1 | Building Technologies Program 

BUILDING TECHNOLOGIES PROGRAM 

Energy Conservation Standards Preliminary Analysis for Fluorescent Lamp Ballasts 

Linda GraDepartment of EEnergy Efficiency ballasts.rulemaki

April 26, 2010 

EERE-2007-BT-STD-0016 COMMENT 27
2

34

Background and Legal Authority

5

23

415

6

Public Meeting Agenda 

Market & Tech; Screening; Engineering 

Energy Use; Markup Analysis 

Overview 

Life-Cycle Cost and Payback Period Analysis 

National Impact Analysis 

Preliminary MIA; NOPR Analyses 

2 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
3 | Building Technologies Program 

Stakeholder Participation in the Rulemaking Process 

Federal Register 

Notices 

Framework 

Document 

Preliminary 

Analysis NOPR Final Rule 

• Public meetings and oral comments• Written comments on Federal Register notices, T

Support Documents and Analytical Spreadsheets 

• Data input from manufacturers and other interest

Stakeholder 

Participation 

Today 

EERE-2007-BT-STD-0016 COMMENT 27
Fluorescent Lamp Ballasts 

Rulemaking Schedule 

2007 2008 2009 2010 2011 2012 2013 2014 

Milestone 

Framework Document Published JanFederal Register Notice of Public Meeting and Availability of the Preliminary Technical Support Document MIssue NOPR D

Issue Final Rule Effective Date 

4 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
2

34

Background and Legal Authority

5

23

45

6

Public Meeting Agenda 

1

Market & Tech; Screening; Engineering 

Energy Use; Markup Analysis 

Overview 

Life-Cycle Cost and Payback Period Analysis 

National Impact Analysis 

Preliminary MIA; NOPR Analyses 

5 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
6 | Building Technologies Program 

Framework 

Document 

Preliminary 

Analysis 

NOPR Final Rule 

Market & Technology 

Screening Analysis 

Engineering Analysis 

Energy Use & End Use Load Characterization 

Shipments 

Analysis 

Markups for Equipment Price Determination 

Life-Cycle Cost and Payback Period Analysis 

Preliminary Manufacturer Impact Analysis 

Preliminary AnalysisRulemaking Stage 

EERE-2007-BT-STD-0016 COMMENT 27
Purpose 

•	 Market and Technology Assessment 

–	 Determine the scope of coverage –	 Characterize the fluorescent lamp ballast market an

–	 Identify the technology options to improve ballast eff–	 Establish product classes 

• Screening Analysis 

–	 Screen out technology options that DOE will not con

engineering analysis for fluorescent lamp ballasts 

7 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Scope of Coverage 

•	 Fluorescent lamp ballast means a device which 

start and operate fluorescent lamps by providing voltage and current and limiting the current durin

operation. 42 U.S.C. 6291(29)(a) 

•	 Fluorescent lamp ballasts that are currently cove

include ballasts that operate: 

Number of Lamps Lamp Type 

1 or 2 F40T12 1 or 2 F34T12 

2 F96T12 2 F96T12/ES 2 F96T12HO 2 F96T12HO/ES 

8 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Scope of Coverage 

•	 DOE considered additional fluorescent lamp ball

coverage according to the directive in 42 U.S.C. 6295(g)(7)(B) 

•	 DOE employed the following criteria when determ

which additional ballasts to include in coverage: 

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

9 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Scope of Coverage 

•	 In the preliminary scope of coverage, DOE include

that operate: 

–	 One to six 4-foot MBP lamps in the commercial sect–	 One to four 4-foot MBP lamps in the residential sect–	 One to two 4-foot MiniBP SO lamps –	 One to four 4-foot MiniBP HO lamps –	 One to two 8-foot SP Slimline lamps –	 One to two 8-foot RDC HO lamps –	 One to six 8-foot RDC HO lamps in cold temperatur

signs 

•	 DOE did not consider dimming ballasts in the preli

scope of coverage 

10 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Issues for Discussion 

Issue 2: DOE invites comment on its rationale for extcoverage and also its proposed scope of coverage. Dspecifically requests comment on its exclusion of dimmballasts from the scope of coverage 

Issue 3 from the Test Procedure NOPR: DOE seek

comment on potential methods of measurement to dethe efficiency of dimming ballasts if DOE decides to in

them in the scope of energy conservation standards. 

