The MagneTek, Inc. Statement

for the April 18, 2000 DOE Public Hearing on

the Energy Conservation Program for Consumer Products:

Fluorescent Lamp Ballasts, Docket No. EE- -97-500

I am Michael Stein, Director of Global Standards for MagneTek , Inc., Vice-chairman of

the Lighting Systems Division of the National Electrical Manufacturers Association

(NEMA) and past Chairman of NEMA's Ballast Section. Today, I am here representing

MagneTek.

MagneTek believes that the current Proposed Rule satisfies all of the legal requirements

and adequately addresses all of the stakeholder concerns. MagneTek strongly supports

and requests that the Department of Energy adopts the proposed Ballast Rule as

submitted by the Joint Stakeholders and, as spelled out in the DOE NOPR in the Federal

Register notice of March 15, 2000.

MagneTek also supports the statement of the Ballast Section of NEMA presented earlier

in this hearing by Norm Grimshaw.

My comments today will focus more on the process than on the details of the analysis or

the final rule. I am in the unique position of having participated in the development of the

proposed law for ballast efficiency in 1987 and 1988, which was approval by Congress

and signed by President Reagan in June of 1988. I have also been involved in the ballast

rulemaking process since the aborted NOPR of March 4, 1994 through to the negotiations

of last October by the Joint Stakeholders.

In 1986 and 1987, the ballast industry worked with many states that were developing

ballast efficiency standards similar to the original one published in California in 1982.

The problem was that each state had their own variation of the original, and that would

have required special products or marking in many states for the ballast types that were

being regulated. The industry welcomed the suggestion of Howard Geller of the

American Council for an Energy Efficient Economy to have a U. S. requirement for

ballast efficiency modeled after the California requirements. The 1988 amendment to the

appliance law of 1987 was passed and it included the ballast efficiency requirements

discussed above and superceded state requirements. We did not fully understand,

however, the consequences of being part of the energy efficiency program for consumer

products until the NOPR was published in 1994.

The notorious eight appliance NOPR published March 4, 1994 failed because DOE and

its contractors developed the requirements and the supporting analyses without input

from the stakeholders, particularily the manufacturers of the products being regulated.

Page 1 04/11/00

EE-RM-97-500 COMMENT 99BB

The MagneTek, Inc. Statement 

for the April 18, 2000 DOE Public Hearing on 

the Energy Conservation Program for Consumer Products: 

Fluorescent Lamp Ballasts, Docket No. EE-RM-97-500 

I am Michael Stein, Director of Global Standards for MagneTek, Inc., Vice-chairman of 

the Lighting Systems Division of the National Electrical Manufacturers Association 

(NEMA) and past Chairman ofNEMA's Ballast Section. Today, I am here representing 

MagneTek. 

MagneTek believes that the current Proposed Rule satisfies all of the legal requirements 

and adequately addresses all of the stakeholder concerns. MagneTek strongly supports 

and requests that the Department of Energy adopts the proposed Ballast Rule as 

submitted by the Joint Stakeholders and, as spelled out in the DOE NOPR in the Federal 

Register notice of March 15, 2000. 

MagneTek also supports the statement of the Ballast Section ofNEMA presented earlier 

in this hearing by Norm Grimshaw. 

My comments today will focus more on the process than on the details of the analysis or 

the final rule. I am in the unique position of having participated in the development of the 

proposed law for ballast efficiency in 1987 and 1988, which was approval by Congress 

and signed by President Reagan in June of 1988. I have also been involved in the ballast 

rulemaking process since the aborted NOPR of March 4, 1994 through to the negotiations 

oflast October by the Joint Stakeholders. 

In 1986 and 1987, the ballast industry worked with many states that were developing 

ballast efficiency standards similar to the original one published in California in 1982. 

The problem was that each state had their own variation of the original, and that would 

have required special products or marking in many states for the ballast types that were 

being regulated. The industry welcomed the suggestion of Howard Geller of the 

American Council for an Energy Efficient Economy to have a U.S. requirement for 

ballast efficiency modeled after the California requirements. The 1988 amendment to the 

appliance law of 1987 was passed and it included the ballast efficiency requirements 

discussed above and superceded state requirements. We did not fully understand, 

however, the consequences of being part of the energy efficiency program for consumer 

products until the NOPR was published in 1994. 

The notorious eight appliance NOPR published March 4, 1994 failed because DOE and 

its contractors developed the requirements and the supporting analyses without input 

from the stakeholders, particularily the manufacturers of the products being regulated. 

Page 1 04/11100 

B 
NEMA and the ballast industry began the process to change the way the analyses are

done by working with DOE's contractor, LBNL, by the end of 1994. We also set the

stage for the 1996 Process Improvement Rule by working through Congress in 1995 to

get a moratorium on the consumer product rulemaking. Most of the revised analyses and

processes outlined in the Process Improvement Rule were tried on the ballast industry

first.

When published in 1999 in the Technical Support Document (TSD), the Life Cycle Costs

(LCC) analysis had differences in opinion between industry and DOE on some issues.

Some of these were a result of the ballast, a component of a lighting system, being

analyzed like a finished consumer product like a refrigerator. We understand that for

consumer products the end user price is important because the purchasing decision is

very price sensitive. Ballasts are a component of a lighting system, which is purchased by

a commercial or industrial consumer. They make purchasing decisions based on

functionally, energy consumption and return on investment which could be based on

simple payback or life cycle costs. Consumer ballast prices are not accessible and are

imbedded in the costs of the luminaire and the costs of the installation. This would also

be true for other component products like motors or power supplies that are only sold to

consumers as part of other finished products.

