chapter 7) with the operating hour distribution 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 for fluorescent lamp-andballast systems. The 2005 RECS data indicates the probability that a certain building type resides 

within a census division. The LMC indicates the occurrence 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 level 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 annual 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 for 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 commercial sector. The 2002 MECS data indicates the 

probability a certain building type exists. DOE aggregates LMC annual operating hour data by 

industrial application to develop 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

 

 

 

 

 

 

Figure 6.2.1 displays the probability distribution of annual operating hours DOE uses for 

lamp-and-ballast systems in the residential sector. DOE uses these 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 Operating Hour Distribution by Building Type 

Figure 6.2.2 displays the annual operating hour probability distributions for lamp-andballast systems operating in the 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 

abili

16% 

5: Nonrefrigerated warehouse 

6: Food sales 

13: Public assembly 

14: Education 

25: Retail other than mall 

26: Service 

ob

7: Public order and safety 15: Food service 91: Other 

Pr

14% 26 

em

5 

12% 

Syst FL 

10% 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 

6-3 

EERE-2007-BT-STD-0016 COMMENT 20
 Chemicals & allied products 

 

 

s

 

Figure 6.2.3 displays the annual operating hour probability distribution for lamp-andballast 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 

22 23

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. Miscellaneous 

5,8695,0914,9113,6475,7073,8885,8935,3235,2745,3005,4754,5165,3875,6804,0325,1674,4545,9763,5922,831 

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-start (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 examined a range of estimates for energy savings 

from occupancy sensors compiled in Esource5

 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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 energy 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 rated input power ratings, DOE calculates the 

annual energy consumption of the entire lamp-and-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 consumption per lamp-and-ballast system based on 

measured and normalized input power, using the U.S. weighted average of annual operating 

hours in each sector. The average annual operating 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 Operating 4-Foot MBP and 2-Foot U-Shaped 

Lamps (F32T8 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/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 Operating 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 6.3.4. Four-Lamp RS and IS 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 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 Annual 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

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 Consumption, 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 Operating 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 Operating 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 

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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 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 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 

EERE-2007-BT-STD-0016 COMMENT 20
REFERENCES 

1. U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Energy 

Conservation Program for Consumer Products: 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 Information Administration. 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 Information 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 Information Administration. Manufacturing Energy 

Consumption Survey, Table 1.4: Number of Establishments 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 

EERE-2007-BT-STD-0016 COMMENT 20
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 Markups 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 Incremental Markups for Fluorescent Lamp 

Ballasts............................................................................................................................. 7-9
 

Table 7.2.8 State and Local Sales Tax Rates............................................................................... 7-9
 

Table 7.2.9 Regional Average Tax Rates .................................................................................. 7-10
 

LIST OF FIGURES 

Figure 7.1.1 Ballast Distribution Channels.................................................................................. 7-1
 

7-i 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 teardown analyses and a manufacturer markup 

analysis to develop manufacturer selling prices (MSPs) for representative ballast designs 

(chapter 5). DOE then applied distribution channel markups and sales 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 life-cycle cost (LCC) analysis and the 

national impact analysis (NIA). In particular, DOE developed end-user prices for ballast designs 

associated with a candidate 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 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, 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 installed 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 the two main distribution channels for ballasts. 

Figure 7.1.1 Ballast Distribution Channels 

7-1 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

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 conservation standards, manufacturers often introduce 

design changes to their product lines that result in increased production costs and MSPs. DOE 

assumes that some or all of the 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 models 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 (sales, general, and administration), materials and 

labor costs, research and development and interest expenses, depreciation and taxes, and profits. 

In order for sales of a product to contribute 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 multiplying 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 the 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 determined the equipment prices for ballast 

designs installed in fixtures: 

PEND = (PMFR × MUOEM × MUWHOLE × MUCONT × MUTAX ) Eq. 7.1

 Where: 

PEND = equipment price to the end-user ($), 

PMFR = MSP of baseline or standard-level equipment ($), 

MUOEM = OEM markup, 

MUWHOLE = wholesaler markup, 

MUCONT = contractor markup, and 

MUTAX = sales tax markup. 

For replacement ballasts, the equation is the same as above, except that the OEM markup 

( MUOEM ) is omitted. 

For each of the parties involved in the distribution of the equipment, the markups 

presented above are further differentiated between a “baseline markup” and an “incremental 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

 

 

 

 

 

 

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 that relate the manufacturer price of baseline 

ballast designs to the OEM, wholesaler or contractor baseline sales price, as shown in the 

following equations: 

POEM _ BASE = (PMFR _ BASE × MUOEM _ BASE) Eq. 7.2 

PWHOLE _ BASE = (POEM _ BASE × MUWHOLE _ BASE) Eq. 7.3 

PCONT _ BASE = (PWHOLE _ BASE × MUCONT _ BASE) Eq. 7.4 

PEND _ BASE = (PCONT _ BASE × MUTAX ) Eq. 7.5

 Where:
 

POEM _ BASE = OEM selling price of baseline equipment ($),
 

PMFR _ BASE = MSP of baseline equipment ($), 

MUOEM _ BASE = OEM markup for baseline equipment, 

PWHOLE _ BASE = wholesaler selling price of baseline equipment ($),
 

MUWHOLE _ BASE = wholesaler markup for baseline equipment, 

PCONT _ BASE = contractor selling price of baseline equipment ($),
 

MUCONT _ BASE = contractor markup for baseline equipment, 

PEND _ BASE = end-user purchase price for baseline equipment ($), and 

MUTAX = sales tax markup. 

For replacement ballasts, the equations are the same as above, except that the OEM 

( POEM _ BASE = (PMFR _ BASE × MUOEM _ BASE) ) is omitted, and the wholesaler baseline selling price is 

determined by applying the wholesaler baseline markup to the MSP for baseline equipment: 

PWHOLE _ BASE = (PMFR _ BASE × MUWHOLE _ BASE) Eq. 7.6 

7.1.2 Incremental Markups 

Incremental markups are defined as coefficients 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: 

POEM _ INCR = (PMFR _ INCR × MUOEM _ INCR) Eq. 7.7 

PWHOLE _ INCR = (POEM _ INCR × MUWHOLE _ INCR) Eq. 7.8 

PCONT _ INCR = (PWHOLE _ INCR × MUCONT _ INCR) Eq. 7.9 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

PEND _ INCR = (PWHOLE _ INCR × MUTAX )	 Eq. 7.10 

Where: 

POEM _ INCR = incremental OEM price for equipment with increased efficiency ($), 

PMFR _ INCR = incremental manufacturer price for equipment with increased 

efficiency ($), 

MUOEM _ INCR = incremental OEM markup for equipment with increased efficiency, 

PWHOLE _ INCR = incremental wholesaler price for equipment with increased efficiency ($), 

MUWHOLE _ INCR = incremental wholesaler markup for equipment with increased 

efficiency, 

PCONT _ INCR = incremental contractor price for equipment with increased efficiency ($), 

MUCONT _ INCR = incremental contractor markup for equipment with increased 

efficiency, 

PEND _ INCR = incremental end-user price for baseline equipment ($), and 

MUTAX = sales tax markup. 

For replacement ballasts, the equations are the same as above, except that incremental 

OEM ( POEM _ INCR = (PMFR _ INCR × MUOEM _ INCR) ) is omitted, and the incremental wholesaler price 

is determined by applying the incremental wholesaler markup to the incremental manufacturer 

price for equipment with increased efficiency: 

PWHOLE _ INCR = (PMFR _ INCR × MUWHOLE _ INCR)	 Eq. 7.11 

7.1.3	 Overall Markups 

Overall markups, including both overall baseline and overall incremental markups, relate 

the manufacturer price to the final customer price ( PEND ) as indicated by the following equation 

PEND = (PEND _ BASE + PEND _ 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 law 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 costs. For the OEM and wholesaler markups, DOE 

used 10-K reports from publicly owned lighting fixture manufacturers and electrical 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. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

 

 

 

 

 

 

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 Net 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 margins to calculate baseline markups on existing 

equipment (i.e., prior to efficiency changes resulting from enactment of proposed efficiency 

standards). Each company’s baseline 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 calculated 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 815,795 744,315 652,837 848,543 850,787 813,408 803,514 

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 803,400 735,800 656,800 595,000 561,900 481,500 409,100 

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.
 

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Table 7.2.2 Gross Profit Margins 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 73,094,000 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 24,430,000 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 Markups 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 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

The incremental markup applied to higher-efficiency equipment is lower than the 

baseline markup because DOE assumes that expenses like labor and occupancy costs remain 

fixed and need not be recovered in the markup. Profits and other operating costs are assumed to 

be variable and to scale with the MSP. 

The surveyed SEC 10-K reports did not typically 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 “Operating 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 calculated 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 wholesaler 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 develop total weighted markups. The weighted total baseline and 

incremental markups are provided in Table 7.2.7. 

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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 calculated 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) and the operating hour distribution 

(chapter 6) that DOE uses in the LCC spreadsheet. DOE also calculated a national populationweighted average sales tax for use as a single-value input to the LCC, should users want singleaverage results. DOE also used this result in the 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 California with a weighted average value of 7.12 percent 

nationwide. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

 

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 

EERE-2007-BT-STD-0016 COMMENT 20
REFERENCES 

1. U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Energy 

Conservation Program for Consumer Products: Technical Support Document: Energy 

Efficiency Standards for Consumer Products; Fluorescent Lamp Ballast Proposed Rule. 

January 2000. (Last accessed June 30, 2009.) 

<http://www.eere.energy.gov/buildings/appliance_standards/residential/pdfs/chap3.pdf> 

2. The Sales Tax Clearinghouse. State Aggregate 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/states/tables/NST-EST2008-

02.csv> 

7-11 

EERE-2007-BT-STD-0016 COMMENT 20
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.............................................................................................................. 8-13 

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 Systems (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 Operating 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

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 Estimate 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 Purchases 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 Addressed in Life-Cycle 

Cost and Payback Period Analyses* .................................................................. 8-22 

Table 8.4.1. Framework of Event-Type Scenarios 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 Scenarios 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 Scenarios 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-Lamp 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-Lamp 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 Sector (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 the Industrial Sector........................................................ 8-31 

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EERE-2007-BT-STD-0016 COMMENT 20
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-Lamp 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-Lamp 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 the 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 Electricity Price Trend .............................................................. 8-13 

8-iii 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 individual consumers of proposed amended energy 

conservation standards for 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 economic impacts of analyzed ballast designs. 

Amended standards usually decrease operating 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 (discounted) 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-efficient 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 and PBP. Key variables and calculations are 

presented for each metric. DOE performs the calculations 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 rulemaking (NOPR) stage of this rulemaking. 

8-1 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

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 results. However, other factors related to the 

characteristics of the consumer using the products 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 can 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 Consumption 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 values 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 choices 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 new construction/renovation) is assumed to influence the costeffectiveness of the consumer purchase decision. For example, DOE assumes that a consumer 

will replace a failed ballast with an identical ballast 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 analyses on the baseline ballasts from the 

representative product classes identified in the ballast market 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

•	 Two-Lamp Instant Start (IS) and Rapid-Start (RS) Ballasts Operating 4-Foot Medium 

Bipin (MBP) and 2-Foot U-Shaped Lamps (Commercial Sector Only) (F32T8 Baseline) 

•	 Two-Lamp Programmed-Start (PS) Ballasts Operating 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 Miniature 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 Power 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 industrial sectors) and 11,385 

hours (residential sector). 

8.1.2 Overview of LCC and PBP Inputs 

As mentioned previously, the LCC represents the total consumer expense over the 

analysis period, including purchase expenses, operating costs (including energy expenditures), 

and installation costs. DOE discounts future operating costs to the time of purchase and sums 

them over the analysis period. The PBP represents the number of years it takes customers to 

recover the purchase price of more energy-efficient equipment through lower operating costs. 

8-3 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

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 tax markup in detail. 

•	 Installation Cost: This input represents the cost 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 installed 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 disposal costs represent the cost of recycling a 

ballast or fluorescent lamp, and 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: The 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 operating 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 the 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. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

•	 Lifetime: Lifetime is the total hours in operation after which the consumer retires the 

ballast from service. 

•	 Discount Rate: The discount rate 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 boxes indicate the inputs, 

the parallelograms indicate intermediate calculated 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 electricity price trend. DOE characterizes all of the 

total cost inputs with single-point values, but will characterize several 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 sector 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 value. 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 ⎛ OCt + RCt DC ⎞ LCC = IC +∑⎜

⎜ t + t ⎟⎟ t=1 (1+ r) (1+ r) ⎝ ⎠ Eq. 8.1 

Where: 

LCC = life-cycle cost ($), 

8-6 

EERE-2007-BT-STD-0016 COMMENT 20
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, replacement 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 customer price to install products (i.e., the cost for 

labor and materials; $). 

In the markups analysis (chapter 7), DOE develops end-user product prices and sales 

taxes to derive final product prices. DOE then applies installation 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 multiplicative 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 installation cost includes labor and overhead. Thus, 

the total installed cost equals the final product price plus the installation cost. DOE calculates the 

total installed cost for the ballasts analyzed based on the following equation: 

8-7 

EERE-2007-BT-STD-0016 COMMENT 20
IC = FPP + INST 

Eq. 8.3 = PRICE × MUTAX + INST 

Where: 

IC = total installed cost, 

FPP = final product price, 

INST = installation cost, 

PRICE = end-user product price, and 

MUTAX = 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 Ballast Rule”). 65 FR 56740; 10 CFR 430.23(m)(4). 

To account for relamping that occurs during the 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 occurrence of spot versus group relamping to 

derive weighted averaged relamping times. According 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 install 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 luminaire 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 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

 

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 welfare 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 $69.79 (in 2008$), 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 system 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 incurred in the operation of the lamp-and-ballast 

system. Below are the inputs for operating costs: 

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• annual operating hours 

• power rating (W) 

• electricity prices ($/kWh) 

• electricity price trends 

• discount rate (%) 

• analysis period (yrs) 

The analysis period, discount rate, and effective date of the amended standard are 

required for determining the operating cost and for establishing the operating cost present value. 

The electricity consumption for the baseline and 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 consumption. 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 cons × EP × EPT

Eq. 8.4 = (PWR ×OH )× EP × EPT 

Where: 

OC = operating costs, 

Econs = 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 information 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 determines 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 ballast service life, which is ultimately used in 

calculating the total replacement cost. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

As described in chapter 6, DOE establishes 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 building 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- and 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. 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. 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 average operating hours for affected lamp-and-ballast 

systems by 30 percent. Table 8.2.4 presents the 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 (in hours) to calculate the annual energy 

usage (in kilowatt-hours) of the lamp-and-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. 

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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 residential, commercial, or industrial price by 

dividing the residential, commercial, or industrial revenues by residential, commercial, or 

industrial sales. 

2. Calculate a regional average price, weighting each utility with customers in a region by 

the number of residential, commercial, or industrial consumers served in that region. 

The calculation uses the most recent available 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 needed 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 establishes 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, commercial, or industrial prices for 2008 and 2007. 

8.2.3.4 Electricity Price Trend 

The electricity price trend projects the future cost of electricity to 2030. DOE calculates 

the LCC and PBP using three separate projections from AEO2009: reference case, low economic 

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EERE-2007-BT-STD-0016 COMMENT 20
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 price 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 operation 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 Ballast Rule (49,054 hrs). Combining DOE’s estimate of 49,054 hours 

and the average operating hours for fluorescent lamps 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 average 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 rated 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. 

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As discussed in the technology assessment (chapter 3), ballast technology options 

(e.g., starting method) often affect the lifetime of the lamp. For 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 (total 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 first 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 cost inputs, as seen in the following equation: 

RC = FPPL + INSTL Eq. 8.5 = PRICE L TAX × MU + INSTL 

 Where: 

RC = replacement cost, expressed in dollars, 

FPPL = final product price (price for the product only) expressed in dollars, 

INSTL = installation cost, 

PRICEL = end-user product price expressed in dollars, and 

MUTAX = 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 disposing of lamps costs about 10 cents per linear 

foot.10 Ballast recycling rate data are not available, 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 released by the Association of Lighting and Mercury 

Recyclers in 2004 noted that, nationwide, approximately 30 percent of lamps used by businesses 

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and 2 percent of lamps in the residential sector are recycled.11 Thus, DOE applies a cost of 10 

cents per linear foot in the commercial and industrial 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 period is based on the baseline ballast life divided 

by the average annual operating hours for that ballast in a chosen sector. For example, the 

baseline ballast life for commercial and industrial sectors is 49,054 hours. 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 operating hours of this product 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 Crystal 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 discounts future expenditures to establish their 

present values. DOE derives the discount rates for this rulemaking separately for residential and 

commercial/industrial consumers. For residential consumers, DOE estimates the discount rate by 

looking across all possible debt or asset classes that might be used to purchase ballasts. For the 

commercial and industrial consumers, DOE estimates the cost of capital for 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 credit 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 accounts), 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 

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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 type 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 deductible. 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 rates 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 

% 

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Nominal 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 for 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 checking 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 returns on the Standard and Poor’s (S&P) 500 

1977–2005.17 The mutual fund rates are a weighted average 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 annual inflation rate in each year. Average nominal and real interest 

rates for the classes of assets are shown in Table 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 develops a normal probability 

distribution of interest rates for each asset type by using the mean value and standard deviation 

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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 equity 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 (Rf), 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 

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overall stock market. Betas usually vary between 0.5 and 2.0. A firm 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: 

ke = Rf + (β × ERP) Eq. 8.6

 Where: 

ke = the cost of equity for a company, expressed in dollars, 

Rf = 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 (kd) 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 and 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 the discount rate using the equation: 

k = k e e d d × w + k × w Eq. 8.7 

 Where: 

k= the (nominal) cost of capital, 

ke and kd = the expected rates of return on equity and debt, respectively, and 

we and wd = 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 Associates19 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 shows, 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, and valuation).21 

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Table 8.2.10. Variables Used to Estimate Company Discount Rates 

Variable Symbol Average Value 

% 

Source 

Risk-Free Asset Return Rf 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) kd 6.9 Damodaran Online 

Percent Debt Financing wd 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. However, 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 

survey23 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 from the U.S. Office of Management and Budget 

discount rate for investments in government 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 owner, commercial, and industrial 

company database. 

The cost of capital may be viewed as the discount 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 (commercial companies). 

Table 8.2.11. Real Discount Rates by Ballast Ownership Category 

Ownership Category Mean Real 

Discount Rate 

% 

Standard 

Deviation 

% 

Number of 

Observations 

8-21 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

Industrial 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 capital 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 ranges between 1.1 and 2.4 percent (Table 8.2.11). 

Different combinations of commercial property owners and commercial, industrial, and 

government buyers purchase the ballast types considered 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 category 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 Purchases 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 ballast 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 the different sectors as a weighted average 

of the distributions for the different 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 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

% 

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 that comply with the amended 

standard). DOE’s publication of a final rule in this standards 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 standards 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 versions of ballasts operating 

4-foot MBP lamps). 

Table 8.2.15. Effective Dates of Standards for Ballast 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. However, DOE bases the cost of the equipment on 

the most recent available data; all dollar values are expressed in 2008$. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

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 design) to the decrease in annual operating expenditures. This type of 

calculation is known as a “simple” PBP, because 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: 

ΔIC PBP = Eq. 8.9 ΔOC 

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 baseline (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 lamp-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 the 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 forth 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 

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EERE-2007-BT-STD-0016 COMMENT 20
rating of the lamp-and-ballast system by the usage profile (i.e., hours of operation) of that 

system. For the engineering analysis, DOE measured 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 presumption test in the LCC and PBP analyses, DOE 

is not performing a stand-alone rebuttable presumption analysis, as it is already embodied in the 

LCC 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 and the installation cost. The inputs to the operating costs are the 

lamp-and-ballast system input power rating, annual operating hours, and electricity cost. The 

PBP uses the same inputs as the LCC calculation described in section 8.2, except 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 conservation 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 consumer 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 ballast 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 standards 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 standards-compliant lamp (if available), but 

failed HO ballasts as well as residential ballasts and fixtures are expected to be replaced 

with magnetic ballasts or fixtures containing magnetic ballasts. Users who had a T8 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

ballast fail would be expected to replace it with 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 typical standards-compliant systems produce 

significantly (i.e., greater than 10 percent) more light 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 event, the spatial layout of fixtures in the 

building space is not constrained to any previous 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 instance, 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-Type 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-Type 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. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

Table 8.4.3. Framework of Event-Type 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 of LCC calculations for each baseline lamp-andballast system. Key inputs consist of using historical 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 that save energy and maintain light output above 

a maximum 10 percent decrease from the baseline 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, and 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 through Table 8.5.15 present the 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 installed 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 ( 

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EERE-2007-BT-STD-0016 COMMENT 20
Table 8.5.3), the higher CSLs exhibit both lower installed prices and lower operating costs than the 

F34T12 base case. 

8-28 

EERE-2007-BT-STD-0016 COMMENT 20
Table 8.5.1. LCC and PBP Results for Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U

the Commercial Sector (F32T8 Baseline) 

Event Response CSL Ballast 

Efficacy 

Factor 

(BEF) 

Lamp 

Type 

LCC 

$ 

LCC 

Savings 

$ 

Installed 

Price 

$ 

Operating 

Cost Savings 

$ 

I: Ballast Baseline 0/1 1.450 F32T8 273.24 N/A 55.87 N/A 

Failure/ Lamp and Ballast 2 1.535 F32T8 264.06 9.18 59.42 1.39 

Replacement Replacement 3 1.561 F32T8 263.48 9.76 57.98 16.79 

II: New Baseline 0/1 1.450 F32T8 275.52 N/A 58.27 N/A 

Construction/ Lamp and Ballast 2 1.535 F32T8 269.38 6.14 61.81 1.06 

Renovation Replacement 3 1.561 F32T8 266.18 9.34 60.38 16.10 

* 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-ShapeCommercial Sector 

Event Response CSL BEF Lamp 

Type 

LCC 

$ 

LCC 

Savings 

$ 

Installed 

Price 

$ 

Operating 

Cost Savings 

$ 

I: Ballast Baseline 0 1.418 F32T8 248.26 N/A 55.87 N/A 

Failure/ 

Replacement 

Lamp and Ballast 

Replacement 

1 1.518 F32T8 236.07 12.20 59.42 1.46 

II: New Baseline 0 1.418 F32T8 250.68 N/A 58.27 N/A 

Construction/ 

Renovation 

Lamp and Ballast 

Replacement 

1 1.518 F32T8 243.81 6.86 61.81 0.96 

* A number in parentheses indicates a negative value. 

