Energy Conservation Program: Energy Conservation Standards for Fluorescent Lamp Ballasts
Federal RegisterApr 11, 2011
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DEPARTMENT OF ENERGY
10 CFR Part 430
[Docket Number EE-2007-BT-STD-0016]
RIN 1904-AB50
Energy Conservation Program: Energy Conservation Standards for Fluorescent Lamp Ballasts
AGENCY:
Office of Energy Efficiency and Renewable Energy, Department of Energy.
ACTION:
Notice of proposed rulemaking (NOPR) and public meeting.
SUMMARY:
The Energy Policy and Conservation Act (EPCA) prescribes energy conservation standards for various consumer products and commercial and industrial equipment, including fluorescent lamp ballasts (ballasts). EPCA also requires the U.S. Department of Energy (DOE) to determine if amended standards for ballasts are technologically feasible and economically justified, and would save a significant amount of energy, and to determine whether to adopt standards for additional ballasts not already covered by Federal standards. In this NOPR, DOE proposes amended energy conservation standards for those ballasts currently subject to standards, and new standards for certain ballasts not currently covered by standards. This NOPR also announces a public meeting to receive comment on these proposed standards and associated analyses and results.
DATES:
DOE will hold a public meeting on May 10, 2011, from 9 a.m. to 4 p.m., in Washington, DC. The meeting will also be broadcast as a webinar. See section 0, “Public Participation,” for webinar registration information, participant instructions, and information about the capabilities available to webinar participants.
DOE will accept comments, data, and information regarding this notice of proposed rulemaking (NOPR) before and after the public meeting, but no later than June 10, 2011.
See
section 0, “Public Participation,” of this NOPR for details.
ADDRESSES:
The public meeting will be held at the U.S. Department of Energy, Forrestal Building, Room GE-086, 1000 Independence Avenue, SW., Washington, DC 20585. To attend, please notify Ms. Brenda Edwards at (202) 586-2945. Please note that foreign nationals visiting DOE Headquarters are subject to advance security screening procedures. Any foreign national wishing to participate in the meeting should advise DOE as soon as possible by contacting Ms. Brenda Edwards at (202) 586-2945 to initiate the necessary procedures.
Any comments submitted must identify the NOPR for Energy Conservation Standards for Fluorescent Lamp Ballasts and provide docket number EE-2007-BT-STD-0016 and/or regulatory information number (RIN) number 1904-AB50. Comments may be submitted using any of the following methods:
1.
Federal eRulemaking Portal: http://www.regulations.gov.
Follow the instructions for submitting comments.
2.
E-mail: ballasts.rulemaking@ee.doe.gov.
Include the docket number and/or RIN in the subject line of the message.
3.
Mail:
Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, Mailstop EE-2J, 1000 Independence Avenue, SW., Washington, DC 20585-0121. If possible, please submit all items on a CD. It is not necessary to include printed copies.
4.
Hand Delivery/Courier:
Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, 950 L'Enfant Plaza, SW., Suite 600, Washington, DC 20024. Telephone: (202) 586-2945. If possible, please submit all items on a CD. It is not necessary to include printed copies.
Written comments regarding the burden-hour estimates or other aspects of the collection-of-information requirements contained in this proposed rule may be submitted to Office of Energy Efficiency and Renewable Energy through the methods listed above and by e-mail to
Christine_J._Kymn@omb.eop.gov.
For detailed instructions on submitting comments and additional information on the rulemaking process,
see
section 0 of this document (Public Participation).
Docket:
The docket is available for review at
http://www.regulations.gov,
including
Federal Register
notices, framework documents, public meeting attendee lists and transcripts, comments, and other supporting documents/materials. All documents in the docket are listed in the
http://www.regulations.gov
index. Not all documents listed in the index may be publicly available, such as information that is exempt from public disclosure.
A link to the docket web page can be found at:
http://www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_ballasts.html.
This web page will contain a link to the docket for this notice on regulations.gov. The regulations.gov web page contains simple instructions on how to access all documents, including public comments, in the docket.
See
section 0 for further information on how to submit comments through
http://www.regulations.gov.
For further information on how to submit or review public comments or participate in the public meeting, contact Ms. Brenda Edwards at (202) 586-2945 or e-mail:
Brenda.Edwards@ee.doe.gov.
FOR FURTHER INFORMATION CONTACT:
Dr. Tina Kaarsberg, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue, SW., Washington, DC 20585-0121. Telephone: (202) 287-1393. E-mail:
Tina.Kaarsberg@ee.doe.gov.
Ms. Elizabeth Kohl, U.S. Department of Energy, Office of the General Counsel, GC-71, 1000 Independence Avenue, SW., Washington, DC 20585-0121. Telephone: (202) 586-7796. E-mail:
Elizabeth.Kohl@hq.doe.gov.
