1 | Building Technologies Program 

APPLIANCE STANDARDS PROGRAM 

Fluorescent Lamp Ballasts Test Procedure NOPR Public Meeting 

Linda GraveDepartment of Energy Energy Efficiency and FLB-2009-TP-0016@

April 26, 2010 

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Welcome 

• Introductions • Role of the Facilitator •	 Ground Rules (norms) 

- Listen as an ally - Use short, succinct statements/keep to the point - Hold sidebar conversations outside the room - One person speaks at a time (raise hand to be recogn

your name for the record)
 

- Set cell phones to silent/vibrate
 

• Housekeeping Items • Agenda Review • Opening Remarks 

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Agenda - Morning 

Test Procedure 9:00 – 9:20 am Welcome, Introductions, Opening Sta

9:20 – 10:00 am Test Procedure: Overview and Existin

10:00 – 10:45 am Test Procedure: Alternative Methods 10:45 – 11:00 am Break 

11:00 – 12:00 pm Test Procedure: Proposed Method 

12:00 – 1:00 pm Lunch 

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Agenda - Afternoon 

Energy Conservation Standard
 1:00 – 1:10 pm 1:10 – 1:45 pm 

1:45 – 2:30 pm 

2:30 – 2:45 pm 

2:45 – 3:00 pm 

3:00 – 3:30 pm 

3:30 – 4:00 pm 

4:00 – 4:15 pm 4:15 – 4:30 pm 

4:30 – 5:00 pm 

5:00 pm 

Introduction, Statute, and Context 

Market & Tech; Screening Analysis 

Engineering Analysis 

Energy Use & Markup Analysis 

Break 

Life-Cycle Cost And Payback Period A

National Impact Analysis 

Preliminary MIA 

NOPR Analyses 

Final Questions / Discussion Closing Remarks and Adjourn 

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Workshop participants are invited to provide summa

comments or statements on the test procedure and conservation standard at this time.

Purpose of Public Meeting 

1.	 Present DOE’s proposed test procedure and the ene

conservation standard preliminary analysis 

2.	 Seek comment from participants on the test procedu

and the energy conservation standard analysis 

3.	 Discuss the next steps for the rulemakings 

Workshop participants are invited to provide summacomments or statements on the test procedure and conservation standard at this time. 

h 

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Issues for Discussion 

Issue Box: DOE welcomes comments, data, and informconcerning its test procedure and standards preliminary analysis for fluorescent lamp ballasts. Throughout this presentation, issues that correspond to those raised in Dpublished material from the test procedure NOPR and standards preliminary analysis are raised for discussion boxes like this one. Nonetheless, comments are welcomany part of DOE’s analysis. 

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Summary of NOPR issues on which 

DOE seeks comment 

1.	 All aspects of the existing test procedure for active mode en

consumption. 

2.	 Appropriate usage of ANSI C82.2-2002, ANSI C82.1-2004 a

C82.11-2002. 

3.	 Method of measurement for ballasts capable of dimming lig

4.	 All aspects of the resistor-based BE correlated to BEF test 5.	 All aspects of the alternative methodologies DOE considere

others not mentioned. 

6.	 Ballasts that do not operate resistors. 7.	 BF variation due to lamp power variation and the impact of 

variation on BEF. 

8.	 Ballast factor binning. 9.	 Transfer equation methodology. 10. Transfer equation scaling. 11. Testing burden imposed by resistor-based BE correlated to 

method. 

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Presentation Overview 

1 Regulatory History & Rulemaking Process 3 Alternative Methods Considered 4 Proposal: Resistor-Based BE Correlated to 2 Existing Test Procedure 

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Regulatory History 

Energy Policy and 

Conservation Act, 1975 

National Appliance 

Energy Conservation 

Amendments of 1988 

54 FR 6076, 

February 7, 1989 

2000 Ballast Rule 

65 FR 56740 

September 19, 2000 

Established energy conservation standar

of test procedure development for consu

Added fluorescent lamp ballasts as cove

required development of a test procedur

efficiency standards and required DOE to standards twice. 