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EERE-2007-BT-STD-0016 COMMENT 20
Table 8.5.3. LCC and PBP Results for Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot U

the Commercial Sector (F34T12 Baseline) 

Event Response CSL BEF Lamp 

Type 

LCC 

$ 

LCC 

Savings 

$ 

Installed 

Price 

$ 

Operating 

Cost Savings 

$ 

I: Ballast 

Failure/ 

Replacement 

Baseline 0 1.359 F34T12 308.59 N/A 68.41 N/A 

Lamp and Ballast 

Replacement 

1 1.450 F32T8 276.79 31.80 59.42 2.53 2 1.535 F32T8 262.63 45.96 57.98 3.92 3 1.561 F32T8 245.03 63.56 39.53 84.85 

II: New 

Construction/ 

Renovation 

Baseline 0 1.359 F34T12 310.89 N/A 70.81 N/A 

Lamp and Ballast 

Replacement 

1 1.450 F32T8 275.02 35.88 61.81 2.98 

2 1.535 F32T8 264.13 46.77 60.38 4.01 

3 1.561 F32T8 243.94 66.95 41.93 90.40 

* A number in parentheses indicates a negative value. For PBP, negative values indicate standards that reduce operating and installed c

Table 8.5.4. Summary of the LCC and PBP Results for 4-Lamp RS and IS Ballasts Operating 4-Foot MBP Shaped Lamps in the Commercial Sector 

Event Response CSL BEF Lamp 

Type 

LCC 

$ 

LCC 

Savings 

$ 

Installed 

Price 

$ 

Operating 

Cost Savings 

$ 

I: Ballast Baseline 0 0.768 F32T8 486.04 N/A 97.74 N/A 

Failure/ 

Replacement 

Lamp and Ballast 

Replacement 

1 0.781 F32T8 497.97 (11.93)* 101.29 (0.91) (

II: New Baseline 0 0.768 F32T8 488.29 N/A 100.14 N/A 

Construction/ 

Renovation 

Lamp and Ballast 

Replacement 

1 0.781 F32T8 489.25 (0.96) 103.68 0.28 

* A number in parentheses indicates a negative value.** An entry of “never” for PBP indicates standards that do not reduce operating costs.

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EERE-2007-BT-STD-0016 COMMENT 20
Table 8.5.5. LCC and PBP Results for Four-Lamp PS Ballasts Operating 4-Foot MBP and 2-Foot U-Shape

Commercial Sector 

Event Response CSL BEF Lamp 

Type 

LCC 

$ 

LCC 

Savings 

$ 

Installed 

Price 

$ 

Operating 

Cost Savings 

$ 

I: Ballast Baseline 0 0.708 F32T8 447.78 N/A 97.74 N/A 

Failure/ 

Replacement 

Lamp and Ballast 

Replacement 

1 0.755 F32T8 441.31 6.47 101.29 0.93 

II: New Baseline 0 0.708 F32T8 450.22 N/A 100.14 N/A 

Construction/ 

Renovation 

Lamp and Ballast 

Replacement 

1 0.755 F32T8 439.16 11.05 103.68 1.35 

Table 8.5.6. LCC and PBP Results for Two-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps iSector (F96T12HO/ES Baseline) 

Event Response CSL BEF Lamp Type LCC 

$ 

LCC 

Savings 

$ 

Installed 

Price 

$ 

Operating 

Cost Savings 

$ 

I: Ballast 

Failure/ 

Replacement 

Baseline 0 0.440 F96T12HO/ES 729.92 N/A 123.28 N/A 

Lamp and Ballast 

Replacement 

1 0.500 F96T12HO/ES 652.57 77.34 126.83 11.39 

1 0.550 F96T8HO 652.57 77.34 126.83 11.39 

2 0.549 F96T8HO 489.82 77.34 102.27 116.52 

II: New 

Construction/ 

Renovation 

Baseline 0 0.440 F96T12HO/ES 732.38 N/A 125.68 N/A 

Lamp and Ballast 

Replacement 

1 0.500 F96T12HO/ES 683.15 49.24 129.22 7.43 

1 0.550 F96T8HO 683.15 49.24 129.22 7.43 

2 0.549 F96T8HO 551.79 49.24 104.67 74.80 

* A number in parentheses indicates a negative value. 

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EERE-2007-BT-STD-0016 COMMENT 20
Table 8.5.7. LCC and PBP Results for Two-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps i

Sector (F96T8HO Baseline) 

Event Response CSL BEF Lamp Type LCC 

$ 

LCC 

Savings 

$ 

Installed 

Price 

$ 

Operating 

Cost Savings 

$ 

I: Ballast Baseline 0/1 0.550 F96T8HO 488.29 N/A 100.16 N/A 

Failure/ 

Replacement 

Lamp and Ballast 

Replacement 

2 0.549 F96T8HO 455.61 32.69 103.71 5.10 

II: New Baseline 0/1 0.550 F96T8HO 490.69 N/A 102.56 N/A 

Construction/ 

Renovation 

Lamp and Ballast 

Replacement 

2 0.549 F96T8HO 548.83 (58.14) 106.10 (7.68) (n

* 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 Lamps in the Com(F96T12ES Baseline) 

Event Response CSL BEF Lamp Type LCC 

$ 

LCC 

Savings 

$ 

Installed 

Price 

$ 

Operating 

Cost Savings 

$ 

I: Ballast Baseline 0 0.797 F96T12ES 502.49 N/A 97.09 N/A 

Failure/ 

Replacement 

Lamp and Ballast 

Replacement 

1 0.807 F96T12ES 501.41 1.09 100.63 0.50 

II: New Baseline 0 0.797 F96T12ES 504.79 N/A 99.49 N/A 

Construction/ 

Renovation 

Lamp and Ballast 

Replacement 

1 0.807 F96T12ES 503.99 0.80 103.03 0.47 

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EERE-2007-BT-STD-0016 COMMENT 20
Table 8.5.9. LCC and PBP Results for Two-Lamp IS Ballasts Operating 8-Foot Slimline Lamps in the Com

(F96T8 Baseline) 

Event Response CSL BEF Lamp Type LCC 

$ 

LCC 

Savings 

$ 

Installed 

Price 

$ 

Operating 

Cost Savings 

$ 

I: Ballast Baseline 0 0.790 F96T8 455.72 N/A 84.57 N/A 

Failure/ 

Replacement 

Lamp and Ballast 

Replacement 

1 0.809 F96T8 454.34 1.37 88.11 0.54 

II: New Baseline 0 0.790 F96T8 457.97 N/A 86.97 N/A 

Construction/ 

Renovation 

Lamp and Ballast 

Replacement 

1 0.809 F96T8 453.48 4.49 90.51 0.88 

Table 8.5.10. LCC and PBP Results for Two-Lamp PS Ballasts Operating 4-Foot T5 MiniBP SO Lamps in the 

Event Response CSL BEF Lamp Type LCC 

$ 

LCC 

Savings 

$ 

Installed 

Price 

$ 

Operating 

Cost Savings 

$ 

I: Ballast Baseline 0 1.309 F28T5 310.47 N/A 51.51 N/A 

Failure/ Lamp and Ballast 1 1.441 F28T5 276.71 33.76 55.06 4.07 

Replacement Replacement 2 1.482 F28T5 276.72 33.75 53.62 3.91 

II: New Baseline 0 1.309 F28T5 312.98 N/A 53.91 N/A 

Construction/ Lamp and Ballast 1 1.441 F28T5 279.01 33.98 57.45 4.09 

Renovation Replacement 2 1.482 F28T5 271.42 41.56 56.02 4.76 

* 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 t

Event Response CSL BEF Lamp Type LCC 

$ 

LCC 

Savings 

$ 

Installed 

Price 

$ 

Operating 

Cost Savings 

$ 

I: Ballast Baseline 0 0.688 F54T5HO 383.90 N/A 50.25 N/A 

Failure/ Lamp and Ballast 1 0.791 F54T5HO 348.05 35.85 53.80 5.54 

Replacement Replacement 2 0.837 F54T5HO 341.56 42.34 52.36 6.26 

II: New Baseline 0 0.688 F54T5HO 386.37 N/A 52.65 N/A 

Construction/ Lamp and Ballast 1 0.791 F54T5HO 350.48 35.89 56.19 5.55 

Renovation Replacement 2 0.837 F54T5HO 337.04 49.33 54.76 7.24 

8-33 

EERE-2007-BT-STD-0016 COMMENT 20
Table 8.5.12. LCC and PBP Results for Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot 

the Residential Sector (Low Power Factor, F34T12 Baseline) 

Event Response CSL BEF Lamp Type LCC 

$ 

LCC 

Savings 

$ 

Installed 

Price 

$ 

Operating 

Cost Savings 

$ 

I: Ballast Baseline 0 1.277 F34T12 123.98 N/A 68.41 N/A 

Failure/ Lamp and Ballast 1 1.457 F32T8 118.11 5.87 59.42 (0.29)* (

Replacement Replacement 2 1.492 F32T8 118.68 5.30 57.98 (0.49) 

II: New Baseline 0 1.277 F34T12 126.35 N/A 70.81 N/A 

Construction/ Lamp and Ballast 1 1.457 F32T8 108.17 18.18 61.81 0.90 

Renovation Replacement 2 1.492 F32T8 105.89 20.46 60.38 0.98 

* 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 standard

operating costs.

Table 8.5.13. LCC and PBP Results for Two-Lamp RS and IS Ballasts Operating 4-Foot MBP and 2-Foot the Residential Sector (Low Power Factor, F32T8 Baseline) 

Event Response CSL BEF Lamp Type LCC 

$ 

LCC 

Savings 

$ 

Installed 

Price 

$ 

Operating 

Cost Savings 

$ 

I: Ballast Baseline 0/1 1.457 F32T8 114.57 N/A 55.87 N/A 

Failure/ 

Replacement 

Lamp and Ballast 

Replacement 

2 1.492 F32T8 120.11 (5.54)* 59.42 (0.19) (

II: New Baseline 0/1 1.457 F32T8 116.96 N/A 58.27 N/A 

Construction/ 

Renovation 

Lamp and Ballast 

Replacement 

2 1.492 F32T8 119.37 (2.41) 61.81 0.11 

* A number in parentheses indicates a negative value.** An entry of “never” for PBP indicates standards that do not reduce operating costs.

8-34 

EERE-2007-BT-STD-0016 COMMENT 20
Table 8.5.14. LCC and PBP Results for Four-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps 

Temperature/Sign Ballasts) in the Commercial Sector 

Event Response CSL BEF Lamp Type LCC 

$ 

LCC 

Savings 

$ 

Installed 

Price 

$ 

Operating 

Cost Savings 

$ 

I: Ballast Baseline 0 0.196 F96T12HO 1479.28 N/A 151.24 N/A 

Failure/ 

Replacement 

Lamp and Ballast 

Replacement 

1 0.238 F96T12HO 1108.02 371.26 154.79 40.87 

II: New Baseline 0 0.196 F96T12HO 1481.58 N/A 153.64 N/A 

Construction/ 

Renovation 

Lamp and Ballast 

Replacement 

1 0.238 F96T12HO 1284.09 197.49 157.18 21.92 

Table 8.5.15. LCC and PBP Results for Four-Lamp RS and IS Ballasts Operating 8-Foot RDC HO Lamps Temperature/Sign Ballasts) in the Industrial Sector 

Event Response CSL BEF Lamp Type LCC 

$ 

LCC 

Savings 

$ 

Installed 

Price 

$ 

Operating 

Cost Savings 

$ 

I: Ballast Baseline 0 0.196 F96T12HO 1169.55 N/A 151.24 N/A 

Failure/ 

Replacement 

Lamp and Ballast 

Replacement 

1 0.238 F96T12HO 900.11 269.45 154.79 38.43 

II: New Baseline 0 0.196 F96T12HO 1171.88 N/A 153.64 N/A 

Construction/ 

Renovation 

Lamp and Ballast 

Replacement 

1 0.238 F96T12HO 1029.00 142.89 157.18 20.61 

8-35 

EERE-2007-BT-STD-0016 COMMENT 20
REFERENCES
 

1. U.S. Department of Energy–Energy Information Administration. Annual Energy Outlook 

2009 with Projections to 2030. March 2009. 

<http://www.eia.doe.gov/oiaf/aeo/excel/aeotab_3.xls> 

2. U.S. Department of Energy–Energy Efficiency and Renewable Energy. Office of Building 

Research and Standards: Technical 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> 

3. National Fire Protection Association. Online Access to National Electrical Code® 

Softbound 2005 Edition (NFPA 70TM). 2005. Quincy, MA. 

<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> 

5. E Source. Purchasing Advisor Web Page–Lighting: Occupancy Sensors. Boulder, CO. 

(Last Accessed May 5, 2009.) 

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

6. U.S. Department of Energy–Energy Information Administration. Form EIA-861 for 2006. 

2006. Washington, D.C. <http://www.eia.doe.gov/cneaf/electricity/page/eia861.html> 

7. U.S. Department of Energy–Energy Information Administration. Annual Energy Outlook 

2008. June 2008. Washington, D.C. 

<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. 

9. Economic Research Associates, Inc. and Quantec, LLC. Revised/Updated EULs Based On 

Retention and Persistence Studies Results. 2005. Southern California Edison. 

10. Environment, Health and Safety Online. EHSO’s Fluorescent Lights and Lighting Disposal 

and Recycling Web Page – Recycling Costs. Atlanta, GA. (Last Accessed April 28, 2009.) 

<http://www.ehso.com/fluoresc.php> 

11. Association of Lighting and Mercury Recyclers. National Mercury-Lamp Recycling Rate 

and Availability of Lamp Recycling Services in the U.S. Calistoga, CA. November 2004. 

12. The Federal Reserve Board. Survey of Consumer Finances. 

<http://www.federalreserve.gov/PUBS/oss/oss2/scfindex.html> 

8-36 

EERE-2007-BT-STD-0016 COMMENT 20
13. The Federal Reserve Board. Federal Reserve Statistical Release, Selected Interest Rates, 

Historical Data, Instrument: CDs (secondary market), Maturity: 6-month, Frequency: 

Annual, Description: Average rate on 6-month negotiable certificates of deposit (secondary 

market), quoted on an investment basis. 2006. Washington, D.C. 

<http://www.federalreserve.gov/releases/H15/data.htm> 

14. The Federal Reserve Board. Federal Reserve Statistical Release, Selected Interest Rates, 

Historical Data, Instrument: State and local bonds, Maturity: 20-year, Frequency: Monthly, 

Description: Bond buyer go 20-bond municipal bond index. 2006. Washington, D.C. 

<http://www.federalreserve.gov/releases/H15/data.htm> 

15. The Federal Reserve Board. Federal Reserve Statistical Release, Selected Interest Rates, 

Historical Data, Instrument: Corporate bonds/Moody’s Seasoned AAA, Frequency: 

Annual, Description: Moody’s yield on seasoned corporate bonds – all industries, AAA. 

2006. Washington, D.C. <http://www.federalreserve.gov/releases/H15/data.htm> 

16. Mortgage-X. Mortgage Information Service: Cost of Savings Index (COSI) Index History. 

2006. <http://mortgage-x.com/general/indexes/default.asp> The September, 12, 2007 

material from this website is available in Docket #EE–2006–STD–0131. For more 

information, contact Brenda Edwards Jones at (202) 586-2945. 

17. Damodaran Online. The Data Page: Historical Returns on Stocks, Bonds, and Bills – 

United States. 2006. <http://pages.stern.nyu.edu/~adamodar> The September 12, 2007 

material from this website is available in Docket #EE–2006–STD–0131. For more 

information, contact Brenda Edwards Jones at (202) 586-2945. 

18. Modigliani, F. and M. Miller. The Cost of Capital, Corporation Finance and the Theory of 

Investment. American Economic Review. 1958. (June): pp. 261–297. 

19. Ibbotson’s Associates. Stocks, Bonds, Bills, and Inflation, Valuation Edition, 2001 

Yearbook. 2001. 

20. Damodaran, A. Damodaran Online. Historical Returns on Stocks, Bonds and Bills – United 

States. <http://pages.stern.nyu.edu/~adamodar> 

21. Damodaran, A. Damodaran Online. Current U.S. Data. 

<http://pages.stern.nyu.edu/~adamodar> 

22. U.S. Department of Commerce–Bureau of Economic Analysis. Table 1.1.9 Implicit Price 

Deflators for Gross Domestic Product. 2008. 

<http://www.bea.gov/national/nipaweb/SelectTable.asp?Selected=N> 

23. Value Line. Value Line Investment Survey. 2007. <http://www.valueline.com> 

24. U.S. Office of Management and Budget. Circular No. A-94. Appendix C. 2008. 

<http://www.whitehouse.gov/omb/circulars/a094/a94_appx-c.html> 

8-37 

EERE-2007-BT-STD-0016 COMMENT 20
25. Federal Reserve Board. Statistics: Releases and Historical Data – Selected Interest Rates – 

State and Local Bonds. 2008. 

<http://www.federalreserve.gov/releases/h15/data/Monthly/H15_SL_Y20.txt> 

26. U.S. Department of Energy–Energy Information Administration. Commercial Buildings 

Energy Consumption Survey: Commercial Energy Uses and Costs. 2003. Washington, 

D.C. <http://www.eia.doe.gov/emeu/cbecs/> 

8-38 

EERE-2007-BT-STD-0016 COMMENT 20
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 Construction/Renovation......................................................................... 9-4 

9.3 BASE-CASE INPUTS AND FORECASTS ...................................................................... 9-6 

9.3.1 Base-Case Scenarios 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 Installed 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-and-Ballast Replacement Trends................................ 9-4 

Table 9.3.1. Total Historical Fluorescent Ballast Shipments (millions)...................................... 9-9 

Table 9.3.2. Historical Fluorescent Ballast Shipments by Estimated Life Event (millions) ..... 9-10 

Table 9.3.3. 2006 Ballast Stocks (millions)............................................................................... 9-11 

Table 9.3.4. Weighted Apportionments for Standard- and High-Efficiency 4-Foot T8 

MBP Ballasts ..................................................................................................... 9-12 

Table 9.3.5. Base-Case Initial Market-Share Apportionments for Two-Lamp RS and IS
 

Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps (F34T8 

Baseline) ............................................................................................................ 9-12 

Table 9.3.6. Base-Case Initial Market-Share Apportionments 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 Apportionments for Two-Lamp RS and IS
 

Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps (F34T12 

Baseline) ............................................................................................................ 9-12 

Table 9.3.8. Base-Case Initial Market-Share Apportionments for Four-Lamp RS and IS
 

Ballasts Operating 4-Foot MBP and 2-Foot U-Shaped Lamps ......................... 9-13 

Table 9.3.9. Base-Case Initial Market-Share Apportionments for Four-Lamp PS Ballasts 

Operating 4-Foot MBP and 2-Foot U-Shaped Lamps ....................................... 9-13 

9-i 

EERE-2007-BT-STD-0016 COMMENT 20
Table 9.3.10. Base-Case Initial Market-Share Apportionments 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 Apportionments 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 Apportionments for Two-Lamp IS Ballasts 

Operating 8-Foot Slimline Lamps (F96T12/ES Baseline)................................. 9-13 

Table 9.3.13. Base-Case Initial Market-Share Apportionments for Two-Lamp IS Ballasts 

Operating 8-Foot Slimline Lamps (F96T8 Baseline) ........................................ 9-13 

Table 9.3.14. Base-Case Initial Market-Share Apportionments for Two-Lamp PS Ballasts 

Operating 4-Foot T5 MiniBP SO Lamps........................................................... 9-14 

Table 9.3.15. Base-Case Initial Market-Share Apportionments for Two-Lamp PS Ballasts 

Operating 4-Foot T5 MiniBP HO Lamps .......................................................... 9-14 

Table 9.3.16. Base-Case Initial Market-Share Apportionments 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 Apportionments 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 Apportionments 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 Forecasted Ballast Shipments (Existing and 

Emerging Technologies Scenarios) ................................................................... 9-15 

Figure 9.3.2. 8-Foot RDC HO Base-Case Forecasted 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 and Emerging Technologies Scenarios)..... 9-17 

Figure 9.3.6. Base-Case Forecasted Shipments for Sign Ballasts Operating 8-Foot RDC 

HO Lamps.......................................................................................................... 9-18 

Figure 9.3.7. 4-Foot MBP Base-Case Ballast Shipments Forecast by Market Segment ........... 9-19 

Figure 9.3.8. 8-Foot RDC HO Base-Case Ballast Shipments Forecast by Market Segment .... 9-19 

Figure 9.3.9. 8-Foot Slimline Base-Case Ballast Shipments Forecast by Market Segment...... 9-20 

Figure 9.3.10. 4-Foot MiniBP SO and HO Ballast Shipments Forecast by Market 

Segment.............................................................................................................. 9-20 

9-ii 

EERE-2007-BT-STD-0016 COMMENT 20
Figure 9.5.1. 4-Foot MBP Base Case and Standards-Case Ballast Shipments Forecasts 

(Emerging Technologies, Roll-Up Scenario) .................................................... 9-22 

Figure 9.5.2. 4-Foot MBP Base Case and Standards-Case Ballast Shipments Forecasts 

(Existing Technologies, Shift Scenario) ............................................................ 9-23 

Figure 9.5.3. 8-Foot RDC HO (including Cold Temperature/Sign) Base Case and 

Standards-Case Ballast Shipments Forecasts (Existing Technologies, Shift 

Scenario) ............................................................................................................ 9-23 

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) .............................................................................................. 9-24 

Figure 9.5.5. 8-Foot Slimline Base Case and Standards-Case Ballast Shipments Forecasts 

(Existing Technologies, Shift Scenario) ............................................................ 9-24 

Figure 9.5.6. 8-Foot Slimline Base Case and Standards-Case Ballast Shipments Forecasts 

Figure 9.5.7. 4-Foot MiniBP SO and HO Base Case and Standards-Case Ballast 

Figure 9.5.8. 4-Foot MiniBP SO and HO Base Case and Standards-Case Ballast 

(Emerging Technologies, Roll-Up Scenario) .................................................... 9-25 

Shipments Forecasts (Existing Technologies, Shift Scenario) .......................... 9-25 

Shipments Forecasts (Emerging Technologies, Roll-Up Scenario) .................. 9-26 

9-iii 

EERE-2007-BT-STD-0016 COMMENT 20
 

CHAPTER 9. SHIPMENTS ANALYSIS
 

9.1 INTRODUCTION 

Shipments of fluorescent lamp ballasts (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 rulemaking (NOPRs). This chapter describes DOE’s 

methodology for projecting annual shipments and presents 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 absence of amended Federal energy conservation 

standards. In determining the base case, DOE considers historical shipments, emerging 

technologies, the mix of efficiencies sold in the 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 what 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 methodology for ballasts; section 9.3 describes the data 

inputs, historical shipments, base-case scenarios, and shipments forecasts; section 9.4 discusses 

the impacts of proposed amended standards on the mix of ballast designs; and section 9.5 

presents the shipments results for the different 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 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 annual shipment projections, 2006–2044. 