SUPPLEMENTARY INFORMATION:
I. Summary of the Proposed Rule
II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for Fluorescent Lamp Ballasts
3. Compliance Date
III. Issues Affecting the Scope of This Rulemaking
A. Additional Fluorescent Lamp Ballasts for Which DOE Is Proposing Standards
1. Scope of EPCA Requirement That DOE Consider Standards for Additional Ballasts
2. Identification of the Additional Ballasts for Which DOE Proposes Standards
3. Summary of Fluorescent Lamp Ballasts to Which DOE Proposes To Extend Coverage
B. Off Mode and Standby Mode Energy Consumption Standards
IV. General Discussion
A. Test Procedures
B. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
C. Energy Savings
1. Determination of Savings
2. Significance of Savings
D. Economic Justification
1. Specific Criteria
2. Rebuttable Presumption
V. Methodology and Discussion
A. Market and Technology Assessment
1. General
2. Product Classes
3. Technology Options
B. Screening Analysis
C. Engineering Analysis
1. Approach
2. Representative Product Classes
3. Baseline Ballasts
4. Selection of More Efficient Ballasts
5. Efficiency Levels
6. Price Analysis
7. Results
8. Scaling to Product Classes Not Analyzed
D. Markups To Determine Product Price
1. Distribution Channels
2. Estimation of Markups
3. Summary of Markups
E. Energy Use Analysis
F. Life-Cycle Cost and Payback Period Analyses
1. Product Cost
2. Installation Cost
3. Annual Energy Use
4. Energy Prices
5. Energy Price Projections
6. Replacement and Disposal Costs
7. Product Lifetime
8. Discount Rates
9. Compliance Date of Standards
10. Ballast Purchasing Events
G. National Impact Analysis—National Energy Savings and Net Present Value Analysis
1. Annual Energy Consumption per Unit
2. Shipments
3. Site-to-Source Energy Conversion
H. Consumer Sub-Group Analysis
I. Manufacturer Impact Analysis
1. Overview
2. GRIM Analysis
3. Discussion of Comments
4. Manufacturer Interviews
J. Employment Impact Analysis
K. Utility Impact Analysis
L. Environmental Assessment
M. Monetizing Carbon Dioxide and Other Emissions Impacts
1. Social Cost of Carbon
2. Valuation of Other Emissions Reductions
VI. Analytical Results
A. Trial Standard Levels
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
2. Economic Impacts on Manufacturers
3. National Impact Analysis
4. Impact on Utility or Performance of Products
5. Impact of Any Lessening of Competition
6. Need of the Nation To Conserve Energy
C. Proposed Standards
1. Trial Standard Level 3
D. Backsliding
VII. Procedural Issues and Regulatory Review
A. Review Under Executive Order 12866
B. Review Under the Regulatory Flexibility Act
1. Description and Estimated Number of Small Entities Regulated
2. Description and Estimate of Compliance Requirements
3. Duplication, Overlap, and Conflict With Other Rules and Regulations
4. Significant Alternatives to the Proposed Rule
C. Review Under the Paperwork Reduction Act
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under the Information Quality Bulletin for Peer Review
VIII. Public Participation
A. Attendance at Public Meeting
B. Procedure for Submitting Prepared General Statements for Distribution
C. Conduct of Public Meeting
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
IX. Approval of the Office of the Secretary
I. Summary of the Proposed Rule
The Energy Policy and Conservation Act (42 U.S.C. 6291
et seq.;
EPCA or the Act), as amended, requires that any new or amended energy conservation standard DOE prescribes for certain products, such as fluorescent lamp ballasts (ballasts), be designed to achieve the maximum improvement in energy efficiency that is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, the new or amended standard must result in a significant conservation of energy. (42 U.S.C. 6295(o)(3)(B)) In accordance with these and other statutory provisions discussed in this notice, DOE proposes new and amended energy conservation standards for ballasts. The proposed standards are shown in Table I.1. These proposed standards, if adopted, would apply to all products listed in Table I.1 and manufactured in, or imported into, the United States on or after June 30, 2014.
Table I.1—Proposed Standards
Product class *
Proposed standard **
Percent improvement
over current standard or baseline +
IS and RS ballasts that operate:
4-foot MBP lamps
1.32 * Ln (total lamp arc power) + 86.11
1.9 to 13.4.
8-foot slimline lamps
PS ballasts that operate:
4-foot MBP lamps
1.79 * ln (total lamp arc power) + 83.33
9.3 to 12.6.
4-foot MiniBP SO lamps
4-foot MiniBP HO lamps
IS and RS ballasts that operate 8-foot HO lamps
1.49 * ln (total lamp arc power) + 84.32
34.7.
PS ballasts that operate 8-foot HO lamps
1.46 * ln (total lamp arc power) + 82.63
32.0.