Established fluorescent lamp ballast test Appendix Q to Subpart B of 10 CFR 430

DOE published an energy conservation srule as the first revision of standards requstatute. 

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Regulatory History 

73 FR 3653, 

January 22, 2008 

74 FR 54445, 

October 22, 2009 

75 FR 14288 & 75 FR 

14319, March 24, 2010 

Energy Policy Act of 

2005 (EPACT 2005) 

Promulgated new energy conservation sballasts that operate “energy saver” lam

DOE published a framework document f

conservation standard under developme

DOE published a final rule addressing stmode test procedure for fluorescent lamp 

DOE published a NOPR addressing the procedure and a NOPM announcing ava

preliminary analysis for fluorescent lamp 

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Test Procedure Rulemaking Process 

Final 

Rule NOPR 

•	 NOPR published by DOE on March 24, 2010 •	 NOPR public meeting today April 26, 2010 •	 Comments on NOPR from interested parties 

–	 Transcript records oral comments from today’s public 

–	 Written comments (comment period closes June 7, 20

•	 DOE reviews and considers all comments •	 Final Rule Publication 

–	 Final Rule will be published before or on the same day 

final rule for the energy conservation standards rulema(June 2011) 

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Test Procedure Overview 

•	 Serves as the 7-year review of the active mode test •	 Updates ANSI references for existing test procedure •	 Proposes a new test procedure based on ballast effi

correlated to BEF for use with amended standards 

•	 Sets up certification requirements for existing standa

for amended standards 

3 years
 

TP Final Rule 

Publication 

Standard Final Rule 

Publication 

App. Q 

Compliance Date 

Standard 

Effective Date 

App. Q1 

Effective Date 

C

1 year 1 yea

June 2011 June 2012 June 2014 

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Issues for Comment 

Issue 1 from the Energy Conservation Standard Prelimin

Analysis: Manufacturers have observed non-compliant ball

were labeled as compliant in the marketplace. DOE request

comments on ways to enhance the certification and enforceprocedures for fluorescent lamp ballasts. 

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Presentation Overview 

1 Regulatory History & Rulemaking Process 3 Alternative Methods Considered 4 Proposal: Resistor-Based BE Correlated to 2 Existing Test Procedure 

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Existing Test Procedure 

• The existing test procedure calculates ballast efficacy 

based on ANSI C82.2-1984 

• Proposed amendments to the existing test procedure 

– Method of measurement ANSI C82.2-1984 → ANSI C82

–	 For ballast operating conditions, replace ANSI C82.1-19

ANSI C82.1-2004 for low-frequency ballasts ANSI C82.11-2002 for high-frequency ballasts 

Issue 2: DOE seeks comment on the updates and the appro

of ANSI C82.2-2002, ANSI C82.11 Consolidated-2002, and AC82.1-2004. 

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Drawbacks of Existing Test Procedure 

Lamp Manufacturing Variation 

–	 Reference lamp measured power can deviate up to 2.5

rated lamp power, impacting input power and BEF 

Measurement Variation 

–	 Testing facility ambient temperature variation –	 Lamps respond differently to the change between low- 

frequency operation, affecting BF measurement 

Limitations of BEF 

–	 BEF can not be used to directly compare ballasts that o

different wattage lamps or numbers of lamps 

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Efficiency Metric 

•	 Several commenters suggested changing the metric 

BEF to ballast efficiency (BE) or relative system effic

(RSE) 

• DOE will continue setting standards using BEF to be 

consistent with existing energy conservation standar42 USC 6295(g)(5), (g)(8) 

•	 DOE proposes to measure ballast efficiency using a 

resistor system and to correlate BE to BEF 

BE 

Correlations 

BEF 

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Issue for Comment 

Issue 1: DOE seeks comment on all aspects of the existintest procedure for active mode energy consumption found 10 CFR part 430, subpart B, appendix Q. 