9.2.1 Analyzed Product Classes, Market Sectors, and Market Segments 

DOE forecasted annual shipments for the ballast 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

Table 9.2.1. Product Classes and Market Sectors 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 specific 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 market segment, DOE makes certain assumptions 

about how consumers are likely to purchase new ballasts 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 (and 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 lampand-ballast system with two two-lamp, 4-foot MBP lamp-and-ballast systems). Table 9.2.2 

below presents a full listing of the modeled lamp-and-ballast system replacement trends. 

9-3 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

 

Table 9.2.2. Modeled Fluorescent Lamp-and-Ballast Replacement Trends 

Retired Lamp-and-Ballast System Replacement 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 replacements 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 percent 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 distribution of expected failure rates throughout 

ballast lifetimes. 

DOE calculated average commercial and industrial ballast service lifetimes 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 construction and renovation by deriving growth rates for each product 

class. The growth rates are based on EIA’s Annual Energy Outlook 2009 (AEO2009),1,2 which 

estimates annual commercial floor space and residential building growth. Because the AEO2009 

considers future trends in economic growth, DOE incorporated macroeconomic conditions in its 

9-4 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

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 intensity of ballasts per unit of 

floor space remains constant (i.e., sector growth rates are assumed 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 research 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 exception 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 systems. 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 migration requires the purchase of a new fixture, 

to establish 4-foot MiniBP T5 SO shipments, DOE allotted a portion of what would otherwise be 

the 4-foot MBP fixture new construction/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 shipments model, DOE holds the 

resulting percentage—approximately 12.5 percent of the new construction/renovation market— 

constant throughout the analysis period. 

In the industrial sector, confidential historical 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 systems (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 light output. Historical shipment data for 8-foot 

RDC HO lamps shows substantial 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 shipments, DOE assumed that these systems were 

9-5 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

penetrating both the 8-foot RDC HO and HID markets. Similar to its analysis for T5 SO systems, 

DOE established that the new construction/renovation market segment 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 total 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 systems fully penetrate the 8-foot RDC HO new 

construction/renovation market segment as well as the HID new construction/renovation market 

segment. These same assumptions are applied 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 systems. Consequently, DOE models only 4-foot 

T8 MBP lamp-and-ballast systems for new construction in the residential 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 scenarios 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 (CMH) 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 their 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 technology—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 technologies. DOE believes evaluating 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 case does not affect the relative benefits of each 

CSL and prevents uncertain projections of market share, price, or performance from obscuring 

the benefits derived from more efficient ballast designs alone. 

The assumptions and methodology that drive these 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 analyzed 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 penetration achieved by a technology. 

9-6 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

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 those covered by this 

rulemaking were analyzed in the existing technologies scenario. 

In the emerging technologies scenario, DOE attempts to forecast the market penetration 

of both mature technologies and those technologies that are still undergoing significant changes 

in price and efficiency. Specifically, DOE considered 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 relative to the fluorescent lamp-and-ballast system it 

replaces. Specifically, DOE uses the following formula to calculate simple PBP: 

− ΔPurchase Price ($/klm) Simple Payback = ΔAnnual Electricity Cost ($/klm/yr) + ΔAnnual Replacement Cost ($/klm/yr) 

Where: 

Δ = the difference between the two technology options compared, 

Purchase Price = includes the lamp price and fixture price, 

Annual Electricity Cost = 

a function of the mean annual operating 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 PBP 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 penetration 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 penetration; 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 penetration. The 5-year average represents the time DOE 

assumed it takes products with lower PBPs to penetrate the market. 

Fourth, when necessary, DOE applied a scaling factor to the predicted market penetration 

to account for observed market trends. Fifth, as stated above, DOE reduced the projected 

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EERE-2007-BT-STD-0016 COMMENT 20
installed stock of covered 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 lowering the energy savings of a potential new 

standard. For those covered ballasts remaining, the cost effectiveness 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 mature technologies in the 

current market show the potential to penetrate the fluorescent ballast market significantly. 

(A rapidly growing market, T5 systems are considered 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 previous 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 replacement for a 4-foot MBP lamp-and-ballast system. 

DOE used the retrofit kit as a current baseline from 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 other 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 replacements, see appendix 10C of the GSFL/IRL 

NOPR TSD.4

 Following the five-step process described 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 require their own specific fixtures. 

In this rulemaking, DOE also analyzed the potential penetration of CMH into the 

fluorescent lighting market. DOE first estimated current CMH prices using a methodology 

similar to the methodology it used to estimate GSFL 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 systems (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. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

9.3.2.1 Historical Shipments 

DOE used U.S. Census Bureau Current Industrial Reports (CIR) for 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 fluorescent ballasts (CIRs for ballasts 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 available data, and/or market trends 

identified in ballast manufacturer interviews, the proposed lamps rulemaking, and the 

Fluorescent Ballasts Energy Conservation Standards Final Rule published 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 specific ballast designs, DOE 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 ballast 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 manufacturer interviews and 

conservative estimates, NEMA shipments 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 

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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 million ballasts in 1990 to 127.8 million ballasts in 

2005. In the absence of clear data on historical ballasts stock, DOE judged that this very strong 

growth in ballasts shipments was unlikely to reflect equivalent growth in ballasts stock, and 

would likely not persist through 2044. Rather, DOE 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 technologies 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 that the remainder of the strong growth in 

fluorescent lamp ballasts shipments was due to technology-induced retrofits. Accordingly, DOE 

calculates the installed stock in 2006 as the estimated share of historical shipments that are not 

due to technology-induced retrofits. DOE then extrapolated an adjusted shipments estimate by 

taking the difference between the 1990–2005 shipments growth rates and the 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 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

DOE then produced stock estimates by summing backwards from 2005 and applying 

ballast product lifetimes to this adjusted shipments estimate. To accurately forecast ballast 

shipments, DOE assumed a ballast age distribution for the installed ballast stocks using trends in 

ballast shipments, calibrated to the available shipment data. Table 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 systems. 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 preferences. 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 system properties such as price and energy 

consumption are key inputs to the NES and NPV calculations. Therefore, within each product 

class, DOE believes it is necessary to directly account for the mix of technologies that consumers 

select in the base and standards case. To account for the range of possible consumer choices, 

DOE develops technology market-share apportionments. These market-share apportionments are 

used to estimate historical shipments and installed stock for each ballast design in the base and 

standards 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 detailed historical ballast shipment data from NEMA to 

develop percentage market shares for the analyzed ballast designs. However, based on 

manufacturer interviews, DOE was able to develop a general assumed 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 apportionments for the two efficiency levels. 

Specifically, DOE assumes that 69 percent of shipped 4-foot T8 MBP electronic ballasts are 

standard-efficiency designs, and 31 percent are high-efficiency designs. 

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EERE-2007-BT-STD-0016 COMMENT 20
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 Wholesaler Weighted Average 

Standard 80 50 69 

High 20 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 shipments model, as it reflects the assumed tendency of 

most consumers to minimize their first cost and select standard-efficiency designs if not 

otherwise required. Consequently, for each product class in the base case, DOE apportions 69 

percent of shipments to the baseline ballast design, 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 designs in each product class. 

Table 9.3.5. Base-Case Initial Market-Share Apportionments for Two-Lamp RS and IS 

Ballasts Operating 4-Foot MBP and 2-Foot 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 Apportionments 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 Apportionments 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 

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EERE-2007-BT-STD-0016 COMMENT 20
Table 9.3.8. Base-Case Initial Market-Share Apportionments 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 Apportionments 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 Apportionments 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 Apportionments 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 Apportionments 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 Apportionments 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 

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EERE-2007-BT-STD-0016 COMMENT 20
Table 9.3.14. Base-Case Initial Market-Share Apportionments 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 Apportionments 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 Apportionments 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 Apportionments 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 Apportionments 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 base-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. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

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 their 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 retrofits 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 lifetimes (section 9.2.1.1). Also note that shipments of T12 ballasts are 

near zero during the analysis period because they are being substituted by T8 ballasts. 

For categories of ballasts expected to experience penetration by LED lamps and other 

emerging technologies (4-foot MBP category, and 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 ballast 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

0 

50,000 

100,000 

150,000 

200,000 

250,000 

300,000 

350,000 

Shipments 

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 Forecasted Ballast Shipments (Existing and 

Emerging Technologies Scenarios, Excluding Sign Ballasts) 

2,500,000
 

2,000,000
 

Shipments 

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 Forecasted Ballast Shipments (Existing and 

Emerging Technology Scenarios) 

9-16 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

0 

5,000,000 

10,000,000 

15,000,000 

20,000,000 

25,000,000 

30,000,000 

35,000,000 

40,000,000 

45,000,000 

Shipments 

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-Case Forecasted Ballast Shipments (Existing 

and Emerging Technologies Scenarios) 

35,000,000
 

30,000,000
 

Shipments 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 Technologies Scenarios) 

9-17 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

Shipments 

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 for 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 construction/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 construction/renovation. Note that 8-foot slimline ballasts are only 

shipped for replacement (Figure 9.3.9). They are substituted in the new construction by T5 

ballast systems. The figures below are for the existing technologies scenario. 

9-18 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

0.00 

0.02 

0.04 

0.06 

0.08 

0.10 

0.12 

0.14 

Shipments (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 

0.0060 

Shipments (billions) 

New Construction Ballast Replacement 

Year 

Figure 9.3.8. 8-Foot RDC HO Base-Case Ballast Shipments Forecast by Market Segment 

9-19 

EERE-2007-BT-STD-0016 COMMENT 20
 

0.0000 

0.0005 

0.0010 

0.0015 

0.0020 

0.0025 

Shipments (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 

0.0250 

Shipments (billions) 

New Construction Ballast Replacement 

Year 

Figure 9.3.10. 4-Foot MiniBP SO and HO Ballast Shipments Forecast by Market Segment 

9-20 

EERE-2007-BT-STD-0016 COMMENT 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 take 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 scenarios 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 standards case in which all product efficiencies in the 

base case that do not meet the standard would roll 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 ballast or lamp-and-ballast system in the roll-up 

scenario. The roll-up scenario characterizes consumers primarily driven by the first-cost of the 

analyzed 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 standards 

case 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 consumers 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 previously demanded system except where additional replacement 

trends are modeled (as given in Table 9.2.2). The structure 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 shipments 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 principal events that prompt ballast purchases: 

(1) ballast failure/replacement; and (2) new construction/renovation. 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

9.5 RESULTS 

The following sections show the shipments forecasts 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 scenario are presented in preliminary TSD chapter 10. 

Figure 9.5.1 through Figure 9.5.8 present the shipments forecasts for the base case and 

standards-cases for ballasts in the existing technologies/shift and the emerging technologies/rollup scenarios scenario. As noted, these reflect the upper- and lower-bound scenarios for energy 

use. For the standards case, shipments are shown at what they are modeled as in the CSL 3 

scenario. Please note that if the line does not show 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, and new construction/renovation. As discussed earlier, instead of 

using each particular ballast design’s individual 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 change 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) 

9-22 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

0.06 

0.05 

0.04 

0.03 

0.02 

0.01 

0.00 

2014 2018 2022 2026 2030 2034 2038 2042 

Year 

Shipments (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 Technologies, Shift Scenario) 

0.01 

0.01 

2014 2018 2022 2026 2030 2034 2038 2042 

Shipments (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) 

9-23 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

0.01
 

0.01
 

0.00
 

0.00
 

0.00
 

0.00
 

0.00
 

Year
 

2014 2018 2022 2026 2030 2034 2038 2042 

Shipments (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 

Year 

Shipments (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 Standards-Case Ballast Shipments Forecasts 

(Existing Technologies, Shift Scenario) 

9-24 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

0.00
 

0.00
 

0.00
 

0.00
 

0.00
 

0.00
 

2014 2018 2022 2026 2030 2034 2038 2042 

Year 

Shipments (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 Standards-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 2042 

Shipments (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 Case and Standards-Case Ballast Shipments 

Forecasts (Existing Technologies, Shift Scenario) 

9-25 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

Shipments (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 Case 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 shipments 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 the 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 Technologies, 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 

9-26 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Four-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 

9-27 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

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 252,219,540 -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 

EERE-2007-BT-STD-0016 COMMENT 20
 

REFERENCES 

1. U.S. Department of Energy–Energy 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/servicerpt/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 Standards for General Service Fluorescent Lamps 

and Incandescent Reflector Lamps. January, 2009. Washington, D.C. 

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

EERE-2007-BT-STD-0016 COMMENT 20
 

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 Efficiency Distributions............................................ 10-2
 

10.2.2 Installed Ballast Stock ..................................................................................... 10-13
 

10.2.3 Average Ballast Efficiency 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, Ventilation, 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 Distributions (Existing Technologies, Shift 

Scenario) ........................................................................................................................ 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) ........................................................................................................................ 10-4 

Table 10.2.3. Ballasts Operating 4-Foot MBP Lamps (Residential), Base Case and 

Standards Case Efficiency Distributions (Emerging Technologies, Shift Scenario)..... 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) ........................................................................................................................ 10-5 

10-i 

EERE-2007-BT-STD-0016 COMMENT 20
 

Table 10.2.5. Ballasts Operating 4-Foot MBP Lamps (Commercial), Base Case and 

Standards Case Efficiency Distributions (Existing Technologies, Shift Scenario) ....... 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) ........................................................................................................................ 10-6 

Table 10.2.7. Ballasts Operating 4-Foot MBP Lamps (Commercial), Base Case and 

Standards Case Efficiency Distributions (Emerging Technologies, Shift Scenario)..... 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) ........................................................................................................................ 10-7 

Table 10.2.9. Ballasts Operating 8-Foot Single Pin (Slimline) Lamps, Base Case and 

Standards Case Efficiency Distributions (Existing Technologies, Shift Scenario) ....... 10-7 

Table 10.2.10. Ballasts Operating 8-Foot Slimline Lamps, Base Case and Standards Case 

Efficiency Distributions (Existing Technologies, 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 Technologies, Roll-Up Scenario)......................... 10-9 

Table 10.2.13. Ballasts Operating 8-Foot Recessed Double Contact (RDC) High Output 

(HO) Lamps, Base Case and 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 (Existing Technologies, Roll-Up Scenario)................. 10-10 

Table 10.2.15. Ballasts Operating 8-Foot RDC HO Lamps, Base Case and Standards 

Case Efficiency Distributions (Emerging 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 Miniature Bipin (MiniBP) Standard Output 

(SO) and HO Lamps, Base Case and Standards Case Efficiency Distributions 

(Existing Technologies, Shift Scenario) ...................................................................... 10-11 

Table 10.2.18. Ballasts Operating 4-Foot T5 MiniBP SO and HO Lamps, Base Case and 

Standards Case Efficiency Distributions (Existing Technologies, Roll-Up 

Scenario) ...................................................................................................................... 10-12 

Table 10.2.19. Ballasts Operating 4-Foot T5 MiniBP SO and HO Lamps, Base Case and 

Standards Case Efficiency Distributions (Emerging Technologies, Shift Scenario)... 10-12 

Table 10.2.20. Ballasts Operating 4-Foot T5 MiniBP SO and HO Lamps, Base Case and 

Standards Case Efficiency Distributions (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 and Net Present Value Inputs ..................................... 10-33 

Table 10.5.2. Cumulative National Energy Savings for Ballasts under the Existing, Shift 

Scenario (2014-2044)................................................................................................... 10-34 

Table 10.5.3. Cumulative National Energy Savings for Ballasts under the Emerging, 

Roll-Up Scenario (2014-2044) .................................................................................... 10-35 

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EERE-2007-BT-STD-0016 COMMENT 20
 

Table 10.5.4. Cumulative NPV Results for Ballasts Under the Existing Technologies, 

Shift Scenario (2014-2044).......................................................................................... 10-42 

Table 10.5.5. Cumulative NPV Results for Ballasts Under the Emerging Technologies, 

Roll-Up Scenario (2014-2044) .................................................................................... 10-42 

LIST OF FIGURES 

Figure 10.2.1. 4-Foot MBP (Residential) Installed Ballast Stock (CSL 3) ............................. 10-14 

Figure 10.2.2. 4-Foot MBP (Commercial) Installed Ballast Stock (CSL 3)............................ 10-14 

Figure 10.2.3. 8-Foot Slimline Installed Ballast Stock (CSL 3).............................................. 10-15 

Figure 10.2.4. 8-Foot RDC HO Installed 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 Stock, Ballasts Operating 4-Foot MBP Lamps 

(Residential, Existing Technologies, Shift Scenario)* ................................................ 10-17 

Figure 10.2.7. Average Efficiency of Stock, Ballasts Operating 4-Foot MBP Lamps 

Figure 10.2.8. Average Efficiency of Stock, Ballasts Operating 4-Foot MBP Lamps 

Figure 10.2.9. Average Efficiency of Stock, Ballasts Operating 4-Foot MBP Lamps 

Figure 10.2.10. Average Efficiency of Stock, Ballasts Operating 4-Foot MBP Lamps 

Figure 10.2.11. Average Efficiency of Stock, Ballasts Operating 4-Foot MBP Lamps 

Figure 10.2.12. Average Efficiency of Stock, Ballasts Operating 4-Foot MBP Lamps 

Figure 10.2.13. Average Efficiency of Stock, 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, Ballasts Operating 4-Foot T5 MiniBP SO 

(Residential, Existing Technologies, 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 Technologies, Roll-Up Scenario) ........................................... 10-19 

(Commercial, Emerging Technologies, Roll-Up Scenario)......................................... 10-20 

(Commercial, Emerging Technologies, 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 Technologies, Shift Scenario)*........................................... 10-25 

10-iii 

EERE-2007-BT-STD-0016 COMMENT 20
 

Figure 10.2.23. Average Efficiency of Stock, Ballasts Operating 4-Foot T5 MiniBP SO 

and HO Lamps (Existing Technologies, Roll-Up Scenario)* ..................................... 10-25 

Figure 10.2.24. Average Efficiency of Stock, Ballasts Operating 4-Foot T5 MiniBP SO 

and HO Lamps (Emerging Technologies, Roll-Up Scenario)*................................... 10-26 

Figure 10.2.25. Average Efficiency of Stock, Ballasts Operating 4-Foot T5 MiniBP SO 

and HO Lamps (Emerging Technologies, Shift Scenario)* ........................................ 10-26 

Figure 10.5.1. National Annual Total Installed Equipment and Operating Cost Savings 

for 4-Foot MBP (Residential) at CSL3 (Existing Technologies, Shift Scenario) 

Discounted at 7 Percent per Year................................................................................. 10-36 

Figure 10.5.2. National Annual Total Installed Equipment and Operating Cost Savings 

for 4-Foot MBP (Residential) at CSL3 (Emerging Technologies, Roll-Up 

Scenario) Discounted at 7 Percent per Year ................................................................ 10-36 

Figure 10.5.3. National Annual Total Installed Equipment and Operating Cost Savings 

for 4-Foot MBP (Commercial) at CSL3 (Existing Technologies, Shift Scenario) 

Discounted at 7 Percent per Year................................................................................. 10-37 

Figure 10.5.4. National Annual Total Installed Equipment and Operating Cost Savings 

for 4-Foot MBP (Commercial) at CSL3 (Existing Technologies, Shift Scenario) 

Discounted at 7 Percent per Year................................................................................. 10-37 

Figure 10.5.5. National Annual Total 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 Total Installed Equipment and Operating Cost Savings 

for 8-Foot Slimline at CSL3 (Emerging Technologies, Roll-Up Scenario) 

Discounted at 7 Percent per Year................................................................................. 10-38 

Figure 10.5.7. National Annual Total 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 Total Installed Equipment and Operating Cost Savings 

for 8-Foot RDC HO at CSL3 (Emerging Technologies, Roll-Up Scenario) 

Discounted at 7 Percent per Year................................................................................. 10-39 

Figure 10.5.9. National Annual Total 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 Total Installed Equipment and 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

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 result 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 and 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 the representative ballast product classes. 

DOE performs all NIA calculations using a Microsoft Excel spreadsheet, available at 

www.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_ballasts.html. 

Appendix 10A provides instructions for using the spreadsheet. 

The following sections describe in detail 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 information 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 the 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 forecasts (such as equipment costs and operating 

costs) and projected ballast stocks (such as average efficiency and energy consumption) are key 

10-1 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

aspects of DOE’s NES and NPV estimates. This section describes these key characteristics of 

stock and shipments as they relate to the NES and NPV. Note that the representative product 

classes addressed individually in the NES and NPV results are aggregated in broader groupings 

for describing stock and shipment characteristics (e.g., ballasts operating T12 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 incurred. 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 energy consumption is a function of lamp-andballast system characteristics in the installed stock. The total installed stock of lamp-and-ballast 

systems is used to determine total annual energy 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 ballast 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-andballast system design. 

Sections 10.3.2 and 10.4.2 discuss inputs to calculation of the NES and NPV in further 

detail. 

The following sections detail the forecasted distribution of efficiencies, 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 with 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-case and standards-case efficiency 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 characterize the shipments of ballasts for each 

analyzed product class. The forecasted efficiency distributions of shipments for ballasts depend 

directly on these apportionments and the total shipments of a particular ballast type in each year 

of the analysis period. 