11 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Product Classes 

•	 DOE establishes separate energy conservation s

for each product class 

•	 DOE divides covered product into classes by: 

(1) the type of energy used; (2) the capacity of the equipment; and (3) any other performance-related features that requ

standard levels, such as features affecting consum

(42 USC 6295(q)) 

12 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Product Classes 

•	 DOE used the following criteria to subdivide balla

product classes: 

–	 Lamp Length –	 Number of Lamps –	 Lumen Package –	 Lamp Diameter (T5 Lamps) –	 Starting Method –	 Market Sector 

13 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Product Classes: 

Lamp Length and Number 

•	 A ballast’s input power affects its BEF 

–	 Longer lamps tend to have higher wattages than c

shorter lamps and therefore ballasts operating lonhave lower BEFs 

–	 Operating greater numbers of lamps causes a bal

have a lower BEF than if it were operating only on

•	 Both lamp length and operating different number

lamps affect the physical space required by the lballast system. 

•	 Result: Subdivide product classes by ballasts tha

–	 One, two, three, four, five, or six lamps –	 Four- or eight-foot lamps 

14 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Product Classes: 

Lumen Package 

•	 Lumen package refers to the quantity of light pro

a lamp-and-ballast system 

•	 HO systems have a higher input power compare

systems, causing them to have lower BEFs. 

•	 Low and high BF ballasts have lower BEFs than 

BF ballasts. 

•	 Consumers use systems with different lumen pa

different applications 

•	 Result: Subdivide product classes by ballasts tha

–	 Standard Output or High Output –	 Low (BF ≤ 0.78), Normal (0.78 < BF < 1.10), or Hi

1.10) ballast factor 

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EERE-2007-BT-STD-0016 COMMENT 27
Product Classes: 

Lamp Diameter 

•	 Due to higher input power, T12 ballasts generally 

lower BEFs than T8 ballasts, which in turn have BEFs than T5 ballasts. 

•	 Lamp diameter alone does not represent a uniqu

–	 T8 systems are direct replacements for T12 syste

•	 T5 systems have certain application restrictions 

their quantity of light per unit lamp length. 

–	 T5 systems are not appropriate for use in direct lig

fixtures. 

•	 Result: Establish separate product classes for ba

operate T5 lamps 

16 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Product Classes: 

Starting Method 

•	 Programmed Start (PS) and Rapid Start (RS) ba

have lower BEFs than Instant Start (IS) ballasts 

electrode heating 

•	 IS ballasts are common replacements for RS ba•	 Occupancy sensors are predominantly used with 

ballasts rather than IS or RS ballasts 

•	 Result: Subdivide product classes by ballasts tha

–	 PS Ballasts or RS/IS Ballasts 

17 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Product Classes: 

Market Sector 

•	 Residential ballasts have lower BEFs than comp

commercial ballasts, possibly due to more stringrequirements 

•	 Sign ballasts have lower BEFs than comparable 

that operate 8-foot HO lamps, due to cold temperequirements 

•	 Use in a specific application, for which other ball

not a suitable substitute, indicates utility 

•	 Result: Subdivide product classes by ballasts tha

–	 Residential Ballasts vs. Commercial/Industrial Bal

–	 Cold Temperature Sign Ballasts 

18 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Product Classes: Example 

• In summary, DOE established 70 product classe

fluorescent lamp ballasts 

Ballast and 

Lamp Type 

Starting 

Method 

Ballast 

Factor 

Number of Lamps 

One Two Three Four Five 

4-Foot MBP and 

2-Foot U-Shaped 

IS and RS 

High 1 2 3 4 5 

Normal 7 8 9 10 11 

Low 13 14 15 16 17 

PS 

High 19 20 21 22 23 

Normal 25 26 27 28 29 

Low 31 32 33 34 35 

... 

19 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Issues for Discussion 

Issue 3: DOE defined product classes based on lam

lumen package, maximum number of lamps operatedmethod, ballast factor, and market sector. These class

factors created 70 product classes. DOE seeks commthese product classes – including comments on the appropriate starting method definitions to use in the relanguage and the ranges attributed to high, low, and nballast factor 

20 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Technology Options to Improve BEF 

• Electronic Ballasts • Lamp Diameter • Improved Components 

– Transformers – Diodes – Capacitors – Transistors 

• Improved Circuit Design
 

– Cathode cutout – Integrated circuits – Starting method 

21 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Issues for Discussion 

Issue 4: DOE identified several technology options tthe efficiency of a fluorescent lamp ballast. DOE invitecomment on these options, discussed in preliminary Tchapter 3. 