The LCC also tried to compare different lighting systems, particularily four foot T12 vs.

T8 lighting systems. The marketplace certainly does this and that is the reason for the

success of the electronic T8 ballasts. In the case of the ballast rule, some of the benefits

of the T8 system are attributable to the lamps and the luminaire. Although an attempt was

made to compensate for these factors they were done in error. DOE does not compare

different systems for consumer appliances using gas or electricity even though consumers

make this comparison.

My recommendation would be for different efficiency laws or regulations for commercial

and industrial products than for consumer products like appliances. Also the energy

efficiency of components such as ballasts, motors, and power supplies should be analyzed

as part of the complete system or product. For lighting efficiency the best measure for the

commercial and industrial user is unit power density (watts per square foot) as specified

in ASHRAE/IESNA 90.1. This allows the users flexibility to meet their lighting

requirements within a specific power budget.

The Manufacturers Impact Analysis (MIA) when it was published in 1999 met the ballast

industry's expectations. This may be because the DOE contractor on the MIA also

worked on the Process Improvement Rule, so they understood what was not done right in

the original TSD and earlier revisions. In the MIA, the ballast industry had input through

the entire process. DOE listened and considered the impact on the ballast industry

suppliers and others manufacturers in the lighting industry. The ballast rule MIA should

serve as a model for the MIA's for other product rulemakings.

Page 2 04/11/00

EE-RM-97-500 COMMENT 99BB

NEMA and the ballast industry began the process to change the way the analyses are 

done by working with DOE's contractor, LBNL, by the end of 1994. We also set the 

stage for the 1996 Process Improvement Rule by working through Congress in 1995 to 

get a moratorium on the consumer product rulemaking. Most of the revised analyses and 

processes outlined in the Process Improvement Rule were tried on the ballast industry 

first. 

When published in 1999 in the Technical Support Document (TSD), the Life Cycle Costs 

(LCC) analysis had differences in opinion between industry and DOE on some issues. 

Some of these were a result of the ballast, a component of a lighting system, being 

analyzed like a finished consumer product like a refrigerator. We understand that for 

consumer products the end user price is important because the purchasing decision is 

very price sensitive. Ballasts are a component of a lighting system, which is purchased by 

a commercial or industrial consumer. They make purchasing decisions based on 

functionally, energy consumption and return on investment which could be based on 

simple payback or life cycle costs. Consumer ballast prices are not accessible and are 

imbedded in the costs of the luminaire and the costs of the installation. This would also 

be true for other component products like motors or power supplies that are only sold to 

consumers as part of other finished products. 

The LCC also tried to compare different lighting systems, particularily four foot T12 vs. 

T8 lighting systems. The marketplace certainly does this and that is the reason for the 

success of the electronic T8 ballasts. In the case of the ballast rule, some of the benefits 

of the T8 system are attributable to the lamps and the luminaire. Although an attempt was 

made to compensate for these factors they were done in error. DOE does not compare 

different systems for consumer appliances using gas or electricity even though consumers 

make this comparison. 

My recommendation would be for different efficiency laws or regulations for commercial 

and industrial products than for consumer products like appliances. Also the energy 

efficiency of components such as ballasts, motors, and power supplies should be analyzed 

as part of the complete system or product. For lighting efficiency the best measure for the 

commercial and industrial user is unit power density (watts per square foot) as specified 

in ASHRAE/IESNA 90.1. This allows the users flexibility to meet their lighting 

requirements within a specific power budget. 

The Manufacturers Impact Analysis (MIA) when it was published in 1999 met the ballast 

industry's expectations. This may be because the DOE contractor on the MIA also 

worked on the Process Improvement Rule, so they understood what was not done right in 

the original TSD and earlier revisions. In the MIA, the ballast industry had input through 

the entire process. DOE listened and considered the impact on the ballast industry 

suppliers and others manufacturers in the lighting industry. The ballast rule MIA should 

serve as a model for the MIA's for other product rulemakings. 

Page 2 04/11100 
The development of the range of electricity prices was done more with 20/20 hindsight

rather than 20/20 foresight. We are rapidly becoming deregulated in the electric utility

industry. The DOE EIA estimates for electricity prices barely considered this

deregulation. Variable electricity prices were used for sensitivity analysis, but this was

based on history rather than future expectations. Further DOE did not recognize the fact

that the magnetic ballast purchaser had a lower average electricity price than the average

electronic ballast purchaser. As the electric utility industry deregulates more in the future,

DOE must rethink how it forecasts electricity prices for future rulemakings.

These comments have been made as an overview of the process and MagneTek is not

requesting that any changes be made to any of the analyses. We support the proposed rule

and urge its adoption as a final rule.

Page 3 04/11/00

EE-RM-97-500 COMMENT 99BB

The development of the range of electricity prices was done more with 20/20 hindsight 

rather than 20/20 foresight. We are rapidly becoming deregulated in the electric utility 

industry. The DOE EIA estimates for electricity prices barely considered this 

deregulation. Variable electricity prices were used for sensitivity analysis, but this was 

based on history rather than future expectations. Further DOE did not recognize the fact 

that the magnetic ballast purchaser had a lower average electricity price than the average 

electronic ballast purchaser. As the electric utility industry deregulates more in the future, 

DOE must rethink how it forecasts electricity prices for future rulemakings. 

These comments have been made as an overview of the process and MagneTek is not 

requesting that any changes be made to any of the analyses. We support the proposed rule 

and urge its adoption as a final rule. 

Page 3 04/11/00