Table 10.2.1 through Table 10.2.20 show the percentage 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

There are two tables per representative ballast product class: one depicting the efficiency 

mixes in the existing technologies shift scenario and one depicting those in the emerging 

technologies roll-up scenario. Emerging technologies scenarios address the penetration of 

particular ballast markets by light-emitting diode (LED) products; chapter 9 discusses these 

scenarios in further detail. Because consumers in the shift scenario make purchase decisions 

based more on the energy savings of a particular ballast design, the shift scenario often presents a 

more aggressive forecasted efficiency 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 scenarios 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 product classes are smaller than they are in existing technologies, any 

substitution trends based on these product classes are smaller as well. To the extent that these 

substitution trends affect the efficiency 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 Technologies, Shift Scenario) 

Year CSL Proportions of All 4-Foot MBP (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 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 MBP (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 MBP (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 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 MBP (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 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 

10-7 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 Recessed Double Contact (RDC) High Output 

(HO) Lamps, Base Case and Standards Case 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

Table 10.2.14. Ballasts Operating 8-Foot RDC HO Lamps, 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 Lamps, 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

Table 10.2.16. Ballasts Operating 8-Foot RDC HO Lamps, 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 Miniature Bipin (MiniBP) Standard Output 

(SO) and HO Lamps, Base Case and Standards 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

Table 10.2.18. Ballasts Operating 4-Foot T5 MiniBP 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 MiniBP 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

Table 10.2.20. Ballasts Operating 4-Foot T5 MiniBP 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 technologies 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 available CSL 3 efficiency level option. The difference between the 

emerging technologies and existing technologies scenarios, as noted earlier, is that shipments are 

smaller in the emerging technologies case for affected 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 RDC 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 overall stock, and drive its growth 

(Figure 10.2.4). 

10-13 

EERE-2007-BT-STD-0016 COMMENT 20
 

Figure 10.2.1. 4-Foot MBP (Residential) Installed Ballast Stock (CSL 3) 

Figure 10.2.2. 4-Foot MBP (Commercial) Installed Ballast Stock (CSL 3) 

10-14
 

EERE-2007-BT-STD-0016 COMMENT 20
 

Figure 10.2.3. 8-Foot Slimline Installed Ballast Stock (CSL 3) 

Figure 10.2.4. 8-Foot RDC HO Installed Ballast Stock (CSL 3) 

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EERE-2007-BT-STD-0016 COMMENT 20
 

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 efficiency 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 technologies/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 ballast efficiency, which results in overlapping 

curves in the figures. These figures’ titles are noted with a “*”. 

10-16 

EERE-2007-BT-STD-0016 COMMENT 20
 

1.44

1.45

1.46

1.47

1.48

1.49

1.5

1.51

2014201620182020202220242026202820302032203420362038204020422044

Average BEF

Base Case

CSL 1

CSL 2

CSL 3

Figure 10.2.6. Average Efficiency of Stock, Ballasts Operating 4-Foot MBP Lamps 

(Residential, Existing Technologies, Shift Scenario)* 

1.44

1.45

1.46

1.47

1.48

1.49

1.5

1.51

2014201620182020202220242026202820302032203420362038204020422044

Average BEF

Base Case

CSL 1

CSL 2

CSL 3

Figure 10.2.7. Average Efficiency of Stock, Ballasts Operating 4-Foot MBP Lamps 

(Residential, Existing Technologies, Roll-Up Scenario)* 

10-17 

EERE-2007-BT-STD-0016 COMMENT 20
 

1.44

1.45

1.46

1.47

1.48

1.49

1.5

1.51

2014201620182020202220242026202820302032203420362038204020422044

Average BEF

Base Case

CSL 1

CSL 2

CSL 3

Figure 10.2.8. Average Efficiency of Stock, Ballasts Operating 4-Foot MBP Lamps 

(Residential, Emerging Technologies, Roll-Up Scenario)* 

1.44

1.45

1.46

1.47

1.48

1.49

1.5

1.51

2014201620182020202220242026202820302032203420362038204020422044

Average BEF

Base Case

CSL 1

CSL 2

CSL 3

Figure 10.2.9. Average Efficiency of Stock, Ballasts Operating 4-Foot MBP Lamps 

(Residential, Emerging Technologies, Shift Scenario)* 

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EERE-2007-BT-STD-0016 COMMENT 20
 

1.21

1.22

1.23

1.24

1.25

1.26

1.27

1.28

1.29

1.3

1.31

2014201620182020202220242026202820302032203420362038204020422044

Average BEF

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

1.31

2014201620182020202220242026202820302032203420362038204020422044

Average BEF

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) 

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EERE-2007-BT-STD-0016 COMMENT 20
 

1.22

1.23

1.24

1.25

1.26

1.27

1.28

1.29

1.3

1.31

2014201620182020202220242026202820302032203420362038204020422044

Average BEF

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

1.31

2014201620182020202220242026202820302032203420362038204020422044

Average BEF

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 

EERE-2007-BT-STD-0016 COMMENT 20
 

0.785

0.79

0.795

0.8

0.805

0.81

0.815

2014201620182020202220242026202820302032203420362038204020422044

Average BEF

Base Case

CSL 1

CSL 2

CSL 3

Figure 10.2.14. Average Efficiency of Stock, Ballasts Operating 8-Foot Slimline Lamps 

(Existing Technologies, Shift Scenario)* 

0.785

0.79

0.795

0.8

0.805

0.81

0.815

2014201620182020202220242026202820302032203420362038204020422044

Average BEF

Base Case

CSL 1

CSL 2

CSL 3

Figure 10.2.15. Average Efficiency of Stock, Ballasts Operating 8-Foot Slimline Lamps 

(Existing Technologies, Roll-Up Scenario)* 

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EERE-2007-BT-STD-0016 COMMENT 20
 

0.785

0.79

0.795

0.8

0.805

0.81

0.815

2014201620182020202220242026202820302032203420362038204020422044

Average BEF

Base Case

CSL 1

CSL 2

CSL 3

Figure 10.2.16. Average Efficiency of Stock, Ballasts Operating 8-Foot Slimline Lamps 

(Emerging Technologies, Roll-Up Scenario)* 

0.785

0.79

0.795

0.8

0.805

0.81

0.815

2014201620182020202220242026202820302032203420362038204020422044

Average BEF

Base Case

CSL 1

CSL 2

CSL 3

Figure 10.2.17. Average Efficiency of Stock, Ballasts Operating 8-Foot Slimline Lamps 

(Emerging Technologies, Shift Scenario)* 

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EERE-2007-BT-STD-0016 COMMENT 20
 

0

0.05

0.1

0.15

0.2

0.25

0.3

2014201620182020202220242026202820302032203420362038204020422044

Average BEF

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

0.3

2014201620182020202220242026202820302032203420362038204020422044

Average BEF

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 

EERE-2007-BT-STD-0016 COMMENT 20
 

0

0.05

0.1

0.15

0.2

0.25

0.3

2014201620182020202220242026202820302032203420362038204020422044

Average BEF

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

0.3

2014201620182020202220242026202820302032203420362038204020422044

Average BEF

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)* 

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EERE-2007-BT-STD-0016 COMMENT 20
 

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

2014201620182020202220242026202820302032203420362038204020422044

Average BEF

Base Case

CSL 1

CSL 2

CSL 3

Figure 10.2.22. Average Efficiency of Stock, Ballasts 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

1.8

2014201620182020202220242026202820302032203420362038204020422044

Average BEF

Base Case

CSL 1

CSL 2

CSL 3

Figure 10.2.23. Average Efficiency of Stock, Ballasts Operating 4-Foot T5 MiniBP SO and 

HO Lamps (Existing Technologies, Roll-Up Scenario)* 

10-25 

EERE-2007-BT-STD-0016 COMMENT 20
 

1.1

1.15

1.2

1.25

1.3

1.35

1.4

1.45

1.5

2014201620182020202220242026202820302032203420362038204020422044

Average BEF

Base Case

CSL 1

CSL 2

CSL 3

Figure 10.2.24. Average Efficiency of Stock, Ballasts 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

1.5

2014201620182020202220242026202820302032203420362038204020422044

Average BEF

Base Case

CSL 1

CSL 2

CSL 3

Figure 10.2.25. Average Efficiency of Stock, Ballasts Operating 4-Foot T5 MiniBP SO and 

HO Lamps (Emerging Technologies, Shift Scenario)* 

10-26 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

10.3 NATIONAL ENERGY SAVINGS 

10.3.1 National Energy Savings Definition 

DOE calculates annual national energy savings 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 following standards implementation; i.e., national annual 

energy consumption (AEC) with standards is less than AEC in the base case. 

NESt = (AECt,base − AECt ,std ) × HVAC × RR Eq. 10.1 

Where: 

NESt = 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 annual national energy savings multiplied by the 

HVAC interaction factor and rebound rate. 

NEScum = ∑NESt Eq. 10.2 t 

Where: 

NEScum = 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 consumption and the site-to-source conversion factor, 

shown by the following equation: 

AEC = ∑STOCKbd ×UECbd × src _ convt Eq. 10.3 

bd 

Where: 

bd = ballast ID number, 

STOCKbd = stock of ballasts for a given design surviving in the year for which DOE 

calculated AEC, 

UECbd = unit energy consumption (kWh per year), and 

src_convt = time-dependent conversion factor to convert from site energy (kWh) to 

source energy (quads, Btu/kWh). 

10-27 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 and 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 technologies, dictate the penetration of other lighting 

technologies, and therefore affect the total volume 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 consumption. For electricity, the conversion factors 

vary over time due to projected changes in generation sources (i.e., the power plant types 

projected to provide electricity 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 factors 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

2008 version of the AEO (AEO2008), and will update to the latest 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 winter months. Consistent 

with the Lamps rule, DOE assumed an HVAC factor of 1.06 in the commercial 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 theory, “rebound effect” refers to the tendency of a 

consumer to respond to the cost savings associated with more efficient equipment in a manner 

that actually leads to marginally greater product 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-percent rebound values for commercial and industrial lighting. 

10-29 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

Therefore, in the calculation of national energy savings due to energy conservation standards on 

lighting, DOE calculated a rebound rate of 8.5 percent in the residential sector and 1 percent in 

the commercial and industrial sectors. 

However, the take-back in energy consumption 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 energy 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 = ∑OCSt × DFt Eq. 10.5 

PVC = ∑TICt × DFt 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 the 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 calculated a discount factor from the discount 

10-30 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

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 installed costs as the difference between the 

total annual installed costs in the standards case minus those in the base case. For each case, the 

total annual installed costs equal 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 for 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 operating cost savings as the difference between total annual operating 

costs in the base case minus those in the standards 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 = ∑STOCKbd ×UECbd × electricity price Eq. 10.7 

bd 

DOE uses an average number of annual operating 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 MiniBP 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

10.4.2.3 Discount Factor 

DOE multiplies monetary values in future years by the discount factor (DF) to calculate 

the present value. The following equation describes 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 

tp = year in which the present value is being determined. 

DOE estimates national impacts with both a 3-percent and a 7-percent real discount rate 

as the average real rate of return on private investment 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 analysis (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 the 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_standards/residential/fluorescent_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 spreadsheet model. A brief description of 

the data is given for each input. 

10-32 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

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 Conversion 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 shipment scenarios for ballasts. In this section 

DOE presents only upper and lower bound energy savings 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 results 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 the 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 important to note that the numbers presented in these 

10-33 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

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, which 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 annual total installed cost increases and annual operating cost 

savings at the national level using a 7-percent discount rate. Both annual total installed cost 

increases and annual operating costs savings accumulate from 2014 to 2044. The figures also 

present the NPV, which is the difference between cumulative annual discounted operating cost 

savings and the cumulative annual discounted total installed cost increases. 

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EERE-2007-BT-STD-0016 COMMENT 20
 

   

     

   

     

30

20

10 Discounted Operating

Cost Savings

Discounted Installed Cost 0 Increase 2014 2017 2020 2023 2026 2029 2032 2035 2038 2041 2044

Millions

Total NPV

‐10
 

‐20
 

‐30
 

Figure 10.5.1. National Annual Total Installed Equipment and Operating Cost Savings for 

4-Foot MBP (Residential) at CSL3 (Existing Technologies, Shift Scenario) Discounted at 7 

Percent per Year 

30

20

10 Discounted Operating 2014 2017 2020 2023 2026 2029 2032 2035 2038 2041 2044

Millions

Cost Savings

Discounted Installed Cost 0 Increase

Total NPV

‐10
 

‐20
 

‐30
 

Figure 10.5.2. National Annual Total Installed Equipment and Operating Cost Savings for 

4-Foot MBP (Residential) at CSL3 (Emerging Technologies, Roll-Up Scenario) Discounted 

at 7 Percent per Year 

10-36 

EERE-2007-BT-STD-0016 COMMENT 20
 

   

     

   

     

‐1,000

‐800

‐600

‐400

‐200

0

200

400

600

800

1,000

20142017202020232026202920322035203820412044

Millions

Discounted Operating

Cost Savings

Discounted Installed Cost

Increase

Total NPV

Figure 10.5.3. National Annual Total Installed Equipment and Operating Cost Savings for
 

4-Foot MBP (Commercial) at CSL3 (Existing Technologies, Shift Scenario) Discounted at 7 

Percent per Year 

‐1,000

‐800

‐600

‐400

‐200

0

200

400

600

800

1,000

20142017202020232026202920322035203820412044

Millions

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 Technologies, Shift Scenario) Discounted at 7 

Percent per Year 

10-37
 

EERE-2007-BT-STD-0016 COMMENT 20
 

   

     

   

     

‐4

‐3

‐2

‐1

0

1

2

3

4

5

20142017202020232026202920322035203820412044

Millions

Discounted Operating

Cost Savings

Discounted Installed Cost

Increase

Total NPV

Figure 10.5.5. National Annual Total Installed Equipment and Operating Cost Savings for 

8-Foot Slimline at CSL3 (Existing Technologies, Shift Scenario) Discounted at 7 Percent 

per Year 

‐4

‐3

‐2

‐1

0

1

2

3

4

5

20142017202020232026202920322035203820412044

Millions

Discounted Operating

Cost Savings

Discounted Installed Cost

Increase

Total NPV

Figure 10.5.6. National Annual Total Installed Equipment and Operating Cost Savings for
 

8-Foot Slimline at CSL3 (Emerging Technologies, Roll-Up Scenario) Discounted at 7 

Percent per Year 

10-38
 

EERE-2007-BT-STD-0016 COMMENT 20
 

   

     

   

     

0

100

200

300

400

500

600

700

800

900

1,000

20142017202020232026202920322035203820412044

Millions

Discounted Operating

Cost Savings

Discounted Installed Cost

Increase

Total NPV

Figure 10.5.7. National Annual Total Installed Equipment 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

1,000

20142017202020232026202920322035203820412044

Millions

Discounted Operating

Cost Savings

Discounted Installed Cost

Increase

Total NPV

Figure 10.5.8. National Annual Total Installed Equipment and Operating Cost Savings for
 

8-Foot RDC HO at CSL3 (Emerging Technologies, Roll-Up Scenario) Discounted at 7 

Percent per Year 

10-39
 

EERE-2007-BT-STD-0016 COMMENT 20
 

   

     

   

     

0

50

100

150

200

250

20142017202020232026202920322035203820412044

Millions

Discounted Operating

Cost Savings

Discounted Installed Cost

Increase

Total NPV

Figure 10.5.9. National Annual Total 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 

0

20

40

60

80

100

120

140

160

180

200

20142017202020232026202920322035203820412044

Millions

Discounted Operating

Cost Savings

Discounted Installed Cost

Increase

Total NPV

Figure 10.5.10. National Annual Total Installed Equipment and 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 

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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

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 operating cost savings and installed cost increases. 

Thus, the NPV results are discrete point values rather 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 between 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 levels. As discussed in chapter 8 (LCC and PBP 

analyses), for most ballast purchasing events and most baseline ballast designs, increasing 

efficiency levels generally result in increased LCC savings. Due to this general costeffectiveness of higher efficiency ballasts, the 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 results 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

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 Ballasts 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

REFERENCES 

1. U.S. Department of Energy–Energy 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–Energy 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–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/aeo/index.html>. 

5. Office of Management and Budget. Circular A-4. September 2003. Washington, D.C. 

<http://www.whitehouse.gov/omb/circulars/a004/a-4.pdf>. 

10-43 

EERE-2007-BT-STD-0016 COMMENT 20
CHAPTER 11. LIFE-CYCLE COST SUBGROUP ANALYSIS 

TABLE OF CONTENTS
 

11.1 INTRODUCTION ............................................................................................................ 11-1 

11.2 GENERAL APPROACH.................................................................................................. 11-1 

11-i 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 Department 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 value of a standard for consumer sub-populations. As 

described in chapter 8 of the preliminary technical 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 different 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, commercial, 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 impacts 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 owns 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 purchasing events. The LCC impacts on a consumer who must replace 

a ballast in an existing system versus the purchase of a lamp-and-ballast system for new building 

construction are different. 

In the LCC subgroup analysis, DOE will examine a variety of consumer sub-populations. 

This analysis will determine whether any particular group of consumers would be adversely 

affected by any of the TSLs. 

11-1 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

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 Capacity 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 Product 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/Diminishing 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

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 Rulea 

provides guidance for conducting this analysis with input from manufacturers and other 

interested parties. The U.S. Department of Energy (DOE) applies this methodology to its 

evaluation of amended energy conservation standards 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 range of quantitative and qualitative industry impacts that might 

occur due to an amended energy conservation standard. For example, a particular standard level 

could require changes in manufacturing 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, product 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 the 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. Section 12.3 of this chapter presents initial findings of the Phase I 

analysis. In Phase II, DOE prepares an industry cash flow model and an interview questionnaire 

to guide subsequent discussions with manufacturers. 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
 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

assesses impacts on competition, manufacturing capacity, employment, and regulatory burden 

based on manufacturer interviews 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, employment, and industry costs for fluorescent lamp 

ballasts. Sources of information include reports published by industry groups, trade journals, the 

U.S. Census Bureau, and Securities Exchange Commission (SEC) 10-K filings. In addition, DOE 

relies on information from its market 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 financial impacts of amended energy conservation 

standards. Amended energy conservation standards may require additional investment, raise 

production costs, and/or affect revenue 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 effective 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 information on the effects of 

amended energy conservation standards on revenues and finances, direct employment, capital 

assets, and industry competitiveness. These interviews 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 production costs; shipment projections and market 

share; product mix; conversion costs; 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
 

EERE-2007-BT-STD-0016 COMMENT 20
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 gathered 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 standards on sales, direct employment, capital assets, 

and industry competitiveness. Interviews are scheduled well in advance to provide every 

opportunity for key individuals to be available for comment. Although a written response to the 

questionnaire is acceptable, DOE prefers interactive 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. However, 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 information about profitability 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 develop an industry cash-flow estimate does not 

adequately assess differential impacts among manufacturer subgroups. Smaller manufacturers, 

niche players, and manufacturers exhibiting a cost structure that differs largely from the industry 

average could be more negatively affected. Ideally, 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 the analysis. DOE asks manufacturers and other 

interested parties to suggest what subgroups or characteristics are most appropriate for the 

analysis. 

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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-specific 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 business risks from an increased proportion of fixed 

costs, and potential barriers to market entry (e.g., proprietary technologies). 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, including tooling and other investments. The 

manufacturer interview guide has a series of questions 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 accommodate 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 assess how domestic employment patterns might be 

affected, the manufacturer interviews explore current employment trends in the fluorescent lamp 

ballast industry and solicits manufacturer 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 conservation standard, differences in workforce skills, and 

employee retraining. 

12.2.3.7 Cumulative Regulatory 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. 

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12.3.1 Industry Cost Structure 

DOE developed the fluorescent lamp ballast industry 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 manufacturing 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 ballast employment levels and earnings from 

2003 to 2006. The statistics illustrate a 3-percent increase in the number of production workers 

from 2003 to 2006; however, there was no major change 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 and 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 for 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 expressed both in dollars and as a percentage of 

shipment value. 

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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 production an establishment could attain under normal operating 

conditions. In the Survey of Plant Capacity report, the full production utilization rate is a ratio of 

the actual level of operations to the full production level. 

Table 12.3.4 Full Production Capacity 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 standards at various efficiency levels. The interview questions 

focused on gathering information 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 consumer interests. During the interviews, DOE 

solicited information to determine whether amended energy conservation standards could result 

in disproportionate economic or performance penalties for particular consumer or user 

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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 these 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 having 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 generally 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 the 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 what 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 create 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 

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residential ballasts are extremely price sensitive, an amended energy conservation standard could 

encourage consumers to switch to low-efficiency products such as incandescent lighting. 

12.4.2.2 Product Utility 

Certain manufacturers expressed concern that amended energy conservation standards 

might require changes in product functionality, utility, and other features that would make 

products less desirable to consumers. 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 higher amended energy conservation standard would 

cause manufacturers to incur one-time capital and product conversion costs. Capital conversion 

costs are one-time investments in property, plant and equipment. 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 Regulatory 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 regulations are an important aspect of DOE’s 

consideration of the cumulative regulatory burden 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 regulations and energy conservation standards. 

Several Federal and international regulatory programs may affect the markets for 

fluorescent lamp ballasts. The market and technology 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 regulatory requirements DOE identified. 

Specifically, certain manufacturers 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 concern that failure to regulate residential ballasts would create a 

loophole for inefficient ballasts to enter the market from offshore. Manufacturers noted that they 

would prefer that DOE set a final date for ballast production 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 

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these issues may lead to ballast requirements that could lower ballast efficiency and affect 

payback calculations. Manufacturers also mentioned the impact of international standards on 

ballast redesign. 

12.5 OVERALL KEY ISSUES 

Perhaps the most important aspect of the preliminary 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 profit margins would decrease with the 

implementation of amended energy conservation standards, especially 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 interviewed, consistent profitability is not common 

across all types of fluorescent lamp ballasts. Manufacturers also expressed concern that pricing is 

extremely variable depending on the application (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 amended energy conservation standards would 

force them to invest in more expensive and energy efficient components, improve existing 

product lines, and design new product 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 that the large investment could result in more 

expensive products for consumers. However, other 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 resources available for the development of new products 

would significantly decrease. 

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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 

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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 energy 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 standards 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 modeling 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 generation, installed capacity, sales, and prices. The 

NEMS-BT model provides reference case load shapes for several end uses, including lighting 

applications. 

For electrical end uses, NEMS-BT uses predicted growth in demand for each end use to 

project the total electric system load growth for 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 the 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 rates) of future electricity generating 

plants. 

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The model uses predicted growth in demand for each end use to project total electric 

system load growth for each region, which in turn is used to predict necessary additions to 

electrical generation capacity. Two alternative scenarios 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 predicted 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 conservation 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 electricity savings (in kilowatt hours) expected for a 

particular standard. The extrapolation will be based on a comparison of the change in the NEMSBT variable (e.g., coal-fired generation) to the change 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 with date-certain introduction 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-year forecasted increments extrapolated to 2044. 