22 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Screening Analysis 

•	 Technology options are screened using the follow

criteria: 

–	 Technological feasibility –	 Practicability to manufacture, install, and service –	 Adverse impacts on product utility or availability to 

customers 

–	 Adverse impacts on health or safety 

•	 DOE screened out one technology option: lamina

sheets of amorphous steel 

23 | Building Technologies Program 

Issue 5: DOE invites comment on the technology opteliminated during the screening analysis. 

EERE-2007-BT-STD-0016 COMMENT 27
24 | Building Technologies Program 

Framework 

Document 

Preliminary 

Analysis 

NOPR Final Rule 

Market & Technology 

Screening Analysis 

Engineering Analysis 

Energy Use & End Use Load Characterization 

Shipments 

Analysis 

Markups for Equipment Price Determination 

Life-Cycle Cost and Payback Period Analysis 

Preliminary Manufacturer Impact Analysis 

Preliminary AnalysisRulemaking Stage 

EERE-2007-BT-STD-0016 COMMENT 27
Engineering Analysis:

Purpose 

•	 To evaluate design options that improve BEF rel

the baseline units. 

• To characterize manufacturer selling price versu

relationship for higher BEF fluorescent lamp ball

Downstream A

• Life-Cycle Cost 

Payback Period 

• National Impact 

Manufacturer Selling Price –

BEF Relationship 

Manufacturer

Selling Price 

BEF 

25 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Engineering Analysis:

Methodology 

Choose 

Representative 

Product Classes 

Scale to Product 

Classes Not 

Analyzed 

Define Baseline 

Models 

Select Higher 

BEFSubstitutes 

Develop CSLs 

Develop MPCs 

� Choose product classes to be analyzed in th

and life-cycle cost analysis. 

� Define characteristics of models in each rep

product class which will serve as reference changes due to energy conservation standa

� Identify higher BEF substitutes from a datab

commercially-available ballasts. Substitutes 

similar light output and save energy when po

� Determine manufacturer production costs fo

ballasts and their higher BEF substitutes. 

� Develop candidate standard levels that span 

efficacy from the baseline to the maximum tfeasible. 

� Scale results to other product classes not an

26 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Representative Product Classes 

•	 DOE chose representative product classes to co

its analytical effort. 

•	 DOE based its selection on those product classe

highest volume of shipments. 

•	 Of 70 total product classes, DOE selected 10 as 

representative. 

•	 Four for ballasts that operate 4-foot MBP lamp

commercial sector 

•	 At least one for every other ballast type 

•	 DOE tested ballasts in all representative product 

27 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Baseline Models 

•	 Typically a baseline ballast just meets the existin

conservation standard or represents the most colowest BEF ballast in that product class. 

•	 DOE selected multiple baseline ballasts in certai

classes to ensure consideration of different ballaand their associated consumer economics. 

•	 For example, for ballasts that operate two 4-foot 

lamps, DOE selected two baselines 

–	 T12, RS ballast –	 T8, IS ballast 

28 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
CSLs for Ballasts that Operate 

Two 4-foot MBP Lamps 

•	 DOE chose more efficient substitutes from comm

available products and tested them according to 

BEF test procedure. 

CSL Lamp Type Starting Method Input Power BEF 

CSL0/ 

Baseline T12 RS 63.5 1.359 80

CSL1/ 

Baseline T8 IS 60.4 1.450 85

CSL2 T8 IS 56.0 1.535 90CSL3 T8 IS 56.4 1.561 92

•	 DOE plans to conduct additional testing for the N

determine BEFs for those ballasts not tested usi

proposed active mode test procedure. 

29 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Issues for Discussion 

Issue 6: DOE requests comment on its selection of representative product classes, baseline ballasts, and lamp-and-ballast systems chosen to represent baseliincreasing efficiency. 

Issue 7: The highest CSL presented, which represenmost efficient tier of commercially available ballasts, i“max-tech” level that DOE determined for this prelimin

rulemaking. However, DOE presents additional resea

appendix 5D of the preliminary TSD to explore whethtechnologies used in products similar to ballasts can to improve the efficiency of ballasts currently on the m

DOE requests comments on the maximum technologfeasible ballast efficiency and its associated MSP. 