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Presentation Overview 

1 Regulatory History & Rulemaking Process 3 Alternative Methods Considered 4 Proposal: Resistor-Based BE Correlated to 2 Existing Test Procedure 

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Alternatives – Improved Light Output Method 

•	 Much of the variation in the ANSI based, light output 

procedure can be reduced by further specifying somfactors: 

–	 Lamp measured power, rated wattage ± 1.0% –	 Testing facility ambient temperature, 25oC ± 0.5oC –	 Operate the reference lamp at constant voltage –	 Use electrode heating in the reference circuit for MBP, 

and RDC lamps 

–	 Use light output measurements for the determination o

factor for all ballasts and all lamps 

–	 For a given ballast, specify the type of lamp and numb

lamps to be operated during testing 

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Alternatives – Improved Light Output Method 

• Potential Advantages 

– Familiar procedure to industry – Ballast is operating its natural load – Reduced measurement variation due to tighter toleran

• Potential Disadvantages 

– Tighter tolerances may be burdensome – The effects of lamp manufacturing variation are not el

Issue 5: DOE seeks comment from interested parties who do 

support the proposed resistor-based ballast efficiency metho

improved light-output-based test procedure. 

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Alternatives – Lamp-based BE

correlated to BEF 

•	 The NEMA Ballast Technical Committee drafted a tes

procedure for the measurement of ballast efficiency (using a lamp and ballast system 

•	 Test Methodology 

1.	 Season the lamp for 12 hours 2.	 Stabilize the lamp and ballast system for no more tha

until steady-state is reached 

3.	 Take input and output power measurements simultan

• Convert BE to BEF using a transfer equation
 

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Alternatives – Lamp-based BE

correlated to BEF 

•	 Potential Advantages 

–	 Most accurately characterizes the real life operating co

a lamp and ballast system. 

–	 The ballast load accounts for the fact that a lamp is a d

load 

–	 Less sensitive to lamp power and environmental cond

the light output based method 

•	 Potential Disadvantages 

–	 Lamp to lamp variation may still be an issue 

Issue 5: DOE seeks comment from interested parties who do 

support the proposed resistor-based ballast efficiency metholamp-based BE correlated to BEF method. 

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Alternatives – Relative System Efficacy (RSE) 

•	 RSE uses the same test method as the existing test •	 RSE normalizes BEF for ballasts of different total rat

power 

•	 Advantages 

–	 RSE is potentially more comparable across different b

–	 Uses a familiar test procedure 

•	 Disadvantages 

–	 RSE is based on the same varied inputs as the existin

procedure for BEF 

Issue 5: DOE seeks comment from interested parties who do 

support the proposed resistor-based ballast efficiency metho

test procedure or any other procedure they believe is approp

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Presentation Overview 

1 Regulatory History & Rulemaking Process 3 Alternative Methods Considered 4 Proposal: Resistor-Based BE Correlated to 2 Existing Test Procedure 

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Proposed Test Method 

DOE proposes to measure ballast efficiency and correla

value to BEF. Input power and output power are me

while the ballast is operating a resistive load. 

Test Method 1.	 Prepare test setup and conditions 2.	 Make electrical measurements and calculate BE 3.	 Measure ballast factor to determine appropriate tran

equation 

4.	 Determine BEF from BE based on the transfer equa

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Resistor Load Bank Resistor Load Bank

Resistor Value Determination 

DOE determined resistor values using: 1.	 ANSI C78.81-2005 specifications 

–	 Electrode resistance for all lamps and all frequencies –	 Select lamp arc resistances for certain operating freq

2.	 Empirical Methods 

–	 Measured the lamp resistance during high-frequency 

when the lamp is creating the same amount of light afrequency operation 

Electrode Electrode 

Lamp Arc 

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Resistors - Ballast Factor 

•	 A lamp driven at different BFs exhibits different impe

•	 DOE used one resistor to test ballasts of all ballast f

•	 DOE developed correlations of BE to BEF specific to 

normal, and high BF bins to account for changes in impedance 

•	 Using one resistor is less expensive and less burden

than specifying multiple resistors specific to particula

Low BF Normal BF High BF

0.78 1.10 

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Issues for Comment 

Issue 7: DOE recognizes that in order to correlate measured 

BEF using DOE’s proposed test procedure, the BF of the temust be determined. DOE seeks comment on DOE’s approlight output-based measurement to determine ballast factor resulting variation in ballast factor due to lamp manufacturinvariations. DOE also requests comment on impact of this vaBF on the calculated BEF (according to the proposed test p

Issue 8: DOE seeks comment on the effect of DOE’s approa

a single resistor value for measuring ballasts of all ballast faparticular ballast) and correlating measured BE to correlated using transfer equations specific to ballast factor bins. 