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REFERENCES 

1. U.S. Department of Energy–Energy 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–Energy 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/archive/aeo09/pdf/0383(2009).pdf> 

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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
 

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

will conduct this analysis as part of the 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 technical support document). Indirect employment 

impacts affect the national economy in areas other 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 adjustment 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 equipment and reduced spending on energy. 

14.2 ASSUMPTIONS 

DOE expects new standards to increase the total installed cost of equipment (including 

manufacturer sales price, sales taxes, distribution channel markups, and installation cost). DOE 

also expects the new standards to decrease energy 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 the 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 relevant to industrial, commercial, 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 

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EERE-2007-BT-STD-0016 COMMENT 20
 

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-industry 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 services, 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 overall 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. Depending on the design options considered, one 

possible outcome is that the standards for these 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 employment in other sectors. DOE designed the 

employment impact analysis to estimate the annual net national employment impact of these 

types of expenditure flows. 

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REFERENCES 

1. Roop, J. M., M. J. Scott, and R. W. Schultz. ImSET: Impact of Sector Energy Technologies. 

2005. Pacific Northwest National Laboratory: 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. 

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EERE-2007-BT-STD-0016 COMMENT 20
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 Emissions Reduction Benefits .......................................................3 

EA.3 RESULTS ............................................................................................................................4 

REFERENCES ................................................................................................................................5 

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EERE-2007-BT-STD-0016 COMMENT 20
 

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 ballasts. 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 assessment 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 provide key inputs to its analysis. The portion of 

the environmental assessment that NEMS-BT will produce considers carbon dioxide (CO2), 

nitrogen oxides (NOx), and mercury (Hg). The environmental assessment also considers impacts 

on SO2 emissions. For each trial standard level (TSL), DOE will calculate total undiscounted and 

discounted power plant emissions using NEMS-BT. 

EA.2 METHODOLOGY 

DOE will conduct each environmental 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 electric utility industry. Thus, the analysis will 

account for any factors affecting the type of electricity 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 control regulation of power plant emissions of 

CO2, a DOE standard is likely to result in reductions of these emissions. The CO2 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 CO2 emissions using a detailed 

module that provides results with broad coverage of all sectors and inclusion of interactive 

effects. 

EA.2.2 Sulfur Dioxide 

DOE has preliminarily determined that SO2 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 SO2 emissions. The costs of meeting such emission 

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EERE-2007-BT-STD-0016 COMMENT 20
 

cap requirements are reflected in the electricity prices and forecasts used in DOE’s analysis of 

the standards. Title IV of the Clean Air Act sets an annual emissions cap on SO2 for all affected 

EGUs. SO2 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 SO2 emission allowances 

resulting from the lower electricity demand caused by the imposition of an efficiency standard 

could be used to permit offsetting increases in SO2 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 SO2 emissions from the standards. While there remains 

some uncertainty about the ultimate effects of efficiency standards on SO2 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 physical reductions in power sector 

emissions would occur for SO2. 

Even if there is no significant reduction in the overall emissions of SO2 that results from 

the standard, there may still be some economic benefit from reduced demand for SO2 emission 

allowances that is not fully reflected in the cost savings experienced by individual consumers. 

Electricity savings that decrease the overall demand for SO2 emissions allowances could lower 

allowance prices and thereby result in some economic 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 NOx 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 NOX in 28 eastern states and DC. 70 FR 

25162 (May 12, 2005). 

Much like SO2 emissions, a cap on NOx 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 CAIR has been remanded to the EPA by the DC 

Circuit, it will remain in effect until it is replaced by a rule consistent 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 NOx 

emissions through participation in cap-and-trade programs for electric generating units, 

emissions from these sources are capped across the CAIR region. DOE also plans to use NEMSBT to estimate the emissions reductions from possible standards in the 22 States where emissions 

are not capped. 

Standards may produce an environmental-related economic benefit in the form of lower 

prices for emissions allowance credits. As with SO2 allowance prices, DOE does not plan to 

monetize this particular benefit because the effect on the NOx allowance price from any single 

energy conservation standard is likely small and highly uncertain. 

EA-2 

EERE-2007-BT-STD-0016 COMMENT 20
 

EA.2.4 Mercury 

Similar to emissions of SO2 and NOx, future emissions of Hg would have been subject to 

emissions caps. In May 2005, EPA issued the 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 the CAMR. 517 F.3d 574 (DC Cir. 2008). EPA has 

decided to develop emissions standards for power 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 usually 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 does not separate direct PM emissions from power plants from the 

sulfate particulates indirectly produced through complex atmospheric chemical reactions. The 

great majority of PM emissions from power plants are of these secondary particles (secondary 

sulfates). Thus, it is not useful to examine how the amended standard impacts direct PM 

emissions independent of indirect PM production and atmospheric dynamics. Therefore, DOE is 

not planning to assess the impact of these standards on particulate emissions. Further, even the 

cumulative impact of PM emissions from power plants and indirect emissions of pollutants from 

other sources is unlikely to be significant. 

EA.2.6 Monetization of Emissions Reduction Benefits 

For those emissions for which real national emission reductions are anticipated (CO2, Hg, 

and NOx 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. 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 economic 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 

CO2 emissions, it is DOE’s intent to use in its analysis the most current social cost of carbon 

(SCC) values developed and/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 

EERE-2007-BT-STD-0016 COMMENT 20
 

including but not limited to net agricultural productivity loss, human health effects, property 

damage from sea level rise, and changes in ecosystem 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 quantification and monetization, the 

SCC can be used to provide estimates of the social benefits of reductions in GHG emissions. 

At the time of this notice, the most recent interagency estimates of the potential global 

benefits resulting from reduced CO2 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 percent 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 A of the annex 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 knowledge continues to evolve rapidly as to 

the contribution of CO2 and other GHG to changes in the future 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 NOx, and Hg 

emissions resulting from the standard levels it considers. For NOx emissions, available estimates 

suggest a very wide range of monetary values for NOx emissions, ranging from $370 per ton to 

$3,800 per ton of NOX from stationary sources, measured in 2001$ (equivalent to a range of 

$442 to $4,540 per ton in 2008$).4 

For Hg emissions reductions, DOE has previously determined that the impact of Hg 

emissions from power plants on humans is considered 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 lifetime economic productivity 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 exposure 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 $0.66 million per ton emitted (in 2004$) 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 SO2, NOx, CO2, 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

REFERENCES 

1. U.S. Department of Energy–Energy 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/archive/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/mercuryrule/pdfs/certpetition_withdrawal.pdf> 

3. Office of Management and Budget. 2003. Circular A-4: Regulatory Analysis. September 17. 

(Last accessed March 11, 2003.) <http://www.whitehouse.gov/omb/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 Benefits of Federal Regulations 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 Children: 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: Lessons 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 

EERE-2007-BT-STD-0016 COMMENT 20
REGULATORY IMPACT ANALYSIS FOR FLUORESCENT LAMP BALLASTS 

TABLE OF CONTENTS
 

RIA.1 INTRODUCTION ...........................................................................................................1
 

RIA.2 METHODOLOGY ..........................................................................................................1
 

RIA-i 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

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, “Regulatory Planning and Review,” which will be 

subject to review by the Office of Management 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 technical 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 actions affecting the same products. Through 

manufacturer interviews and literature searches, DOE will compile information on burdens from 

existing and pending regulations affecting fluorescent lamp ballasts. 

The regulatory impact analysis also will address the potential for non-regulatory 

approaches to supplant or augment energy conservation 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 has 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 energy 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

•	 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 efficiency relationships; and 

•	 equipment stock data (purchase of new equipment or turnover rates for inventories). 

The output from the NES model for each alternative considered will be as follows: 

•	 Energy use (EJ = 1018 joule) is the cumulative energy use of the equipment from the 

effective date of the amended standard to 2044. DOE will report electricity consumption 

as primary energy. 

•	 National energy savings is the cumulative national energy use from the base case 

projection less the alternative projection. 

•	 Net present value is the value of future operating cost savings from fluorescent lamp 

ballasts bought in the period between the effective date of the new standard and the close 

of the analysis period (2044). DOE calculates 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 alternative case. DOE will discount future 

operating and equipment expenditures to its analysis 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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 

CO2 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 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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 recessed 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 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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 

NOX nitrogen oxides 

NPCC Northwest Power and Conservation Council 

NPV net present value 

NRCan Natural Resources Canada 

NRDC Natural Resources Defense Council 

NVLAP National Voluntary Laboratory Accreditation Program 

NYSERDA New York State Energy Research 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 reflector (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 Hazardous 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 

SO2 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 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

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 

EERE-2007-BT-STD-0016 COMMENT 20
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 FLUORESCENT LAMP BALLASTS............. 3A-1
 

3A.3 DEFINITIONS .............................................................................................................. 3A-6
 

3A.4 ENERGY INDEPENDENCE AND SECURITY ACT OF 2007 .............................. 3A-10
 

3A-i 

EERE-2007-BT-STD-0016 COMMENT 20
APPENDIX 3A. FLUORESCENT LAMP BALLASTS IN THE UNITED STATES CODE 
 

AND CODE OF FEDERAL REGULATIONS 

3A.1 INTRODUCTION 

This appendix lists the relevant 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 statutory requirements under 42 U.S.C. 6295(g) (i.e., 

section 325(g) of EPCA, as amended by the Energy 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 current 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

(6) The standards described in paragraph (5) do not apply to 

(A) a ballast which is designed for dimming or for 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) should be amended, including whether such 

standards should be amended so that they would 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 final 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 amended 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 amend the standards, the earliest date by which a 

previous amendment could have been effective; 

except that in no case may any amended standard 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 manufacturer 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 current 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 after 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 provided 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 luminaire 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 current 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: 

3A-3

EERE-2007-BT-STD-0016 COMMENT 20
 

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 for 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 current 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

(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 ballast in a previously installed luminaire; 

(C) Is marked “FOR REPLACEMENT USE ONLY”; 

(D) Is shipped by the manufacturer in packages containing not more than 10 ballasts; 

(E) Has output leads that when fully extended 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 efficacy 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 current 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 ballasts 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 relevant 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 the 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 standard 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 

EERE-2007-BT-STD-0016 COMMENT 20
(E) The term "input current" means the root-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 distribute 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 may be prescribed by the Secretary. 

(K) The term "relative light output" means the light output delivered through the use of a 

ballast divided by the light output delivered 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 inches 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 nominal 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 extended 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 

EERE-2007-BT-STD-0016 COMMENT 20
(A) Except as provided in subparagraph (E), 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, 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 overall length between 22 and 25 inches and 

rated wattage of 28 or more. 

(iii)Any rapid start lamp (commonly referred 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 “incandescent 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 special 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 

EERE-2007-BT-STD-0016 COMMENT 20
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 conditions 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 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 bases of nominal 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 nominal overall length between 45 and 48 

inches and rated wattage of 26 or more; and 

(6) Any straight-shaped lamp (commonly referred to 4-foot miniature bipin high output 

lamps) with miniature bipin bases of nominal 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

This appendix provides the DOE test procedures for measuring the energy consumption of 

fluorescent lamp ballasts, as contained 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 legislation amended certain 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 Secretary 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 

EERE-2007-BT-STD-0016 COMMENT 20
`(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 standby or active mode function. 

`(iii) STANDBY MODE- 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. 

`(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 the 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 Electrotechnical 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 

EERE-2007-BT-STD-0016 COMMENT 20
`(ii) such an integrated test procedure is technically infeasible for a 

particular covered product, in which case the Secretary shall prescribe a 

separate standby mode and off mode energy 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 chargers and external power supplies. 

`(ii) March 31, 2009, for clothes dryers, room air conditioners, and 

fluorescent lamp ballasts. 

`(iii) June 30, 2009, for residential clothes washers. 

`(iv) September 30, 2009, for residential 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 single amended or new standard, pursuant to 

subsection (o), if feasible. 

`(B) SEPARATE STANDARDS- If not feasible, the Secretary shall prescribe 

within the final rule a separate standard for standby mode and off mode energy 

consumption, if justified under 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 

EERE-2007-BT-STD-0016 COMMENT 20
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 amended 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 (voltage, current, and waveform) for starting and 

operating. 

`(59) BALLAST EFFICIENCY.-- 

`(A) IN GENERAL.-- The term `ballast efficiency' 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 = Pout/Pin. 

`(B) EFFICIENCY FORMULA.-- For the purpose of subparagraph (A)-­

`(i) Pout shall equal the measured operating lamp wattage; 

`(ii) Pin shall equal the measured operating input wattage; 

`(iii) the lamp, and the capacitor when the capacitor is provided, shall constitute 

a nominal system in accordance with the ANSI Standard C78.43-2004; 

`(iv) for ballasts with a frequency of 60 Hz, Pin and Pout shall be measured after 

lamps have been stabilized according to section 4.4 of ANSI Standard C82.6-2005 

using a wattmeter with accuracy specified in section 4.5 of ANSI Standard C82.6­

2005; and 

`(v) for ballasts with a frequency greater than 60 Hz, Pin and Pout 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 `electronic ballast' means a device that uses 

semiconductors as the primary means to control lamp starting and operation. 

`(61) GENERAL LIGHTING APPLICATION.-- The term `general lighting application' 

means lighting that provides an interior or exterior area with overall illumination. 

3A-13 

EERE-2007-BT-STD-0016 COMMENT 20
`(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 `metal 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, possibly in combination with metallic vapors. 

`(64) METAL HALIDE LAMP FIXTURE.-- The term `metal halide lamp fixture' means a 

light fixture for general lighting 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 the 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 Energy 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 

EERE-2007-BT-STD-0016 COMMENT 20
`(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 Energy 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 enactment of this subparagraph, shall indicate 

conspicuously, in a manner prescribed by the Commission under subsection (b) 

by July 1, 2008, a capital letter `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 subparagraphs (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 

EERE-2007-BT-STD-0016 COMMENT 20
 

`(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 fixtures 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 than January 1, 2012, the Secretary shall 

publish a final rule to determine whether 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 

EERE-2007-BT-STD-0016 COMMENT 20
`(3) FINAL RULE BY JANUARY 1, 2019.-­

`(A) IN GENERAL.-- Not later than 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 established 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 halide 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), notwithstanding 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 

EERE-2007-BT-STD-0016 COMMENT 20
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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

APPENDIX 5A. MATERIAL PRICES 

5A.1 INTRODUCTION
 

This appendix presents the results of an analysis 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 BOMs use material prices from January 2009. DOE 

understands that changes in material prices can affect the ultimate manufacturer selling price. 

Therefore, DOE conducted an analysis to determine 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 Labor 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

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-foot 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

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 manufacturer in particular stated 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 purchase magnetic 4-foot T5 ballasts without a T5 standard if 

such ballasts are brought to market, DOE developed models of 4-foot T5 standard output (SO) 

and high output (HO) magnetic ballasts as baselines for the SO and HO T5 product classes, 

respectively. This appendix details the development of those models. In particular, DOE 

developed models of a 2-lamp magnetic 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 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 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

ballast (110W).a Because magnetic ballasts are commercially available to operate these lamps, 

DOE was able to determine the percentage difference 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 * InputPowerMagnetic Equation 5B.2.1 BFMagnetic

AdjustedInputPower = Input Power of Magnetic Ballast adjusted to account for difference in 

ballast factor (BF) 

BFElectronic =BF of electronic ballast 

BFMagnetic =BF of magnetic ballast 

InputPowerMagnetic = 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 that the average increase in input power while 

maintaining BF. For the F32T8 and F34T12, the average increase in input power was 20%. For 

the F96T12/ES, the average increase in input power 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 exhibit the same BF as its electronic counterpart. The results are 

displayed in the following table. 

a

 Although DOE tested electronic F96T12/ES and F32T8 electronic ballasts, DOE used catalog values because DOE 

chose not to test magnetic F96T12/ES and F32T8 magnetic ballasts. 

5B-2 

EERE-2007-BT-STD-0016 COMMENT 20
Table 5B.2.3 Model Magnetic and Electronic 2-lamp 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., these ballasts would be PS) because DOE believes that these 

ballasts would be used as replacements and therefore be in the same product class as their 

electronic counterparts. 

5B-3 

EERE-2007-BT-STD-0016 COMMENT 20
APPENDIX SC. FLUORESCENT LAMP BALLAST TEST DATA 

TABLE OF CONTENTS 

SC.l INTRODUCTION .........................................................................................................SC-l

SC.2 TEST DATA..................................................................................................................SC-l

LIST OF TABLES 

Table SC.l Ballasts That Operate Four-Foot MBP and Two-Foot U-Shaped Lamps ...............SC-l

Table SC.2 Ballasts That Operate Four-Foot MiniBP TS SO Lamps ........................................SC-S

Table SC.3 Ballasts That Operate Four-Foot MiniBP TS HO Lamps .......................................SC-6

Table SC. Ballasts That Operate Eight-Foot SP Slimline Lamps ............................................SC-6

Table SC.S Ballasts That Operate Eight-Foot RDC HO Lamps ................................................SC-7

Table SC.6 Ballasts That Operate Four-Foot MBP and Two-Foot U-Shaped Lamps in the 

Residential Sector ........................................................................................SC-8

Table SC.7 Ballasts that Operate Eight-Foot HO Lamps in Cold Temperature 

Applications and Outdoor Signs ..................................................................SC-8

 SC-i

EERE-2007-BT-STD-0016 COMMENT 20
 

 

   

   

  

APPENDIX SC. FLUORESCENT LAMP BALLAST TEST DATA

SC.t INTRODUCTION

The following appendix lists the test data DOE used to develop the engineering analysis. DOE chose to te

ballasts from many different manufacturers. Through an independent testing facility, DOE tested both the ballast 

and ballast efficiency (BE) of the ballast. For BEF, DOE used the test procedure outlined in l0 CFR 30, Subpar

BE, DOE used the test procedure proposed in the fluorescent lamp ballast active mode test procedure notice of pThree examples of each ballast type were tested, and the average of the three test results is displayed for each balbelow.SC.2 TEST DATA Table SC.t Ballasts That Operate Four-Foot MBP and Two-Foot U-Shaped Lamps

Manufacturer

 N

umber

ofLamps

LampDiameter(t18 ofinches)

LampLength(inches)

LampNominalPower(W)

StartingMethod

BallastNominalInputVoltage(V)

UniversalInputVoltage? (Y1N)

MeasuredBallastInputVoltage(V) in BEF testing

Measured

BallastInputPower(W) inBEF testing

MeasuredBallastFactor in

BEF testing

MeasuredBallastEfficacyFactor

MeasuredBallast InputVoltage (V)in BE testing

MBInP(WBte

A

 l

T8 8 32 IS l20 N l20.03 33. 0.889 2.6S8 l20.03 

B

 l

T8 8 32 IS l20 N l20.03 30.6 0.8 2 2.7 7 l20.0 

A

 l

T8 8 32 IS 277 Y 277.l0 32.2 0.877 2.722 277.l0 

A

 l

T8 8 32 IS 277 Y 277.l0 29.7 0.8 9 2.8SS 277.08 

A

 l

T8 8 32 IS 277 N 277.l7 32.3 0.882 2.736 277.08 

B

 l

T8 8 32 IS 277 N 277.l0 3l.S 0.863 2.7 3 277.06 

B

 l

T8 8 32 IS 277 Y 277.l0 28.0 0.8 8 3.026 277.08 

B

 l

T8 8 32 IS 277 Y 277.l0 27.8 0.8 3 3.036 277.l3 

C l T8 8 32 IS 277 Y 277.l0 30.2 0.88S 2.929 277.l0 

C l T8 8 32 IS 277 Y 277.07 30.0 0.8SS 2.8S2 277.08 

SC-l 

EERE-2007-BT-STD-0016 COMMENT 20
 

    

 

 

         

       

      

  

Manufacturer

 N

umber

ofLamps

LampDiameter(t18 ofinches)

LampLength(inches)

LampNominalPower(W)

StartingMethod

BallastNominalInputVoltage(V)

UniversalInputVoltage? (Y1N)

MeasuredBallastInputVoltage(V) in BEF testing

Measured

BallastInputPower(W) inBEF testing

MeasuredBallastFactor in

BEF testing

MeasuredBallastEfficacyFactor

MeasuredBallast InputVoltage (V)in BE testing

MBInP(WBte

D

 l

T8 8 32 IS 277 N 277.l0 3l.l 0.889 2.8S9 277.0S 

D

 l

T8 8 32 IS 277 Y 277.l0 29.8 0.8 3 2.833 277.03 

D

 l

T8 8 32 IS 277 Y 277.l0 30.8 0.866 2.8l 277.06 

D

 l

T8 8 32 PS 277 Y 277.07 32.6 0.92S 2.838 277.07 

A

 2

Tl2 8 3 RS 277 N 276.97 63.S 0.862 l.3S9 N.D. 

B

 2

Tl2 8 3 RS 277 Y 276.99 6 .3 0.8SS l.330 N.D. 

C 2 Tl2 8 3 RS 277 N 276.9l 63. 0.862 l.36l N.D. 

D

 2

Tl2 8 3 RS 277 N 276.98 6l.2 0.8 l l.37 N.D. 

D

 2

Tl2 8 3 RS 277 N 277.0l 6S.3 0.8S2 l.30S N.D. 