30 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Manufacturer Production Cost 

•	 Full production costs 

–	 Material and component costs derived from a tear

analysis 

–	 For ballasts that could not be torn down due to po

was developed by comparing retail prices to teardresults 

Manufacturer 

Production 

Cost 

Manufacturer 

Markups =
 Manu

Sellin

•	 Direct Material • Sales & marketing •	 Direct Labor • Research & development •	 Factory Overhead • Interest •	 Depreciation • Profit 

31 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Manufacturer Markups 

•	 DOE developed manufacturer markups using SEC fo

reports from publicly owned ballast manufacturing co

–	 Net Sales –	 Costs of Sales –	 Gross Profit 

•	 DOE verified the resulting markups with confidential p

manufacturers 

•	 The average manufacturer markup was found to be 1

Manufacturer 

Production 

Cost 

Manufacturer 

Markups =
 Manu

Sellin

•	 Direct material • Sales & marketing •	 Direct labor • Research & development •	 Factory overhead • Interest •	 Depreciation • Profit 

32 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Manufacturer Selling Price:

Two 4-foot MBP Lamps 

•	 The following table shows the MSP associated w

CSL in the two-lamp 4-foot MBP representative pclass 

CSL Lamp Type BEF BE MSP MSP D

CSL0/ 

Baseline T12 1.359 80.1% $10.26 Retail 

CSL1/ 

Baseline T8 1.450 85.4% $7.43 Te

CSL2 T8 1.535 90.5% $10.01 TeCSL3 T8 1.561 92.0% $8.93 Te

33 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Issues for Discussion 

•	 For the five representative product classes for w

teardowns were possible, DOE used retail price 

determine MPC. 

Issue 8: DOE used scaling techniques estimate the those ballasts that it did not tear down. DOE then calcMSPs by applying overhead and manufacturer markurequests comments on its estimates of manufacturer production costs, as well as DOE’s estimates for overthe manufacturer markup. 

34 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Issues for Discussion 

Issue 10: DOE requests comments on how safety requirements for system interconnects, safety requirelamp end-of-life protection, electromagnetic field requand hazardous material regulation could affect the effcommercially available ballasts. DOE also requests information on the cost of low and high efficiency ballare expected to be compliant with these regulations sDOE can assess how these requirements may affect calculations. 

35 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Scaling CSLs to Other Product 

Classes 

•	 DOE analyzed test data to determine the relation

between ballasts that 

–	 Operate different numbers of lamps –	 Have different starting methods –	 Have different ballast factors 

•	 DOE focused its effort on extensive test data obt

ballasts that operate 4-foot MBP lamps 

•	 DOE created scaling factors based on relationsh

observed among these ballasts to scale CSLs to 

representative product classes. 

36 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Scaling CSLs to Other Product 

Classes: Results 

•	 Number of Lamps 

–	 DOE found a strong correlation between BEF and 

lamp power operated by the ballast. 

–	 DOE found the equation that best represents this 

relationship to be:
 

Ballast Efficacy Factor = Coefficient*Total Rated Lamp 

•	 Starting Method 

–	 DOE found this average reduction to be 2.2% and 

applied this scaling factor when scaling to product with programmed start ballasts. 

•	 Ballast Factor 

–	 DOE found this average reduction to be 3.4% for 

factor and 1.0% for low ballast factor and thereforthese scaling factors as needed. 

37 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Issues for Discussion 

Issue 9: To determine CSLs for non-representative pclasses, DOE tested the BEF of certain ballasts in thoproduct classes and compared these values to the representative classes to create scaling relationshipsscaling relationships were used to create CSLs for thoproduct classes not directly analyzed. DOE requests comments on its scaling methodology and the proposfor fluorescent lamp ballasts in non-representative proclasses. 

38 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
2

34

Background and Legal Authority

5

3

45

6

Public Meeting Agenda 

39 | Building Technologies Program 

1

2 Market & Tech; Screening; Engineering 

Energy Use; Markup Analysis 

Overview 

Life-Cycle Cost and Payback Period Analysis 

National Impact Analysis 

Preliminary MIA; NOPR Analyses 

EERE-2007-BT-STD-0016 COMMENT 27
40 | Building Technologies Program 

Framework 

Document 

Preliminary 

Analysis 

NOPR Final Rule 

Market & Technology 

Screening Analysis 

Engineering Analysis 

Energy Use & End Use Load Characterization 

Shipments Analysis 

Markups for Equipment Price Determination 

Life-Cycle 

Cost and Payback Period Analysis 

Preliminary Manufacturer Impact Analysis 

Preliminary AnalysisRulemaking Stage 

EERE-2007-BT-STD-0016 COMMENT 27
Energy Use Characterization 

•	 Annual energy consumption (kWh) 