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Test Measurements 

BE •	 Electrical measurements taken within 1 minute of en

–	 Input voltage, current, power –	 Output power 

•	 Universal voltage ballasts should be tested at the fol

input voltages: 

–	 277 volts for commercial ballasts –	 120 volts for residential and cold-temperature sign bal

BF •	 Measure BF according to ANSI C82.2-2002 with the 

amendments discussed in the improved light output method: 

–	 Clarifications to BF measurement –	 Operate the ballast with the most common wattage lam

maximum number of lamps a ballast is designed to op

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Transfer Equations - Overview 

•	 DOE tested BE and BEF for multiple ballasts in key p

classes 

•	 Found a linear relationship between BE and BEF •	 Scaled relationships to product classes not directly te

2-lamp, 32W MBP T8, Normal BF, IS/RS 

BEF
 

1.600 1.550 1.500 1.450 1.400 

Slope = 1.697 Slope = 1.697 

0.840 0.860	 0.880 0.900 0.920 BE 

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e o ree

1.624 1.0811.697 1.1291.723 1.147

Transfer Equations - Scaling 

•	 Using data from extensive 4-foot MBP and 8-foot SP 

ballast testing, DOE calculated relationships betweefor changes in 

- Starting Method - Ballast Factor - Number of Lamps - Total Rated Lamp Powe

•	 DOE used these relationships to establish slopes for 

classes without extensive test data 

Slopes for BE to BEF transfer equations 

Ballast 

and Lamp 

Type 

Starting 

Method 

Ballast 

Factor 

Number of Lamps 

One Two Three Four Five 

Four-Foot 

MBP, and Two-Foot 

U-Shaped 

IS and RS 

(not PS) 

High 3.233 1.624 1.081 0.812 0.65

Normal 3.378 1 .697 1.129 0.849 0.67

Low 3.430 1 .723 1.147 0.862 0.69

PS 

High 3.204 1.610 1.071 0.808 0.64

Normal 3.348 1.682 1.119 0.844 0.67

Low 3.400 1.708 1.137 0.857 0.68

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Issue for Comment 

Issue 9: DOE seeks comment on the transfer equations dev

convert BE to BEF. 

Issue 10: DOE seeks comment on the transfer equation sca

techniques (across number of lamps operated by a ballas

method, ballast factor, and total rated lamp power) used foclasses with slopes not based directly on test data. 

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Ballasts that do not operate resistors 

•	 Some ballasts do not operate resistors 

–	 These ballasts did operate lamps –	 Several different ballast types exhibited this issue 

•	 DOE proposes to use the light-output-based test pro

described in 10 CFR Part 430.2 Subpart B Appendix ballasts that do not operate resistors 

Issue 6: DOE seeks comment on why some ballasts do not ope

connected to a resistor load bank and DOE’s proposal to medirectly (as a light output measurement) for these ballasts. DOcomment on other approaches to test these ballasts. 

Issue 4: DOE seeks comment on the effectiveness of the propo

resistor-based BE test method and its expected improvemen

measurement variation. 

Issue 11: DOE seeks comment on its assessment of the anticip

burden imposed by the proposed test method. 

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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 B

– Docket Number EERE-2009-BT-TP-0016 

– Regulatory Identification Number (RIN) 1904

–AB99 

Email: FLB-2009-TP-0016@ee.doe.gov

Postal Mail: Courier: 


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

1000 Independence Avenue, S.W. Washington, DC 20024 Washington, DC 20585-0121 Telephone: (202) 586-29

Comment period closes: June 7, 2010
 

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