A

 2

T8 8 32 IS 277 Y 277.07 S3.3 0.79S l. 92 277.07 

A

 2

T8 8 32 IS 277 Y 277.02 S7.9 0.880 l.Sl9 277.08 

A

 2

T8 8 32 IS 277 Y 277.00 78.0 l.lS6 l. 82 277.l 

A

 2

T8 8 32 IS 277 Y 277.07 S0.8 0.763 l.S03 277.l8 

A

 2

T8 8 32 IS 277 Y 277.03 S6.0 0.860 l.S3S 277.09 

A

 2

T8 8 32 IS 277 N 277.00 78.9 l.l8S l.S02 276.99 

A

 2

T8 8 32 IS 277 N 277.0 60. 0.87S l. S0 * 

B

 2

T8 8 32 IS 277 N 277.07 S8.2 0.8 6 l. S 277.09 

B

 2

T8 8 32 IS 277 Y 277.00 78.6 l.l99 l.S2 277.08 

B

 2

T8 8 32 IS 277 Y 277.03 9.S 0.7S8 l.S3l 277.20 

B

 2

T8 8 32 IS 277 Y 277.06 S .l 0.8 2 l.SS 277.07 

B

 2

T8 8 32 IS 277 Y 277.00 78. l.lS6 l. 7S 277.02 

B

 2

T8 8 32 IS 277 Y 277.07 S0.0 0.760 l.S20 277.ll 

B

 2

T8 8 32 IS 277 Y 276.98 S6. 0.866 l.S3S 277.0 

C 2 T8 8 32 IS 277 Y 277.00 79.0 l.l79 l. 93 276.9 

C 2 T8 8 32 IS 277 Y 277.07 S0.0 0.7S8 l.SlS 277.0l 

C 2 T8 8 32 IS 277 Y 277.02 S6. 0.87 l.S 9 276.96 

C 2 T8 8 32 IS 277 Y 276.97 80.3 l.l92 l. 8S 277.0l 

C 2 T8 8 32 IS 277 Y 277.07 S .2 0.766 l. l3 277.06 

C 2 T8 8 32 IS 277 Y 277.0S SS.9 0.863 l.S 276.99 

D

 2

T8 8 32 IS 277 N 277.07 8.S 0.7 6 l.S38 277.ll 

D

 2

T8 8 32 IS 277 N 277.03 S2.l 0.8l l.S63 277.07 

SC-2 

EERE-2007-BT-STD-0016 COMMENT 20
 

        

     

 

    

   

  

     

  

Manufacturer

 N

umber

ofLamps

LampDiameter(t18 ofinches)

LampLength(inches)

LampNominalPower(W)

StartingMethod

BallastNominalInputVoltage(V)

UniversalInputVoltage? (Y1N)

MeasuredBallastInputVoltage(V) in BEF testing

Measured

BallastInputPower(W) inBEF testing

MeasuredBallastFactor in

BEF testing

MeasuredBallastEfficacyFactor

MeasuredBallast InputVoltage (V)in BE testing

MBInP(WBte

D

 2

T8 8 32 IS 277 N 277.07 S3.S 0.78l l. 60 277.0S 

D

 2

T8 8 32 IS 277 N 277.02 S9.0 0.86 l. 66 277.0l 

D

 2

T8 8 32 IS 277 Y 277.03 9.8 0.7S2 l.S08 277.07 

D

 2

T8 8 32 IS 277 Y 277.03 SS. 0.8 0 l.Sl6 277.0 

D

 2

T8 8 32 IS 277 Y 277.00 7S.S l.llS l. 76 277.02 

D

 2

T8 8 32 IS 277 Y 277.00 SS.6 0.8SS l.S38 277.00 

A

 2

T8 8 32 PS 277 Y 277.07 6.0 0.683 l. 83 277.0S 

A

 2

T8 8 32 PS 277 Y 276.9S S6.7 0.86l l.Sl7 277.03 

A

 2

T8 8 32 PS 277 N 276.98 63.S 0.896 l. l2 277.0 

B

 2

T8 8 32 PS 277 N 277.00 S8.3 0.879 l.S09 277.03 

B

 2

T8 8 32 PS 277 Y 277.00 76.6 l.l33 l. 79 276.99 

B

 2

T8 8 32 PS 277 Y 277.00 8.3 0.7lS l. 83 277.06 

B

 2

T8 8 32 PS 277 Y 277.07 S8.6 0.87l l. 86 277.03 

B

 2

T8 8 32 PS 277 Y 277.07 S.8 0.609 l.33l 277.0 

C 2 T8 8 32 PS 277 Y 276.98 S6.9 0.863 l.Sl6 276.97 

D

 2

T8 8 32 PS 277 Y 277.00 63.3 0.89l l. 08 277.0S 

A

 3

T8 8 32 IS 277 Y 276.87 8S.3 0.869 l.0l9 277.l3 

A

 3

T8 8 32 IS 277 Y 277.00 83.2 0.8 6 l.0l7 277.lS 

A

 3

T8 8 32 IS 277 N 277.00 8S.9 0.872 l.0lS 277.09 

B

 3

T8 8 32 IS 277 N 277.00 83.9 0.8 l.006 277.l9 

B

 3

T8 8 32 IS 277 Y 276.97 82.S 0.8S0 l.03l 277.09 

B

 3

T8 8 32 IS 277 Y 276.97 8 .8 0.8S l.008 277.0 

C 3 T8 8 32 IS 277 Y 276.97 8S.0 0.868 l.022 277.lS 

C 3 T8 8 32 IS 277 Y N.D. N.D. N.D. N.D. 277.00 

D

 3

T8 8 32 IS 277 N 277.03 79. 0.826 l.0 0 277.l0 

D

 3

T8 8 32 IS 277 N 277.00 87.6 0.8 S 0.96 277.07 

D

 3

T8 8 32 IS 277 Y 277.00 83.l 0.8 8 l.02l 277.07 

D

 3

T8 8 32 IS 277 Y 277.00 82.7 0.8 l.02l 277.09 

D

 3

T8 8 32 PS 277 Y 277.00 90.8 0.86l 0.9 9 277.l2 

A T8 8 32 IS 277 Y 276.93 l00.S 0.776 0.772 277.l3 

A T8 8 32 IS 277 Y 276.8S ll2.8 0.8S2 0.7S6 276.87 

SC-3 

EERE-2007-BT-STD-0016 COMMENT 20
 

   

       

     

        

 

   

  

 

Manufacturer

 N

umber

ofLamps

LampDiameter(t18 ofinches)

LampLength(inches)

LampNominalPower(W)

StartingMethod

BallastNominalInputVoltage(V)

UniversalInputVoltage? (Y1N)

MeasuredBallastInputVoltage(V) in BEF testing

Measured

BallastInputPower(W) inBEF testing

MeasuredBallastFactor in

BEF testing

MeasuredBallastEfficacyFactor

MeasuredBallast InputVoltage (V)in BE testing

MBInP(WBte

A T8 8 32 IS 277 Y 276.90 lSS.6 l.l9l 0.766 277.02 

A T8 8 32 IS 277 Y 276.97 9S.3 0.7 S 0.782 277.l 

A T8 8 32 IS 277 Y 276.92 ll . 0.866 0.7S7 276.90 

A T8 8 32 IS 277 N 276.86 llS.S 0.873 0.7S6 276.86 

B T8 8 32 IS 277 N 277.0l lll.S 0.837 0.7Sl 277.2l 

B T8 8 32 IS 277 Y 276.90 l 3.6 l.l36 0.79l 277.0S 

B T8 8 32 IS 277 Y 276.97 96. 0.7S0 0.777 277.l3 

B T8 8 32 IS 277 Y 276.9S ll0.l 0.839 0.762 276.92 

B T8 8 32 IS 277 Y 276.90 l 7. l.l 2 0.77S * 

B T8 8 32 IS 277 Y 276.93 ll0.6 0.8S8 0.776 277.l0 

B T8 8 32 IS 277 Y N.D. N.D. N.D. N.D. 277.0 

C T8 8 32 IS 277 Y 276.93 l S.2 l.l2 0.77 * 

C T8 8 32 IS 277 Y 276.97 97.9 0.77l 0.788 277.l 

C T8 8 32 IS 277 Y 276.9l ll3.7 0.86l 0.7S8 276.97 

C T8 8 32 IS 277 Y 276.97 96.0 0.7S3 0.78S 277.l6 

C T8 8 32 IS 277 Y 276.9 ll2.6 0.872 0.77 276.9 

D T8 8 32 IS 277 N 276.97 93.3 0.736 0.789 277.l 

D T8 8 32 IS 277 N 276.93 l06.8 0.823 0.77l 276.87 

D T8 8 32 IS 277 N 276.90 l 7.7 l.l37 0.770 277.l2 

D T8 8 32 IS 277 N 277.00 96.8 0.7 7 0.772 277.lS 

D T8 8 32 IS 277 N 276.86 ll0.9 0.8 2 0.760 276.8S 

D T8 8 32 IS 277 Y 276.93 93. 0.737 0.788 277.lS 

D T8 8 32 IS 277 Y 276.90 l09.2 0.83l 0.76l 276.88 

D T8 8 32 IS 277 Y 276.97 l09.S 0.8S3 0.779 277.lS 

B T8 8 32 PS l20 N l20.0 ll7.0 0.867 0.7 2 l20.l2 

A T8 8 32 PS 277 Y 277.03 92.l 0.7l2 0.772 277.l2 

A T8 8 32 PS 277 Y 276.88 ll .6 0.888 0.77S 276.9l 

A T8 8 32 PS 277 N 276.90 l20.3 0.86S 0.7l9 276.8S 

B T8 8 32 PS 277 Y 276.90 l 8.8 l.l 7 0.77l 277.03 

B T8 8 32 PS 277 Y 276.97 ll2.7 0.877 0.778 276.87 

C T8 8 32 PS 277 Y 276.83 ll6.l 0.880 0.7S8 276.9l 

SCEERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

  

  

  

Manufacturer

 N

umber

ofLamps

LampDiameter(t18 ofinches)

LampLength(inches)

LampNominalPower(W)

StartingMethod

BallastNominalInputVoltage(V)

UniversalInputVoltage? (Y1N)

MeasuredBallastInputVoltage(V) in BEF testing

Measured

BallastInputPower(W) inBEF testing

MeasuredBallastFactor in

BEF testing

MeasuredBallastEfficacyFactor

MeasuredBallast InputVoltage (V)in BE testing

MBInP(WBte

D T8 8 32 PS 277 Y 276.9l ll8.8 0.8 3 0.709 276.88 

B

 6

T8 8 32 IS 277 Y N.D. N.D. N.D. N.D. 277.03 

N.D. indicates DOE did not perform the measurement, "no data." 

* When connected to a resistor, the ballast did not operate. The ballast did operate a lamp successfully.

Table SC.2 Ballasts That Operate Four-Foot MiniBP TS SO LampsManufacturer

 N

umber

ofLamps

LampDiameter(t18 ofinches)

LampLength(inches)

LampNominalPower(W)

StartingMethod

BallastNominalInputVoltage(V)

UniversalInputVoltage? (Y1N)

MeasuredBallastInputVoltage(V) inBEF testing

Measured

BallastInputPower(W) inBEF testing

MeasuredBallastFactor in

BEF testing

Measured

BallastEfficacyFactor

MeasuredBallastInputVoltage(V) in BE testing

MeBalInpPow(Wtest

C l TS 6 28 PS 277 Y 277.23 30.8 0.997 3.23 277.09 3

A

 2

TS 6 28 PS 277 Y 277.ll 6 .9 l.0l9 l.S70 277.l 6

B

 2

TS 6 28 PS 277 Y 277.0 S9.8 0.9S7 l.600 277.l7 S

B

 2

TS 6 28 PS 277 Y 276.98 70.S l.l l l.6l8 277.lS 8

C 2 TS 6 28 PS 277 Y 277.06 63.6 l.0l0 l.S87 277.lS 6

C 2 TS 6 28 PS 277 Y 276.87 6l.7 l.000 l.620 277.08 l

D

 2

TS 6 28 PS 277 Y 277.0S S8.7 0.9 8 l.6l3 276.89 6

D

 2

TS 6 28 PS 277 Y 276.93 6S. l.06l l.62 276.69 6

SC-S 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

  

 

 

 

 

 

 

 

 

 

Table SC.� Ballasts That Operate Four-Foot MiniBP TS �O LampsManufacturer

 N

umber

ofLamps

Lamp

Diameter(t18 ofinches)

LampLength(inches)

LampNominalPower(W)

StartingMethod

BallastNominalInputVoltage(V)

UniversalInputVoltage? (Y1N)

MeasuredBallastInputVoltage(V) in BEF testing

Measured

BallastInputPower (W)

in BEF testing

MeasuredBallastFactor in

BEF testing

MeasuredBallastEfficacyFactor

MeasuredBallastInputVoltage(V) in BE testing

C l TS 6 S PS 277 Y 276.89 S9.2 l.0l6 l.7l6 277.06 

A

 2

TS 6 S PS 277 Y 277.l3 l26.3 l.0l7 0.806 277.0S 

B

 2

TS 6 S PS 277 Y 277.07 l2 .8 0.988 0.79l * 

B

 2

TS 6 S PS 277 Y 276.97 l20.7 0.970 0.80 276.99 

C 2 TS 6 S PS 277 Y 276.9 l23.7 l.006 0.8l3 277.0S 

D

 2

TS 6 S PS 277 Y 277.0 l22. l.0lS 0.829 277.0S 

A TS 6 S PS 277 Y 277.03 2 0.9 l.0Sl 0. 36 276.99 

B TS 6 S PS 277 Y 277.07 220.7 0.97S 0. 2 276.99 

D TS 6 S PS 277 Y 277.03 226.S l.0l3 0. 7 277.02 

* When connected to a resistor, the ballast did not operate. The ballast did operate a lamp successfully.

Table SC.� Ballasts That Operate Eight-Foot SP Slimline LampsManufacturer

 N

umber

of Lamps

LampDiameter(t18 ofinches)

LampLength(inches)

LampNominalPower(W)

StartingMethod

BallastNominalInputVoltage(V)

UniversalInputVoltage? (Y1N)

MeasuredBallastInputVoltage(V) inBEF testing

Measured

BallastInputPower(W) inBEF testing

MeasuredBallastFactor in

BEF testing

MeasuredBallastEfficacyFactor

MeasuredBallastInputVoltage(V) in BE testing

MBInP(WBte

B

 l

T8 96 S9 IS 277 Y 277.07 S6.0 0.89 l.S96 276.96 

B

 l

T8 96 S9 IS 277 Y 277.07 S7.6 0.878 l.S23 277.0l 

D

 l

T8 96 S9 IS 277 N 277.00 S7.7 0.883 l.S29 277.l9 

D

 2

Tl2 96 60 IS l20 N ll9.92 l07. 0.8S0 0.792 N.D. 

A

 2

Tl2 96 60 IS 277 N 277.00 ll .3 0.907 0.79 N.D. 

B

 2

Tl2 96 60 IS 277 Y 276.89 lll.9 0.892 0.798 N.D. 

C 2 Tl2 96 60 IS 277 N 277.00 ll .8 0.908 0.79l N.D. 

D

 2

Tl2 96 60 IS 277 N 276.83 lll.l 0.88S 0.797 N.D. 

D

 2

Tl2 96 60 IS 277 N 276.86 l09.S 0.88 0.807 N.D. 

D

 2

Tl2 96 60 IS 277 Y 276.88 lll.2 0.900 0.809 N.D. 

A

 2

T8 96 S9 IS l20 N l20.Sl l0 .S 0.829 0.79 l20.ll 

B

 2

T8 96 S9 IS l20 N l20.20 ll2.9 0.876 0.776 l20.l0 

A

 2

T8 96 S9 IS 277 Y 277.03 l0S.7 0.8S0 0.80 277.l 

SC-6 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

Manufacturer

 N

umber

of Lamps

LampDiameter(t18 ofinches)

LampLength(inches)

LampNominalPower(W)

StartingMethod

BallastNominalInputVoltage(V)

UniversalInputVoltage? (Y1N)

MeasuredBallastInputVoltage(V) inBEF testing

Measured

BallastInputPower(W) inBEF testing

MeasuredBallastFactor in

BEF testing

MeasuredBallastEfficacyFactor

MeasuredBallastInputVoltage(V) in BE testing

MBInP(WBte

A

 2

T8 96 S9 IS 277 N 277.00 l0S. 0.8Sl 0.807 277.l 

B

 2

T8 96 S9 IS 277 N 277.00 l07.S 0.8S9 0.799 277.l6 

B

 2

T8 96 S9 IS 277 Y 276.9l l0S.2 0.8S9 0.8l7 277.06 

B

 2

T8 96 S9 IS 277 Y N.D. N.D. N.D. N.D. 277.l2 

C 2 T8 96 S9 IS 277 Y 276.9 l09.S 0.887 0.8l0 277.09 

C 2 T8 96 S9 IS 277 Y 276.97 l l.S l.l26 0.796 277.0l 

C 2 T8 96 S9 IS 277 Y 277.00 93.S 0.7S8 0.8ll 276.9 

C 2 T8 96 S9 IS 277 Y 276.77 l08.0 0.87 0.8l0 277.03 

D

 2

T8 96 S9 IS 277 N 276.86 l0 .9 0.868 0.827 277.l6 

D

 2

T8 96 S9 IS 277 N 277.00 92.8 0.7S8 0.8l7 277.l7 

D

 2

T8 96 S9 IS 277 N 276.97 ll0.2 0.873 0.792 277.l 

D

 2

T8 96 S9 IS 277 N 276.93 l 7.l l.lS6 0.786 277.07 

D

 2

T8 96 S9 IS 277 Y 276.92 l09.7 0.866 0.789 277.lS 

N.D. indicates DOE did not perform the measurement, "no data." 

Table SC.S Ballasts That Operate Eight-Foot RDC �O LampsManufacturer

 N

umber

ofLamps

LampDiameter(t18 ofinches)

LampLength(inches)

LampNominalPower(W)

StartingMethod

BallastNominalInputVoltage(V)

UniversalInputVoltage? (Y1N)

MeasuredBallastInputVoltage(V) inBEF testing

Measured

BallastInputPower(W) inBEF testing

MeasuredBallastFactor in

BEF testing

Measured

BallastEfficacyFactor

MeasuredBallastInputVoltage(V) in BE testing

MeBalInpPow(Wtest

A

 2

Tl2 96 9S RS 277 Y 276.90 l88.3 0.8S8 0. S6 N.D. N

A

 2

Tl2 96 9S RS 277 N 276.9l l66.0 0.8 0.S09 N.D. N

B

 2

Tl2 96 9S RS 277 N 276.87 l96.7 0.879 0. 7 N.D. N

C 2 Tl2 96 9S RS 277 N 276.7S 208. 0.9l7 0. 0 N.D. N

C 2 Tl2 96 9S RS 277 N 276.92 l6 .6 0.836 0.S08 N.D. N

D

 2

Tl2 96 9S RS 277 N 276.8 l72.2 0.87S 0.S08 N.D. N

D

 2

Tl2 96 9S RS 277 Y 276.8l l69.l 0.897 0.S3l N.D. N

D

 2

Tl2 96 9S RS 277 N 276.92 l9S.0 0.90l 0. 62 N.D. N

D

 2

T8 96 86 IS l20 N l20.03 l38.8 0.622 0. 8 l20.08 l

B

 2

T8 96 86 IS 277 Y 277.07 l38.7 0.6S2 0. 70 277.ll 9

SC-7 

EERE-2007-BT-STD-0016 COMMENT 20
  

 

 

   

 

 

 

 

 

 

 

 

D

 2

T8 96 86 IS 277 N 277.03 l 2.8 0.676 0. 73 277.l6 l

A

 2

T8 96 86 PS 277 Y 276.93 l8S.8 0.86 0. 6S 277.03 l

C 2 T8 96 86 PS 277 Y 277.l0 l7S.0 0.773 0. 2 277.08 l

A

 2

T8 96 86 RS l20 N l20.00 l62.l 0.7 0 0. S6 l20.02 l

N.D. indicates DOE did not perform the measurement, "no data." 

Table SC.� Ballasts That Operate Four-Foot MBP and Two-Foot U-Shaped Lamps in the Residential SectManufacturer

 N

umber

ofLamps

LampDiameter(t18 ofinches)

LampLength(inches)

LampNominalPower(W)

StartingMethod

BallastNominalInputVoltage(V)

UniversalInputVoltage? (Y1N)

MeasuredBallastInputVoltage(V) inBEF testing

Measured

BallastInputPower(W) inBEF testing

MeasuredBallastFactor in

BEF testing

Measured

BallastEfficacyFactor

MeasuredBallastInputVoltage(V) in BE testing

MeBalInpPow(Wtest

A

 l

Tl2 8 3 RS l20 N ll9.9S 3 .0 0.66S l.9S7 N.D. N

A

 2

Tl2 8 3 RS l20 N l20.00 63.l 0.8 l l.332 N.D. N

B

 2

Tl2 8 3 RS l20 N ll9.97 6 .6 0.860 l.332 N.D. N

� 2 Tl2 8 3 RS l20 N l20.l8 2. 0.627 l. 80 N.D. N

L

 2

Tl2 8 3 RS l20 N l20.l0 S0.3 0.6S2 l.297 N.D. N

E

 2

T8 8 32 IS l20 N ll9.88 SS.3 0.832 l.S0S l20.0 S 

E

 2

T8 8 32 IS l20 N l20.02 S3.l 0.780 l. 70 l20.0S 

A

 2

T8 8 32 IS l20 N l20.00 S .8 0.83l l.Sl7 ll9.99 S

B

 2

T8 8 32 IS l20 N l20.00 SS.7 0.8l8 l. 70 ll9.98 S

C 2 T8 8 32 IS l20 N l20.00 S7.S 0.8S7 l. 90 ll9.96 S

D

 2

T8 8 32 IS l20 N l20.00 SS.9 0.839 l.S00 ll9.98 S

A T8 8 32 IS l20 N l20.l0 l02.l 0.783 0.767 l20.l7 9

B T8 8 32 IS l20 N l20.l0 l07.2 0.82l 0.766 l20.lS l

C T8 8 32 IS l20 N l20.l0 ll3.2 0.8S6 0.7S6 l20.ll l

D T8 8 32 IS l20 N l20.l0 ll .6 0.8 S 0.738 l20.0S l

N.D. indicates DOE did not perform the measurement, "no data." 