= system input power x annual operating hours 

•	 DOE developed measured input power for representa

and-ballast systems in the engineering analysis 

•	 DOE used normalized input power to compare new 

construction/retrofit and baseline systems on an “equ

basis, e.g., 

No. of 

Lamps 

Ballast 

Type CSL 

System 

Input 

Power 

(W) 

System 

Mean 

Lumens 

Change 

in Mean 

Lumen Output 

Ratio 

Normaliz

System 

Mean 

Lumen

2 F32T8 CSL0 63.5 5,110 0% 100% 5,110 

2 F32T8 CSL1 56.9 4,917 -4% 104% 5,110 

41 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Energy Use Characterization 

•	 DOE developed annual operating hours with data from 

surveys (LMC, CBECS, MECS, RECS) 

•	 DOE’s assumed annual oper ating hours capture varia

across census divisions and large States, building typlighting applications 

Sector 

Average Annual 

Operation 

(hrs/yr) 

Commercial 3,435 

Commercial (PS)* 2,405 

Industrial 4,795 

Residential 789 

* PS ballasts operating 4-foot MBP lamps on occupancy sensors. 

42 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Issues for Discussion 

Issue 11: DOE welcomes comments on the basis anassignment of end-use operating profiles for the ballacovered under this rulemaking. Issue 12: DOE invites comments on the use of lighticontrols in the commercial, industrial, and residential 

43 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
• DOE developed markups to relate manufacturer sellin

(MSP) to end-user ballast prices 

• DOE used distribution channel percentages, MSPs fr

the engineering analysis, and company balance shee

(SEC form 10-K) 

• DOE’s analysis yielded baseline and incremental mar

Markups Analysis 

BALLAST MANUFACTURER 

OEM FIXTURE 

MANUFACTURER 

ELECTRICAL WHOLESALER 

CONTRACTOR 

END-USER OF LIGHTING SYSTEM 

FIXTURE BALLASTS 

REPLACEMENT 

BALLASTS Via OEMs 

Baseline Incremental 

OEM Fixture Manufacturer 1.51 1.16 

Electrical Wholesaler 1.39 1.10 

Contractor 1.13 1.13 

Sales Tax 1.0712 

Estimated % of Shipments 63 Weighted Overall Baseline Markup 2.08 Weighted Overall Incremental Markup 1.37 

44 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Issues for Discussion 

Issue 13: DOE seeks comments on typical markupsas ballast pricing data that DOE could use to verify thmarkups it developed for the preliminary analysis. 

45 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
2

34

Background and Legal Authority

5

3

45

6

Public Meeting Agenda 

46 | Building Technologies Program 

1

2 Market & Tech; Screening; Engineering 

Energy Use; Markup Analysis 

Overview 

Life-Cycle Cost And Payback Period Analysis 

National Impact Analysis 

Preliminary MIA; NOPR Analyses 

EERE-2007-BT-STD-0016 COMMENT 27
47 | Building Technologies Program 

Framework 

Document 

Preliminary 

Analysis 

NOPR Final Rule 

Energy UseCharacterization 

Market and TechnologyAssessment 

ScreeningAnalysis 

EngineeringAnalysis 

Markups toDetermine EquipmentPrice 

Life-CycleCost and Payback Period Analysis 

ShipmentsAnalysis 

Preliminary Manufacturer Impact Analysis 

Preliminary AnalysisRulemaking Stage 

EERE-2007-BT-STD-0016 COMMENT 27
Life-Cycle Cost and

Payback Period Analysis 

•	 Economic evaluation from the end-user perspective 

•	 Life-cycle cost (LCC) equals end-user price plus the s

annual operating costs discounted to a particular bas

•	 Results are expressed as LCC savings (baseline min

standard level) 

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

this analysis 

Combine 

Changes 

in Costs 

L

First Cost (End-User Price + Installation Cost) 

Operating Expenses 

Convert to 

Present 

Value 

48 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
LCC-PBP Analysis Inputs 

•	 DOE derived electricity prices and projections from 20

form 861 data and EIA Annual Energy Outlook 2009 (

•	 DOE based installation costs on labor time and labor 

from the 2000 Ballast Rule, RS Means, and the U.S. 