Table SC.� Ballasts that Operate Eight-Foot �O Lamps in Cold Temperature Applications and Outdoor SManufacturer

 N

umber

ofLamps

LampDiameter(t18 ofinches)

LampLength(inches)

LampNominalPower(W)

StartingMethod

BallastNominalInputVoltage(V)

UniversalInputVoltage? (Y1N)

MeasuredBallastInputVoltage(V) inBEF testing

Measured

BallastInputPower(W) inBEF testing

MeasuredBallastFactor in

BEF testing

Measured

BallastEfficacyFactor

MeasuredBallastInputVoltage(V) in BE testing

MeBalInpPow(Wtest

F

 l

Tl2 96 ll0 IS l20 N l20.l0 l03.9 0.90l 0.867 N.D. N

SC-8 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

  

  

 

 

 

 

Manufacturer

 N

umber

ofLamps

LampDiameter(t18 ofinches)

LampLength(inches)

LampNominalPower(W)

StartingMethod

BallastNominalInputVoltage(V)

UniversalInputVoltage? (Y1N)

MeasuredBallastInputVoltage(V) inBEF testing

MeasuredBallastInputPower(W) inBEF testing

MeasuredBallastFactor in

BEF testing

Measured

BallastEfficacyFactor

MeasuredBallastInputVoltage(V) in BE testing

MeBalInpPow(Wtest

F

 2

Tl2 96 ll0 IS l20 N l20.03 l7 . 0.790 0. S3 N.D. N

D

 2

Tl2 96 ll0 IS l20 Y l20.00 l33. 0.6l3 0. 60 N.D. N

F

 3

Tl2 96 ll0 IS l20 N l20.l0 l7S.l 0.S37 0.306 N.D. N

� 3 Tl2 96 ll0 IS l20 N l20.l3 l77.l 0.S 2 0.306 N.D. N

F Tl2 96 ll0 IS l20 N l20.l0 269.l 0.603 0.22 N.D. N

H Tl2 96 ll0 IS l20 N ll9.90 260.8 0.6l8 0.237 N.D. N� Tl2 96 ll0 IS l20 N l20.l0 269.7 0.607 0.22S N.D. ND Tl2 96 ll0 IS l20 Y l20.00 2S .6 0.607 0.238 N.D. N

D Tl2 96 ll0 IS l20 Y ll9.90 26 .0 0.628 0.238 N.D. N

F Tl2 96 ll0 RS l20 N l20.03 388. 0.778 0.200 N.D. N

I Tl2 96 ll0 RS l20 N l20.03 l80.0 0.30 0.l69 N.D. N

D Tl2 96 ll0 RS l20 N l20.00 393.6 0.77l 0.l96 N.D. N

F

 6

Tl2 96 ll0 IS l20 N ll9.73 3 0.3 0.S3l 0.lS6 N.D. N

F

 6

Tl2 96 ll0 IS l20 N l20.23 08.8 0.636 0.lS6 N.D. N

H 6 Tl2 96 ll0 IS l20 N l20.03 397.8 0.62S 0.lS7 N.D. N� 6 Tl2 96 ll0 IS l20 N l20.00 3 9.3 0.609 0.l7 N.D. N� 6 Tl2 96 ll0 IS l20 N ll9.90 3 3.8 0.S 6 0.lS9 N.D. N

D

 6

Tl2 96 ll0 IS l20 Y l20.00 399.2 0.6 l 0.l6l N.D. N

� 6 Tl2 96 ll0 IS l20 Y l20.l0 l8.S 0.629 0.lS0 N.D. N

N.D. indicates DOE did not perform the measurement, "no data." 

SC-9 

EERE-2007-BT-STD-0016 COMMENT 20
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 Markups and Price Composition............................................... 5D-4
 

 5D-i 

EERE-2007-BT-STD-0016 COMMENT 20
APPENDIX 5D. MAX-TECH
 

5D.1 OVERVIEW
 

When the U.S. Department of Energy (DOE) proposes to adopt or to decline to adopt an 

amended or new standard for a type (or class) of covered product, as part 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 identified 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 feasible 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 information from manufacturer interviews, subject 

matter experts, scholarly articles, U.S. patents, and manufacturer marketing information. DOE 

also considered efficiency improvements used in comparable products, such as power supplies. 

The following sections discuss active rectification 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 assessment (preliminary TSD chapter 3), the second 

stage of an electronic ballast is the input rectifier, which converts AC to DC current. Through its 

research, DOE learned that commercially available ballasts use a process known as passive 

rectification to complete this step. A passive rectification 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 advancements in electronics in the past few decades and new 

developments in controls, metal-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 these MOSFETs in place of diodes to convert AC 

to DC current. Because MOSFETs operate in a slightly different manner than diodes, an 

5D-1 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

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 (preliminary 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 improvements required to move above 92 percent 

efficiency, even small improvements 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 price 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 components 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 the 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 components with lower electrical losses to be 

used in a more efficient ballast design. If more than one alternative existed, DOE chose the 

component that demonstrated the lowest electrical losses and therefore had the greatest potential 

to impact overall efficiency. DOE considered improvements for all components of the ballast, 

regardless of the stage in which they were used. 

5D-2 

EERE-2007-BT-STD-0016 COMMENT 20
 

5D.4.1 Efficiency 

Based on conversations with subject matter experts and members of the ballast and 

electronics community, DOE believes improving the efficiency (reducing electrical losses) of 

components which are currently included in the most efficient commercially available ballast 

could result in a 1 to 2 percentage point increase in efficiency. In this section, DOE discusses the 

characteristics of the alternative components 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; switching 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 available ballasts. Thus, to improve efficiency, 

DOE proposes using M-2a

 grain-oriented steel instead of low-grade, non-oriented steel in the 

core of the transformers. 

For transistors and capacitors, DOE had limited success in identifying more efficient 

replacements. As indicated in Table 5D.2, DOE found alternative MOSFETs with reduced 

electrical losses, but did not locate more efficient bipolar transistors. Thus, DOE only proposes 

to replace existing MOSFETS with a more efficient substitute. For electrolytic capacitors, DOE 

identified several more efficient components as potential 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 existing 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 efficient components available, DOE 

compared online pricing from electronics distributors. 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 grade of electrical steel with an ‘M’ followed by a number. 

Smaller numbers indicate electrical steel with smaller losses. 

5D-3 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

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 capacitor <1% 1.4 <1% 

Transformer, corec

 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 ballasts. Both of these options 

are employed in power supplies and other comparable power products. Although neither option 

is present in commercially available ballasts, DOE believes it is likely that they are 

technologically feasible because they are employed in similar products. As such, DOE has 

included them in this appendix to request comment 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 manufacturer 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

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 Francisco, California. Maryland: NASA Center 

for Aerospace Information; 2006. p. 1-12. 

5D-5 

EERE-2007-BT-STD-0016 COMMENT 20
APPENDIX 12A. MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDE 
 

Fluorescent Lamp Ballasts Rulemaking
 

Manufacturer Analysis Interview Guide 

October 23, 2008 

12A-1 

EERE-2007-BT-STD-0016 COMMENT 20
 

PART 1. MARKET, TECHNOLOGY, AND ENGINEERING ANALYSIS 

A. Market Data 

This section addresses information on the distribution of fluorescent 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 ballasts, 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 operate 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 ballasts that operate 8-foot recessed double contact high output T8 

and T12 lamps (e.g., F96T12HO, F96T12HO/ES, F96T8HO) 

DOE received written comments and comments at the public meeting that DOE should cover the 

following ballast types: 

o	 Low power factor, residential 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 ballast types listed above 

(e.g., low power factor, residential ballasts) and how that market share might change in 

the future. 

A.2	 DOE seeks comment on whether it is technologically 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

o 2-lamp F96T12HO, F96T12HO/ES, and F96T8HO ballasts 

A.4	 DOE seeks comment on whether these are the most appropriate fluorescent 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 ballast attributes (i.e., electronic/magnetic, 

starting method, ballast factor, input power, THD, power factor) 

In order to calculate the aggregate national energy savings, DOE would need data on shipment 

trends. For each of the ballast types, DOE is interested in obtaining shipment data by number of 

lamps operated and ballast efficiency. DOE is also interested 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 efficiency? 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 energy conservation standards, do you expect 

these proportions to change overtime? If so, how? 

A.10	 For F32T8 ballasts, what proportion of ballasts shipped are magnetic 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

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 energy consumption by 

understanding the design options involved in efficiency improvements. Please describe the 

discrete design steps you would undertake to achieve the ballasts in the tables below. In each 

case, start with a standard efficiency ballast, and list the necessary design changes1

 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 commercial 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-4 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

Table 1 Engineering Analysis for Electronic 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-5 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

 

 

 

Table 2 Engineering Analysis for Electronic 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 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 

selling price? 

D.2	 How would the answers given in Table 1 and Table 2 change for fluorescent lamp 

ballasts operating 4-lamps? 

12A-6 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

Table 3 Engineering Analysis for Electronic 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 improvements can be made and 

how would this impact the power consumed, the cost to manufacture the ballast, and the 

selling price? 

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Table 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? 

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EERE-2007-BT-STD-0016 COMMENT 20
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 ballasts migrate through 

the market from manufacturer to end-user. DOE is interested in understanding both the 

proportion (volume) of products that move through certain channels and the mark-ups applied. 

The following figure displays the distribution chain provided by NEMA in the 2000 Ballast 

Rule. According a comment provided by NEMA 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 Contractor/LMC to the End User of 

the Lighting System. 

Figure 1: 1999 NEMA Ballast Distribution Channels 

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C.1	 Is the distribution chain displayed in Figure 1 an accurate representation of how ballasts 

reach the end user? If so, what proportion 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 the 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 sectors? What proportion of ballast shipments to the residential 

sector are low power factor, residential ballasts 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 average annual operating hours for GSFL is 3,435 

hours for the commercial sector, 4,795 hours for the industrial sector and 789 hours for the 

residential sector. 

C.3	 Are these reasonable estimates? If not, what 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 ballast 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. Using average operating hours in the 

commercial sector, industrial, and residential sector, one calculates a ballast life of 

approximately 15 years, 10 years, or 63 years respectively. 

C.5	 DOE understands ballasts are sometimes replaced before they fail 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 lifetime 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”, renovation, 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. 

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EERE-2007-BT-STD-0016 COMMENT 20
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 accomplish 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 for 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 input power for these ballasts? These qualities will help DOE 

establish a new test procedure measuring ballast 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 equation 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 operate 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 extrapolation 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 operate 8-foot recessed double 

contact high output T8 and T12 lamps 

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PART 2. PRELIMINARY MANUFACTURER IMPACT ANALYSIS TOPICS 

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 issues 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 would 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 expenditure 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 facilities? 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 marketing strategy change with changes in 

the efficiency standard? 

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EERE-2007-BT-STD-0016 COMMENT 20
4.2	 Generally how would new product standards impact your customer mix, distribution 

channels, and corresponding profit margins?
 

4.3	 What is the approximate percentage 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 disproportionately advance or harm the competitive positions of 

some firms?
 

5.4	 Are there concerns over intellectual property?
 

5.5	 Could new standards result in disproportionate economic or performance penalties for 

particular consumer/user subgroups?
 

5.6	 Beyond price and energy efficiency, could new standards result in products that will be 

more or less desirable to consumers due to changes in product 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?
 

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APPENDIX EA-SCC. SOCIAL COST OF CARBON FOR REGULATORY IMPACT
 

ANALYSIS UNDER EXECUTIVE 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-CO2 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 Selected 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 Substitutability of Environmental Amenities .........................33 

EA-SCC.8 CONCLUSION......................................................................................................34 

EA-SCC.9 APPENDIX............................................................................................................41 

EA-SCC.9.1 Other (non-CO2) Gases ...........................................................................42 

EA-SCC.9.2 Extrapolating Emissions Projections to 2300 .........................................44 

LIST OF TABLES 

Table 1.1. Social Cost of CO2, 2010–2050 (2007$) ........................................................................2 

Table 4.1. Summary Statistics for Four Calibrated Climate Sensitivity Distributions..................14 

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EERE-2007-BT-STD-0016 COMMENT 20
Table 4.2. Socioeconomic and Emissions Projections from Select EMF-22 Reference 

Scenarios ................................................................................................................16 

Table 5.1. Disaggregated Social Cost of CO2 Values by Model, Socio-Economic 

Trajectory, and Discount Rate for 2010 (2007$)...................................................27 

Table 5.2. Social Cost of CO2, 2010–2050 (2007$) ......................................................................28 

Table 5.3. Changes in the Average Annual Growth Rates of SCC 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 Rate (2007$/ton CO2) ...............49 

Table 9.3. 2010 Global SCC Estimates at 3 Percent Discount Rate (2007$/ton CO2)..................49 

Table 9.4. 2010 Global SCC Estimates at 5 Percent Discount Rate (2007$/ton CO2)..................49 

Table 9.5. Additional Summary 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 Temperature 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 Density 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 (post-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 extrapolations assume GDP per capita 

growth declines linearly, reaching zero in 2300)...................................................46 

Figure 9.4. Global Fossil and Industrial CO2 Emissions, 2000-2300 (post-2100 

extrapolations assume growth rate of CO2 intensity (CO2/GDP) over 

2090–2100 is maintained through 2300) ...............................................................47 

Figure 9.5. Global Net Land Use CO2 Emissions, 2000–2300 (post-2100 extrapolations 

assume emissions decline linearly, reaching zero in 2200) ...................................47 

Figure 9.6. Global Non-CO2 Radiative Forcing, 2000–2300 (post-2100 extrapolations 

assume constant non-CO2 radiative forcing after 2100) ........................................48 

Figure 9.7. Global CO2 Intensity (fossil & industrial CO2 emissions/GDP), 2000–2300 

(post-2100 extrapolations assume decline in CO2/GDP growth rate over 

2090–2100 is maintained through 2300) ...............................................................48 

Figure 9.8. Histogram of Global SCC Estimates in 2010 (2007$/ton CO2), by Discount 

Rate*.......................................................................................................................50 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

APPENDIX EA-SCC. SOCIAL COST OF CARBON FOR REGULATORY IMPACT
 

ANALYSIS UNDER EXECUTIVE ORDER 12866 

Interagency Working Group 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 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 the benefits of the intended regulation justify its costs.” The purpose 

of the “social cost of carbon” (SCC) estimates presented here is to allow agencies to incorporate 

the social benefits of reducing carbon dioxide (CO2) emissions into cost-benefit analyses of 

regulatory actions that have small, or “marginal,” 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 over 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. 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 services due to climate change. 

This document presents a summary of the interagency process that developed these SCC 

estimates. Technical experts from numerous agencies met on a regular basis to consider public 

comments, explore the technical literature in relevant fields, and discuss 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 assumptions grounded in the existing scientific and economic literatures. 

In this way, key uncertainties and model differences transparently and consistently inform the 

range of SCC estimates used in the rulemaking process. 

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The interagency group selected four SCC values 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 95th percentile SCC 

estimate across all three models at a 3 percent discount rate, is included to represent higher-thanexpected impacts from temperature change further out in the tails of the SCC distribution. 

Table 1.1. Social Cost of CO2, 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 services. We report estimates of the social cost 

of carbon in dollars per metric ton of CO2 throughout this document.a 

When attempting to assess the incremental economic impacts of CO2 emissions, the 

analyst faces a number of serious challenges. A recent report from the National Academies of 

Science (NRC 2009) points out that any assessment will suffer from uncertainty, speculation, 

and lack of information about (1) future emissions 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 translation 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, economics, and ethics and should be 

viewed as provisional. 

Despite the serious limits of both quantification and monetization, SCC estimates can be 

useful in estimating the social benefits of reducing CO2 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 the benefits of the 

a

 In this document, we present all values of the SCC as the cost per metric ton of CO2 emissions. Alternatively, one 

could report the SCC as the cost per metric ton of carbon emissions. The multiplier for translating between mass of 

CO2 and the mass of carbon is 3.67 (the molecular weight of CO2 divided by the molecular weight of carbon = 44/12 

= 3.67). 

EA-SCC.2 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

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 CO2 emissions into costbenefit analyses of regulatory actions that have small or “marginal” impacts on cumulative 

global emissions. Most Federal regulatory 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 baseline emissions path, an approximation that is 

reasonable for policies that have effects on emissions that are small relative to cumulative global 

CO2 emissions. For policies that have a large (non-marginal) impact on global cumulative 

emissions, there is a separate question 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 basis to consider public comments, explore 

the technical literature in relevant 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 Departments 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, Office of Energy and Climate 

Change, and Office of Science and Technology Policy. 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 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 socio-economic and emissions scenarios at the 5, 3, 

and 2.5 percent discount rates, respectively. The fourth value is included to represent the higherthan-expected impacts from temperature change further out in the tails of the SCC distribution. 

For this purpose, we use the SCC value for the 95th 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 CO2 in 2015 and $26 per ton of CO2 in 2020. See 

Appendix A for the full range of annual SCC estimates from 2010 to 2050. 

It is important to emphasize that the interagency process is committed to updating these 

estimates as the science and economic understanding of climate 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 substantially updated models become available, and to 

continue to support research in this area. In the meantime, we will continue to explore the issues 

EA-SCC.3 

EERE-2007-BT-STD-0016 COMMENT 20
 

raised in this document and consider public comments 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 regulations have used a wide range of values to 

estimate the benefits associated with reducing CO2 emissions. In the final model year 2011 

CAFE rule, the Department of Transportation (DOT) used both a “domestic” SCC value of $2 

per ton of CO2 and a “global” SCC value of $33 per ton of CO2 for 2007 emission reductions 

(2007$), increasing both values at 2.4 percent per year. It also included a sensitivity analysis at 

$80 per ton of CO2. A domestic SCC value is meant to reflect the value of damages in the United 

States resulting from a unit change in CO2 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 CO2 

(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 $20 per ton CO2 for 2007 emission reductions (2007$). In addition, 

EPA’s 2008 Advance Notice of Proposed Rulemaking for Greenhouse Gases identified what it 

described as “very preliminary” SCC estimates subject to revision. EPA’s global mean values 

were $68 and $40 per ton CO2 for discount rates of approximately 2 percent and 3 percent, 

respectively (2006$ for 2007 emissions). 

In 2009, an interagency process was initiated to offer a preliminary assessment of how 

best to quantify the benefits from reducing CO2 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 CO2 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 comprehensive 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 CO2. 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 approximately 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 final rules and were offered for public comment in 

EA-SCC.4 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

connection with proposed rules, including the joint EPA-DOT fuel economy and CO2 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, the group has considered public 

comments and further explored the technical literature in relevant fields. This section details the 

several choices and assumptions that underlie the resulting 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 interagency 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 about the uncertainties 

embedded in them and with a sincere promise to continue work to improve them. 

EA-SCC.4.1 Integrated Assessment 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 detailed 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 (Policy 

Analysis 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 into changes in atmospheric greenhouse 

concentrations, atmospheric concentrations 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) pathways. These emissions are translated into 

concentrations using the carbon cycle built into each 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 approach to model how changes in emissions result 

in changes in economic damages. In PAGE, for example, the consumption-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 temperature in each region. In FUND, damages in each 

period also depend on the rate of temperature change from the prior period. In DICE, 

temperature affects both consumption and investment. 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 assumptions 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 quantifying 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: climate sensitivity, socio-economic and emissions trajectories, and 

discount rates. A probability distribution for climate sensitivity was specified as an input into all 

three models. In addition, the interagency group used a range of scenarios for the socio-economic 

parameters and a range of values for the discount rate. All other model features were left 

unchanged, relying on the model developers’ best estimates and judgments. In DICE, these 

parameters are handled deterministically and represented by fixed constants; in PAGE, most 

parameters are represented by probability distributions. 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 model based on a global production function with 

an extra stock variable (atmospheric CO2 concentrations). Emission reductions are treated as 

analogous to investment in “natural capital.” By investing in natural capital today through 

reductions in emissions—implying reduced consumption—harmful effects of climate change can 

be avoided and future consumption thereby increased. 

For purposes of estimating the SCC, CO2 emissions are a function of global GDP and the 

carbon intensity of economic output, with the latter declining over time due to technological 

progress. The DICE damage function links global average temperature 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 vulnerable 

market sectors” (based primarily on changes in energy use), human health (based on climaterelated diseases, such as malaria and dengue fever, and pollution), 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 impacts is then added to the other market and nonmarket impacts mentioned above. 

No structural components of the DICE model represent adaptation explicitly, though it is 

included implicitly through the choice of studies used 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 impact estimates assume 

improvements in healthcare over time. In addition, the small impacts on forestry, water systems, 

construction, fisheries, and outdoor recreation imply optimistic and costless adaptation in these 

sectors (Nordhaus and Boyer, 2000; Warren et al., 2006). Costs of resettlement due to sea level 

rise are incorporated into damage estimates, but their magnitude is not clearly reported. 

Mastrandrea’s (2009) review concludes that “in general, DICE 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. Because 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 and calculates these impacts separately for 

eight geographic regions. Damages in each region are expressed as a fraction of output, where 

the fraction lost depends on the temperature change in each region. Damages are expressed as 

power functions of temperature change. The exponents 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 catastrophic 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, the rate at which the probability of experiencing 

a discontinuity increases above the threshold, and 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 for developed countries and 0 °C for developing 

countries for economic impacts, and 0 °C for all regions for non-economic impacts), but 

adaptation is assumed to reduce these impacts. Default values in PAGE2002 assume that the 

developed countries can ultimately 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: agriculture, 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 health (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 sectors, economic damages also depend on CO2 

concentrations. 

Tol (2009) discusses impacts not included in FUND, 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 economic 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). 

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regard to potentially catastrophic events, he notes, “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 populations 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 CO2 fertilization (damages are generally negative but diminishing to zero). 

Adaptation is incorporated into FUND by allowing damages to be smaller if climate 

change happens more slowly. The combined effect of CO2 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 consumption-equivalent value of both market and non-market goods 

(represented as a fraction of global GDP). We recognize that these representations are 

incomplete and highly uncertain. 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, short of launching our own research program. 

The damage functions for the three IAMs are presented in Figure 4.1 and Figure 4.2, using the 

modeler’s default scenarios and mean input assumptions. There are significant differences 

between the three models both at lower (Figure 4.1) and higher (Figure 4.2) increases in globalaverage temperature. 

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Figure 4.1. Annual Consumption Loss as a Fraction of Global GDP in 2100 Due to an 

Increase in Annual Global Temperature in the DICE, FUND, and PAGE Modelse
 

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 the 

annual stream of benefits as a share of global GDP. Each specific combination of climate sensitivity, socioeconomic, and emissions parameters will produce a different 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 5th percentile estimated by PAGE, 

while the damages estimated by DICE are roughly equal to the 95th percentile estimated by 

PAGE. This is significant because at higher discount 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 percent 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 percent 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 adaptation, 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 Domestic 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, consideration of both global and domestic values is 

generally permissible; the relevant statutory 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 from 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 caused by GHG emissions. Second, climate change 

presents a problem that the United States alone cannot solve. Even if the United States were to 

reduce its greenhouse gas emissions to zero, that 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 States 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. 

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considerations are taken as a whole, the interagency 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 takes 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 weighting, 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 estimates 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 countries, the domestic benefit would 

be proportional to the U.S. share of global 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 range. 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-CO2 Emissions

 While CO2 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 reductions 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 their 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 CO2. 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 those caused by longer-lived gases. Impacts other 

than temperature change also vary across gases in ways that are not captured by GWP. For 

instance, CO2 emissions, unlike methane and other greenhouse gases, contribute to ocean 

acidification. Likewise, damages from methane emissions are not offset by the positive effect of 

CO2 fertilization. Thus, transforming gases into CO2-equivalents using GWP, and then 

multiplying the carbon-equivalents by the SCC, would not result in accurate estimates of the 

social costs of non-CO2 gases. 

In light of these limitations, and the significant contributions of non-CO2 emissions to 

climate change, further research is required to link non-CO2 emissions to economic impacts. 

Such work would feed into efforts to develop a monetized value of reductions in non-CO2 

greenhouse gas emissions. As part of ongoing work to further improve the SCC estimates, the 

interagency group hopes to develop methods to value these other greenhouse gases. The goal is 

to develop these estimates by the time we issue revised SCC estimates for CO2 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 CO2 concentration relative to pre-industrial levels 

(or stabilization at a concentration of approximately 550 parts per million (ppm)). Uncertainties 

in this important parameter have received substantial attention in the peer-reviewed literature. 

The most authoritative statement about equilibrium climate sensitivity appears in the 

Fourth Assessment Report of the Intergovernmental Panel on Climate Change (IPCC): 

Basing our assessment on a combination of several independent lines of evidence...including 

observed climate change and the strength of known feedbacks simulated in [global climate 

models], we conclude that the global mean equilibrium warming for doubling CO2, 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. Equilibrium 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 proxy 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 values 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 probability distributions and calibrated them to 

be consistent with the above statement: Roe and 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 Calibrated Climate Sensitivity 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 

5th Percentile 1.72 1.49 1.37 1.13 

10th Percentile 1.91 1.74 1.65 1.48 

Mode 2.34 2.52 2.65 2.90 

Median (50th percentile) 3.00 3.00 3.00 3.00 

Mean 3.50 3.28 3.19 3.07 

90th Percentile 5.86 5.14 4.93 4.69 

95th Percentile 7.14 5.97 5.59 5.17 

Each distribution was calibrated by applying three constraints from the IPCC: 

(1) a median equal to 3 °C, to reflect the judgment of “a most likely value of about 3 °C;”k 

(2) two-thirds probability that the equilibrium climate sensitivity 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 the climate system to increased greenhouse gas 

concentrations (Roe and Baker 2007; Roe 2008). In contrast, the other three distributions are 

mathematical functions that are arbitrarily chosen based on simplicity, convenience, and general 

shape. The Roe and Baker distribution results from 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 

95th percentile that is more consistent with IPCC judgments and the literature. For example, setting the mean and 

mode equal to 3 °C produced 95th 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 distribution better reflects the IPCC judgment that 

“values substantially higher than 4.5°C still cannot be excluded.” Although the IPCC made no 

quantitative judgment, the 95th percentile of the calibrated Roe & Baker distribution (7.1 °C) is 

much closer to the mean and the median (7.2 °C) of the 95th 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 distributions examined by the IPCC (Hegerl et al. 2006) 

than are the 95th percentiles of the three other calibrated 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 certainty 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 from the IPCC Fourth Assessment Report. These 

functions are scaled to integrate to unity between 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 Density 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 interagency 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 reason, we consider how to model several input parameters in 

tandem: GDP, population, CO2 emissions, and non-CO2 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 scenarios 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 uses 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 level 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. Five 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 CO2 (only) concentrations ranging from 612 to 889 ppm in 2100. One 

represents an emissions pathway that achieves stabilization at 550 ppm CO2e (i.e., CO2-only 

concentrations of 425–484 ppm or a radiative forcing of 3.7 W/m2) 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 CO2e scenario, we averaged the 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 CO2 Emissions 

GtCO2/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. 

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550 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 various assumptions about how the future will 

evolve without prejudging what is likely to occur. 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 absent mitigation policies to reduce greenhouse gas 

emissions, rather than the wider range of possible 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 trajectories associated with a 550 ppm CO2e 

concentration scenario are not derived from an assessment of what policy is optimal from a 

benefit-cost standpoint. Rather, it is indicative of one possible 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 assume 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 significant 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 approach 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 CO2 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 population trajectories for the IMAGE, MiniCAM, and 

MERGE models. 

In addition to fossil and industrial CO2 emissions, each EMF scenario provides 

projections of methane, nitrous oxide, fluorinated greenhouse gases, and net land use CO2 

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 the discount rate has a large influence on the current value of 

future damages, there is no consensus about what rates to use in this context. Because CO2 

emissions are long-lived, subsequent damages occur over many years. In calculating the SCC, 

we first estimate the future damages to agriculture, human health, and other market and nonmarket sectors from an additional unit of CO2 emitted in a particular year in terms of reduced 

consumption (or consumption equivalents) 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 marginal 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 choice 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 benefits using discount rates of 3 and 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 CO2 emissions to 83 percent below 2005 

levels by 2050 (per the G-8 agreement) but all other countries continue along a BAU path CO2 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) perspective 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 “because of a lack of justification for choosing a 

social welfare function that is any different than what decision makers [individuals] actually use” 

(Arrow et al. 1996). 

One theoretical foundation for the cost-benefit analyses 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 compensation is difficult to define in the 

intergenerational context. On the other hand, societies provide compensation to future 

generations through investments in human capital and the resulting increase 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 utility 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 generations, and many agree with this view. 

Other concerns also motivate making adjustments to descriptive discount rates. In 

particular, it has been noted that the preferences 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 rate should be below market rates to correct for 

market distortions and uncertainties or inefficiencies in intergenerational transfers of wealth, 

which in the Kaldor-Hicks logic are presumed to compensate future generations for damage (a 

potentially controversial assumption, as noted above; Arrow et al. 1996, Weitzman 1999). 

Further, a legitimate concern about both descriptive and prescriptive approaches is that 

they tend to obscure important heterogeneity in the population. The utility function that underlies 

the prescriptive approach assumes a representative agent with perfect foresight and no credit 

constraints. This is an artificial rendering of the real world that misses many of the frictions that 

characterize individuals’ lives and 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 

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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 recognition of its limitations, we find this approach to be the most 

defensible and transparent given its consistency with the standard contemporary theoretical 

foundations of benefit-cost analysis and with the approach required by OMB’s existing guidance. 

The logic of this framework also suggests that market rates should be used for discounting future 

consumption-equivalent damages. Regardless of the theoretical 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 selecting 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 consequences of selecting one discount 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 appropriate 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 and the consumption rate of interest. Thus, the 

literature recognizes two conceptual discount concepts—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 instance, via higher prices for goods and services— 

a lower discount rate of 3 percent is appropriate to reflect how private individuals trade-off 

current and future consumption. 

The interagency group examined the economics literature and concluded that the 

consumption rate of interest is the correct concept 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 the three integrated assessment models used for 

estimating the SCC. 

Individuals use a variety of savings instruments that vary with risk level, time horizon, 

and tax characteristics. The standard analytic framework used to develop intuition about the 

discount rate typically assumes a representative 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 the uncertain amount. However, the calculation of 

the certainty-equivalent requires first estimating the correlation between the benefits of the 

policy and baseline consumption. 

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If the IAM projections of future impacts represent expected values (not certaintyequivalent values), then the appropriate 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-equivalent 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 percent, which is roughly consistent with Circular A-4’s 

recommendation to use 3 percent to represent 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 percent) 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 

q

 The 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. 

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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 prescriptive 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 ranging 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 neutrality. 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-economists have argued for constant 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 dollar in poorer countries compared to wealthier ones. Stern (2006) 

applies this perspective 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. 

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savings behavior, however, Stern’s assumptions suggest that individuals would save 93 percent 

of their income.w 

Recently, Stern (2008) revisited the values used 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 prescriptive approach can be used to justify 

discount rates between roughly 1.4 and 3.1 percent. 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 theoretically 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-equivalent) discount rate that declines over time. 

Consequently, lower discount rates tend to dominate 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 uncertainty remains an active area of research. 

Newell and Pizer (2003) employ a model of how long-term interest rates change over time to 

forecast future discount rates. Their model incorporates 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 Pizer (2003) and Panipoulou et al. (2004) attempt formally to model 

uncertainty in the discount rate, others argue for a declining scale of discount rates applied over 

time (e.g., Weitzman 2001, and the UK’s “Green Book” for regulatory analysis). This approach 

uses a higher discount rate initially, but applies a graduated scale of lower discount rates further 

out in time.x

 A key question that has emerged with regard 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. 

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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 certainty-equivalent constant 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 consistent with estimates provided 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 riskless 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 incorporate the concern that interest rates are 

highly uncertain over time. It represents the average certainty-equivalent rate using the meanreverting and random walk approaches from Newell and Pizer (2003) starting 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 responds to certain judgments using the prescriptive 

or normative approach and to ethical objections that have been raised about 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). 

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•	 A Roe and Baker distribution for the climate sensitivity parameter bounded between 0 

and 10 with a median of 3 °C and a cumulative 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 rates of 2.5, 3, and 5 percent. 

Because the climate sensitivity parameter is modeled probabilistically, and because PAGE and 

FUND incorporate uncertainty in other model parameters, 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 population from the selected EMF-22 scenarios, 

and the extrapolations based on these 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 depend on both the level and the rate of 

temperature change in that period. 

c.	 In DICE, temperature affects both consumption and investment, so we first adjust the 

EMF GDP paths as follows: Using the Cobb-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 resulting 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 steps, while the time steps in PAGE vary.) 

6.	 Discount the resulting path of marginal damages 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 emissions used to shock the models in step 3. 

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8.	 Multiply by 12/44 to convert from dollars per ton of carbon to dollars per ton of CO2 

(2007 dollars) in DICE and FUND. (All calculations are done in tons of CO2 in PAGE). 

The steps above were repeated in each model for multiple future years to cover the time 

horizons anticipated for upcoming rulemaking analysis. To maintain consistency across the three 

IAMs, climate damages are calculated 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 under 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 more detailed discussion of these assumptions is 

included in the Appendix.) 

This exercise produces 45 separate distributions of the SCC for a given year, the product 

of 3 models, 3 discount rates, and 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 distributions 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 distributions are then used to define 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 rate, 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 values for use in regulatory analyses. Three 

values are based on the average SCC across models and socio-economic and emissions scenarios 

at 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 95th 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 regulatory 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 

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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 SCC 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 CO2 Values by Model, Socio-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 values to 2007 dollars for the year 2010 (assuming, as we did for 

the interim process, that SCC grows at 3 percent per year), FUND yields SCC estimates at or 

near zero for a 5 percent discount rate and around $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 generate 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 for a 4 percent discount rate. Note that these 

comparisons are only approximate since the literature 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

         

 

 

 

 

 

 

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, whereas 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 levels 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 relationship between its damage 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 values 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 CO2, 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.28 

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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 

The SCC increases over time because future emissions 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 other modeling assumptions. Table 5.3 illustrates how the growth rate 

for these four SCC estimates varies over time. The full set of annual 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 determine 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, climate 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 evolving scientific, economic, 

and ethical understandings. During the course of our modeling, it became apparent that there are 

several areas in particular need of additional exploration and research. These caveats and 

additional observations in the following section are 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 CO2 emissions will be 

discounted at rates that differ from those used to develop the SCC estimates. 

EA-SCC.29 

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Incomplete treatment of non-catastrophic damages. The impacts of climate change are 

expected to be widespread, diverse, and heterogeneous. In addition, the exact magnitude of these 

impacts is uncertain because of the inherent complexity 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 assign 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 into these models understandably lags behind the 

most recent research. Our ability to quantify 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 remain non-monetized. (Ocean acidification is one example of a 

potentially large damage from CO2 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 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. 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 Daigneault (2009) confirmed the potential for 

large catastrophe risk premiums but also showed 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 cases 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 developed to account for such risks in regulatory 

analysis. (The next section discusses the scientific 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 extrapolated 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 extreme 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 adaptation in FUND, including widespread reliance on 

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air conditioning, so much so that the largest single benefit category in FUND is the reduced 

electricity costs from not having 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 under the assumption that farmers will change land 

use practices in response to climate change (Mastrandrea 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 potential 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 aversion 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 95th 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 for regulatory policy. Even if individuals are not 

risk-averse for such scenarios, it is possible that 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] should in general assume ‘risk neutrality’ in [their] 

analysis.” 

Nordhaus (2008) points to the need to explore 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 assumptions 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 carbon.” 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 whatever their next best use would have been in the absence 

of climate change (so productivity/GDP would have been still higher). 

EA-SCC.31 

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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 underestimates of the SCC (Mastrandrea 2009). In particular, 

the models’ functional forms may not adequately capture: (1) potentially 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 and increased consumption. 

It is the hope of the interagency group that over time researchers 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. In the meantime, we 

discuss some of the available evidence. 

EA-SCC.7.1	 Extrapolation of Climate Damages 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 extrapolated to the high temperatures found in the 

upper end of the distribution. Recent science suggests that there are a number of potential 

climatic “tipping points” at which the Earth system may exhibit discontinuous behavior with 

potentially severe social and economic consequences (e.g., Lenton et al. 2008, Kriegler et al. 

2009). These tipping points include the disruption of the Indian Summer Monsoon, dieback of 

the Amazon Rainforest and boreal forests, collapse of the Greenland Ice Sheet and the West 

Antarctic Ice Sheet, reorganization of the Atlantic Meridional Overturning Circulation, 

strengthening of El Niño-Southern Oscillation, and the release of methane from melting 

permafrost. Many of these tipping points are estimated to have thresholds between about 3 °C 

and 5 °C (Lenton et al. 2008). Probabilities of several of these tipping points were assessed 

through expert elicitation in 2005–2006 by Kriegler et al. (2009); results from this study are 

highlighted in Table 7.1. Ranges of probability are 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 

EERE-2007-BT-STD-0016 COMMENT 20
 

As previously mentioned, FUND does not include potentially catastrophic effects. DICE 

assumes a small probability of catastrophic damages that increases 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 95th percentile and a 3 percent 

discount rate, the SCC estimated by PAGE across the five socio-economic and emission 

trajectories of $113 per ton of CO2 is almost double the value estimated by DICE, $58 per ton in 

2010. 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 instance, PAGE places a probability near zero on a 

catastrophe at 2.5 °C warming, while DICE assumes 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 IAMs. 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 environmental change with high economic impact. 

EA-SCC.7.2 Failure to Incorporate Inter-Sectoral and Inter-Regional Interactions 

The damage functions do not fully incorporate 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 included in some of the models (FUND includes 

the effects of migration from sea level rise). These 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 scenarios, 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 systems. For instance, during the Paleocene-Eocene 

Thermal Maximum about 55.5 million years ago, when the Earth experienced a geologically 

EA-SCC.33 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

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 increased consumption of non-climate 

goods, a common assumption in many economic models. In the context of climate change, 

however, it is possible that the damages to natural 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 scarcer 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 socio-economic and emissions scenarios at the 5, 3, 

and 2.5 percent discount rates, respectively. The fourth value is included to represent the higherthan-expected impacts from temperature change further out in the tails of the SCC distribution. 

For this purpose, we use the SCC value for the 95th 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 CO2 in 2015 and $26 per ton of CO2 in 2020. 

We noted a number of limitations to this analysis, including the incomplete way in which 

the integrated assessment models capture catastrophic 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 impacts to economic damages makes this modeling exercise even more 

difficult. It is the hope of the interagency group that over time researchers 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.9 APPENDIX 

This Appendix provides additional technical information about the non-CO2 emission 

projections used in the modeling and the method for extrapolating emissions forecasts through 

2300, and shows the full distribution of 2010 SCC estimates by model and scenario 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 

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EA-SCC.9.1 Other (non-CO2) Gases 

In addition to fossil and industrial CO2 emissions, each EMF scenario provides 

projections of methane (CH4), nitrous oxide (N2O), fluorinated gases, and net land use CO2 

emissions to 2100. These assumptions are used in all three IAMs while retaining each model’s 

default radiative forcings (RF) due to other factors (e.g., aerosols and other gases). Specifically, 

to obtain the RF associated with the non-CO2 EMF emissions only, we calculated the RF 

associated with the EMF atmospheric CO2 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-CO2 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 CH4, N2O, SF6, and the CO2 

emissions from land were replaced with the EMF values. 

 PAGE: PAGE models CO2, CH4, sulfur hexafluoride (SF6), and aerosols and contains an 

“excess forcing” vector that includes the RF for everything else. To include the EMF values, we 

removed the default CH4 and SF6 factors,ee decomposed the excess forcing vector, and 

constructed a new excess forcing vector that includes the EMF RF for CH4, N2O, and fluorinated 

gases, as well as the model default values for aerosols and other factors. Net land use CO2 

emissions were added to the fossil and industrial CO2 emissions pathway.

 DICE: DICE presents the greatest challenge because all forcing due to factors other than 

industrial CO2 emissions is embedded in an exogenous non-CO2 RF vector. To decompose this 

exogenous forcing path into EMF non-CO2 gases and other gases, we relied on the references in 

DICE2007 to the Intergovernmental Panel on Climate Change’s (IPCC) Fourth Assessment 

Report (AR4) and the discussion of aerosol forecasts in the IPCC’s Third Assessment Report 

(TAR) and in AR4, as explained below. In DICE2007, Nordhaus assumes that exogenous forcing 

from all non-CO2 sources is -0.06 W/m2

 in 2005, as reported in AR4, and increases linearly to 

0.3 W/m2

 in 2105, based on GISS projections, and then stays constant after that time. 

According to AR4, the RF in 2005 from CH4, N20, and halocarbons (approximately 

similar to the F-gases in the EMF-22 scenarios) was 0.48 + 0.16 + 0.34 = 0.98 W/m2

 and RF 

from total aerosols was -1.2 W/m2. Thus, the -.06 W/m2 non-CO2 forcing in DICE can be 

decomposed into: 0.98 W/m2 due to the EMF non-CO2 gases, -1.2 W/m2 due to aerosols, and the 

remainder, 0.16 W/m2

, due to other residual forcing. 

dd Note EMF did not provide CO2 concentrations for the IMAGE reference scenario. Thus, for this scenario, we fed 

the fossil, industrial and land CO2 emissions into MAGICC (considered a “neutral arbiter” model, which is tuned to 

emulate the major global climate models) and the resulting CO2 concentrations were used. Note also that MERGE 

assumes a neutral biosphere so net land CO2 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 CH4 emissions and the initial atmospheric CH4 is set to zero to avoid double counting the 

effect of past CH4 emissions. 

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For subsequent years, we calculated the DICE default RF from aerosols and other nonCO2 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-CO2 gases not included in the EMF-22 scenarios, the share 

of non-aerosol RF matches the share implicit in the AR4 summary statistics 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 total RF from aerosols (including sulfates, black 

carbon, and organic carbon) in 2100 vs. 2000 under the A1B SRES emissions scenario. Since the 

SRES marker scenarios were not updated for the 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 representation 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. For 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 part 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/m2

; forcing due to other non-CO2 gases not included in the EMF scenarios declines from 

0.160 to 0.153 W/m2. 

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.
 

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. 

Figure 9.1. Sulphur Dioxide Emission Scenarios 

Notes: Thick colored lines depict the four SRES marker scenarios and black dashed lines show the median, 

5th and 95th 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 SO2 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 decomposing 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 through 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 later 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 CO2 emissions are added to the fossil and 

industrial CO2 emissions pathway. 

EA-SCC.9.2 Extrapolating Emissions Projections to 2300 

To run each model through 2300 requires assumptions about GDP, population, 

greenhouse gas emissions, and radiative forcing trajectories after 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 (CO2/GDP) growth rate over 

2090-2100 is maintained from 2100 through 2300. 

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4. Net land use CO2 emissions decline linearly, reaching zero in 2200. 

5. Non-CO2 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 extrapolation 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 available 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 consistent 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 trajectories (Figure A2) also encompass the UN 

medium scenario forecasts through 2300 – global 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., CO2 per 

dollar of GDP) through 2300 assumes that technological improvements and innovations in the 

areas of energy efficiency and other carbon reducing 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 CO2 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-CO2 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 CO2 emissions, net land CO2 emissions, non-CO2 radiative forcing, and CO2 intensity 

(fossil and industrial CO2 emissions/GDP) resulting from these assumptions. 

ii United Nations. 2004. World Population to 2300. 

http://www.un.org/esa/population/publications/longrange2/worldpop2300final.pdf. 

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5.5

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

Extrapolations

Global Population [billion]

Year

Figure 9.2. Global Population, 2000–2300 (post-2100 extrapolations assume the population 

growth rate changes linearly 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 CO2e, full-participation, not-to-exceed 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

Year

World GDP [$trillion]

Figure 9.3. World GDP, 2000-2300 (post-2100 extrapolations 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 CO2e, 

full-participation, not-to-exceed scenarios considered by each of the four models. 

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 Fossil&Industrial CO2 Emissions[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 CO2 Emissions, 2000-2300 (post-2100 

extrapolations assume growth rate of CO2 intensity (CO2/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 scenarios 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

Extrapolations

Net land CO2 emissions [GtCO2/yr]

Year

z 

Figure 9.5. Global Net Land Use CO2 Emissions, 2000–2300 (post-2100 extrapolations 

assume emissions decline linearly, 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 scenarios considered by each of the four models. 

jj MERGE assumes a neutral biosphere so net land CO2 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). 

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0.00

0.75

1.50

2.25

3.00

3.75

2000 2050 2100 2150 2200 2250 2300

IMAGE

MERGE

MESSAGE

MiniCAM

5th scenario

Extrapolations

nonCO2 RF [W/m^2]

Year

Figure 9.6. Global Non-CO2 Radiative Forcing, 2000–2300 (post-2100 extrapolations 

assume constant non-CO2 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 scenarios 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

Extrapolations

Fossil

&IndustrialCO2 intensity [GtCO2/trillion $]

Year

Figure 9.7. Global CO2 Intensity (fossil & industrial CO2 emissions/GDP), 2000–2300 (post2100 extrapolations assume decline in CO2/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 CO2e, full-participation, not-to-exceed scenarios considered by each of the four models. 

EA-SCC.48 

EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 9.2. 2010 Global SCC Estimates at 2.5 Percent Discount Rate (2007$/ton CO2) 

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 CO2) 

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 CO2) 

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 

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EERE-2007-BT-STD-0016 COMMENT 20
 

 

 

 

 

 

 

 

           

 

 

 

 

 

 

 

Message 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

‐25‐12

1

14274053667992

105118131144157170183196209222235248261274

All 2010, 5.0% All 2010, 3.0% All 2010, 2.5%

Figure 9.8. Histogram of Global SCC Estimates in 2010 (2007$/ton CO2), 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 1st and 99th percentiles to better show the data. 

Table 9.5. Additional Summary Statistics 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 

EERE-2007-BT-STD-0016 COMMENT 20