Labor Statistics 

•	 DOE assumed ballast lifetimes of 49,054 hours (com

industrial) and 11,835 hours (residential) 

–	 translates to approximately 15 years (commercial), 10 y

(industrial), and 15 years (residential) 

–	 consistent with the 2000 Ballast Rule and available “life 

studies 

49 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
LCC-PBP Analysis Inputs 

• DOE calculated weighted-average discount rates from 

for cost of capital (commercial & industrial) and estiminterest (“finance cost”) to purchase residential produ

• commercial = 7.0% • industrial = 7.6% 

• residential = 5.6% 

50 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
LCC-PBP Analysis Results 

• Results generally show higher installed prices and lower operating 

higher efficiency levels, which typically results in positive LCC savi

Ballast Product Class Purchasing Event CSL LCC 

$

LCC 

Savings 

$

Installed 

Price 

$

O

2-Lamp RS & IS 

Operating 4-foot MBP and 

2-foot U-Shaped Lamps 

(Commercial, F32T8 Baseline) 

Replacement 

0 / 1 273.24 N/A 55.87 

2 264.06 9.18 59.42 3 263.48 9.76 57.98 

• Some product classes result in negative PBP values, reflecting red

both operating costs and installed costs at higher efficiency levels 

Ballast Product Class Purchasing Event CSL LCC 

$

LCC 

Savings 

$

Installed 

Price 

$

O

2-Lamp RS & IS 

Operating 4-foot MBP and 

2-foot U-Shaped Lamps 

(Commercial, F34T12 Baseline) 

Replacement 

0 308.59 N/A 68.41 1 273.24 35.35 55.87 2 264.06 44.53 59.42 3 263.48 45.11 57.98 

51 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
LCC-PBP Analysis Results 

• PBP values of “never” indicate higher operating costs
 

Ballast Product Class Purchasing Event CSL LCC 

$

LCC 

Savings 

$

Installed 

Price 

$

O

2-Lamp RS & IS 

Operating 4-foot MBP and 

2-foot U-Shaped Lamps 

(Residential, F34T12 Baseline) 

Replacement 

0 123.98 N/A 68.41 1 114.57 9.41 55.87 2 120.11 3.87 59.42 

52 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Issues for Discussion 

Issue 14: DOE’s approach for forecasting electricity does not include evaluating demand load profiles or aquantifying the potential impacts on peak demand for from changes in product efficiency. DOE requests comon alternate data sources, methods for quantifying chdemand charges, and their impacts on electricity price

53 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Issues for Discussion 

Issue 15: DOE acknowledges the general trend towasmaller fixtures and ballast enclosures, and assumed operating temperatures equal to or greater than those current ballast designs, with no extended life for enerefficient ballast designs. DOE welcomes additional cand data on operating lifetimes for energy efficient ba

54 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
2

34

Background and Legal Authority

5

3

45

6

Public Meeting Agenda 

55 | Building Technologies Program 

1

2 Market & Tech; Screening; Engineering 

Energy Use; Markup Analysis 

Overview 

Life-Cycle Cost and Payback Period Analysis 

National Impact Analysis 

Preliminary MIA; NOPR Analyses 

EERE-2007-BT-STD-0016 COMMENT 27
56 | Building Technologies Program 

Framework 

Document 

Preliminary 

Analysis 

NOPR Final Rule 

Energy UseCharacterization 

Market and TechnologyAssessment 

ScreeningAnalysis 

Engineering

Analysis 

Markups toDetermine EquipmentPrice 

Life-CycleCost and Payback Period Analysis 

ShipmentsAnalysis 

Preliminary Manufacturer Impact Analysis 

Preliminary AnalysisRulemaking Stage 

EERE-2007-BT-STD-0016 COMMENT 27
Shipments Analysis 

•	 DOE estimated historical ballast shipments using U.S

Current Industrial Reports (1990-2005) 

•	 DOE calculated installed stock based on estimated lif

•	 Finally, DOE developed base-case and standards-cas

shipment projections based on: 

–	 assumed purchasing events –	 replacement and floor space growth rates –	 existing and emerging technology scenarios, e.g., in wh

displace fluorescent 

57 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
 

Shipments Analysis Results 

•	 Replacement ballasts dominate shipments •	 In some product classes, “surges” of replacement ballasts m

shape of historical shipments growth 

–	 pattern repeated as subsequent generations are replaced 

•	 Cyclical shipment pattern also reflects assumed ballast lifet

failure distributions 

0 

10,000,000 20,000,000 30,000,000 40,000,000 50,000,000 60,000,000 70,000,000 80,000,000 90,000,000 

100,000,000 

2014 2019 2024 2029 2034 2039 2044 

Shipments 

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 

58 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Note on Historical Shipments 

•	 DOE observed striking growth in historical ballasts sh

not consistent with a mature market (450% in 15 year

–	 was the stock growing at the same rate as shipments? 

•	 DOE assumed the stock was growing at most 2% per 

– any shipments beyond that assumed to be due to retrof

140,000,000 120,000,000 100,000,000 

80,000,000 

Retrofit shipments 

60,000,000 "Regular" shipments 40,000,000 
20,000,000 


-


1992 1994 1996 1998 2000 2002 2004
 

59 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Issues for Discussion 

Issue 16: DOE’s assumed average ballast lifetimes sthat a majority of ballast failures occur later in the servlifetime. DOE seeks comment on the assumed averaglifetimes, as well as the distribution of failures around taverage values. In particular, DOE seeks comment on many years beyond average lifetimes that ballasts potremain in service. 

60 | Building Technologies Program 

EERE-2007-BT-STD-0016 COMMENT 27
Issues for Discussion 

Issue 17: DOE used data from the U.S. Census Bureestimate the total historical shipments of each ballast tanalyzed, which required disaggregating the Census dadjusting it to include estimated non-NEMA shipmentsseeks actual, disaggregated ballast and residential fixshipments data to help verify its shipments analysis. 

Sub-issue: DOE seeks comment on the relationship between historical shipments historical stock in the period 1992-2005. 

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Issues for Discussion 

Issue 18: DOE based future ballast shipment trends manufacturer interviews and market trends identified i2009 Lamps Rule; DOE assumes that these trends invarious regulatory and non-regulatory initiatives in the marketplace. DOE requests comments on the magnitutiming of its forecasted ballast shipment trends (e.g., rdeclining shipments, plateaus, etc.) as well as the impcurrent regulatory initiatives on future ballast shipmen

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National Impacts Analysis (NIA) 

•	 National energy savings (NES) and net present value 

calculated for period from 2014-2044 

Ene

Net P

($ 

Shipments Model 

National Energy Savings 

National Economic Impacts 

LCC Analysis Results and Other Inputs 

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EERE-2007-BT-STD-0016 COMMENT 27
2009$ (millions) 2008$ (millions) 500
 0
 -500
 

-1,000
 

NIA Results 

• Net present value rises (shipments) then falls (discou

– But varies between product class, CSL, scenario – Shown here: all ballasts, max tech, Existing/Shift scena– National energy savings: same pattern as operating cos

Net Present Value National Energy 

2,000 0.080 1,500 0.070 

0.060 1,000 

2014

2016

2018

2020

2022

2024

2026

2028

2030

2032

2034

2036

2038

2040

2042

2044

(quads) 0.050
 0.040
 0.030
 

0.020
 0.010 

Discounted Operating Cost Savings Discounted Installed Cost Increase 0.000 Total NPV 

2014

2016

2018

2020

2022

2024

2026

2028

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EERE-2007-BT-STD-0016 COMMENT 27
Issues for Discussion 

Issue 19: DOE acknowledges that there may be certa“external” benefits resulting from the improved efficienballasts that are not captured by the equipment’s userinclude both environmental and energy security-relateexternalities that are also not already reflected in enerprices, such as reduced emissions of greenhouse gasreduced use of fossil fuels for electricity generation. Dinvites comments on the nature and magnitude of sucbenefits. 

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EERE-2007-BT-STD-0016 COMMENT 27
Issues for Discussion 

Issue 20: For the NOPR, DOE will develop trial standlevels (TSLs) based on the candidate standard levels fluorescent lamp ballasts. DOE is considering several in developing the TSLs, including, but not limited to, mLCC, maximum NPV, and maximum technologically-feefficiency. These TSLs may include combinations of Cthe interaction between product classes such as ballaoperate 4-foot medium bipin and 8-foot single pin slimfluorescent lamps. From the list of TSLs developed, Dselect one as its proposed standard for the NOPR. DOcomment on the criteria it should use as the basis for of TSLs. 

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2

34

Background and Legal Authority

455

6

Public Meeting Agenda 

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1

23

Market & Tech; Screening; Engineering 

Energy Use; Markup Analysis 

Overview 

Life-Cycle Cost and Payback Period Analysis 

National Impact Analysis 

Preliminary MIA; NOPR Analyses 

EERE-2007-BT-STD-0016 COMMENT 27
68 | Building Technologies Program 

Framework 

Document 

Preliminary 

Analysis 

NOPR Final Rule 

Market & Technology 

Screening Analysis 

Engineering Analysis 

Energy Use & End Use Load Characterization 

Shipments Analysis 

Markups for Equipment Price Determination 

Life-Cycle 

Cost and Payback Period Analysis 

Preliminary Manufacturer Impact Analysis 

Preliminary AnalysisRulemaking Stage 

EERE-2007-BT-STD-0016 COMMENT 27
Manufacturer Impact Analysis 

Overview 

•	 Purpose 

–	 To identify the impacts of energy conservation standard

manufacturers 

•	 Phase 1 

–	 DOE creates an industry profile to characterize the indu

identify important issues that require consideration 

•	 Phase 2 

–	 DOE prepares an industry cash-flow model and an inte

questionnaire to guide subsequent discussions 

•	 Phase 3 

–	 DOE interviews manufacturers, and assesses the impa

standards both quantitatively (using the Government Re

Impact Model) and qualitatively (impacts on competitionmanufacturing capacity, employment, and regulatory bu

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Preliminary Manufacturer Impact

Analysis – Key Issues 

•	 Impacts on Profitability 

–	 Higher standards may decrease profit margins – espec

OEM distribution channel 

–	 Residential consumers may switch to other types of ligh

products due to higher prices, reducing sales 

•	 Product Conversion Costs/Diminishing Returns to Co

– Conversion costs may increase the price of the ballast 

consumer for, in most cases, a small increase in efficien

•	 Product Innovation 

–	 Resources available for the development of new produc

decrease because existing products may need to be re

•	 Regulatory Burden 

–	 Manufacturers prefer DOE to specify only a final date fo

production and not one for ballast sales as well 

–	 Hazardous material regulations –	 International standards 

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EERE-2007-BT-STD-0016 COMMENT 27
Issues for Discussion 

Issue 21: DOE requests comment on its identification issues and requests data and information from interesparties that can assist in evaluating the potential impamanufacturers. 

Issue 10: DOE recognizes and seeks to mitigate the 

overlapping effects on manufacturers of new or amenstandards and other regulatory actions affecting the sequipment. DOE will analyze and consider the impact manufacturers of multiple, product-specific regulatory in the NOPR. DOE invites comment on regulations apto ballast manufacturers that contribute to their cumulregulatory burden. 

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NOPR

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Analyses for Notice of Proposed Rulemaking (NOPR) 

Framework 

Document 

EnvironmenAssessmen

Life-Cycle Cost Subgroup Analysis 

Manufacturer Impact Analysis 

Utility Impact Analysis 

Employment Impact Analysis 

Revise 

Preliminary 

Analysis 

NOPR Preliminary Analysis Final Rule 

EERE-2007-BT-STD-0016 COMMENT 27
NOPR Analyses 

• LCC Subgroup Analysis 

– effects on various national consumer subgroups 

• Manufacturer Impact Analysis (continued) • Utility Impact Analysis 

– effects on generation capacity of utilities 

• Employment Impact Analysis 

– indirect effects on national employment 

• Environmental Assessment 

– effects on airborne pollutant emissions 

• Regulatory Impact Analysis 

– potential for non-regulatory approaches 

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Issues for Discussion 

Issue 22: DOE plans on monetizing the emission reddue to standards consistent with methods used in recstandards rulemakings. For example, in the case of C

most recent interagency estimates of the potential globenefits resulting from reduced CO2 emissions in 201

$4.7, $21.4, $35.1, and $64.9 per metric ton in 2007 dDOE invites comments on the approaches for monetizemission savings due to energy conservation standar

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DOE Seeks Comments on its Proposal

DOE Seeks Comments on its Proposal 

In all correspondence, include all of the following: 

– Energy Conservation Standards for Fluorescent Lamp 

– Docket Number EERE-2007

–BT

–STD

–0016 

– Regulatory Identification Number (RIN) 1904

–AB50 

Email: ballasts.rulemaking@ee.doe.gov 

Postal Mail: Courier: 


Ms. Brenda Edwards Ms. Brenda Edwards
 U.S. Department of Energy U.S. Department of EBuilding Technologies Program Building Technologies Mailstop EE-2J 950 L’Enfant Plaza, S

1000 Independence Avenue, S.W. Washington, DC 2002Washington, DC 20585-0121 Telephone: (202) 586

Comment period closes: May 10, 2010
 

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