Ballasts that operate 8-foot HO lamps in cold temperature outdoor signs
1.49 * ln (total lamp arc power) + 81.34
31.7.
* IS = instant start; RS = rapid start; MBP = medium bipin; PS = programmed start; SO = standard output; HO = high output.
** The proposed standards are based on an equation that is a function of the natural logarithm (ln) of the total lamp arc power operated by the ballast.
+
Range is applicable to the representative ballasts analyzed.
DOE's analyses indicate that the proposed standards would save a significant amount of energy—an estimated 3.7-6.3 quads of cumulative energy over 30 years (2014 through 2043). This amount is equivalent to the annual energy use of approximately 18.5 million to 31.5 million U.S. homes.
The cumulative national net present value (NPV) of total consumer costs and savings of the proposed standards for products shipped in 2014-2043, in 2009$, ranges from $8.1 billion (at a 7-percent discount rate) to $24.7 billion (at a 3-percent discount rate).
1
The NPV
is the estimated total value of future operating-cost savings during the analysis period, minus the estimated increased product costs, discounted to 2011. The industry net present value (INPV) is the sum of the discounted cash flows to the industry from the base year through the end of the analysis period (2014 to 2043). Using a real discount rate of 7.4 percent, DOE estimates that INPV for manufacturers of all fluorescent lamp ballasts in the base case ranges from $853 million to $1.24 billion in 2009$. If DOE adopts the proposed standards, it expects that manufacturer INPV may change from a loss of 7.7 percent to a loss of 34.7 percent, or approximately a loss of $95.3 million to a loss of $296.2 million. Using a 7-percent discount rate, the NPV of consumer costs and savings from today's proposed standards would amount to 27-119 times the total estimated industry losses. Using a 3-percent discount rate, the NPV would amount to 53-246 times the total estimated industry losses.
1
DOE uses discount rates of 7 and 3 percent based on guidance from the Office of Management and Budget (OMB Circular A-4, section E,
September 17, 2003). See section IV.G for further information.
The projected economic impacts of the proposed standards on individual consumers are generally positive. For example, the estimated average life-cycle cost (LCC) savings are approximately $11-$25 for 2-lamp IS and RS ballasts that operate common 4-foot T8 lamps in the commercial sector.
2
When more than one baseline existed for a representative ballast type, DOE performed separate LCC analyses comparing replacement lamp-and-ballast systems to each baseline. Because T8 systems are generally more efficient than T12 systems, the incremental energy savings in a T8 baseline case are considerably lower than when comparing the same efficiency levels to a T12 baseline. It was only in these dual-baseline (
i.e.,
T12 and T8) cases that DOE observed negative economic impacts at the proposed standard levels, as the incremental energy and operating cost savings in the T8 baseline cases were not sufficient to offset the increased prices of more efficient replacements.
2
The LCC is the total consumer expense over the life of a product, consisting of purchase and installation costs plus operating costs (expenses for energy use, maintenance and repair). To compute the operating costs, DOE discounts future operating costs to the time of purchase and sums them over the lifetime of the product.
In addition, the proposed standards would have significant environmental benefits. The energy saved is in the form of electricity, and DOE expects the energy savings from the proposed standards to eliminate the need for approximately 4.37-7.22 gigawatts (GW) of generating capacity by 2043. The savings would result in cumulative (undiscounted) greenhouse gas emission reductions of approximately 40-121 million metric tons (MMt)
3
of carbon dioxide (CO
2
) between 2014 and 2043. During this period, the proposed standards would result in undiscounted emissions reductions of approximately 32-44 thousand tons of nitrogen oxides (NO
X
) and 0.59-1.67 tons of mercury (Hg).
4
DOE estimates the net present monetary value of the CO
2
emissions reduction is between $0.18 and $6.67 billion, expressed in 2009$ and discounted to 2011, based on a range of discount rates discussed in section 0. DOE also estimates the net present monetary value of the NO
X
emissions reduction, expressed in 2009$ and discounted to 2011, is between $19 and $35 million at a 7-percent discount rate, and between $42 and $65 million at a 3-percent discount rate.
5
3
A metric ton is equivalent to 1.1 short tons. Results for NO
X
and Hg are presented in short tons.
4
DOE calculates emissions reductions relative to the most recent version of the Annual Energy Outlook (AEO) Reference case forecast. As noted in chapter 16 of the TSD, this forecast accounts for regulatory emissions reductions through 2008, including the Clean Air Interstate Rule (CAIR, 70 FR 25162 (May 12, 2005)), but not the Clean Air Mercury Rule (CAMR, 70 FR 28606 (May 18, 2005)). Subsequent regulations, including the proposed CAIR replacement rule and the proposed Clean Air Transport Rule (75 FR 45210 (August 2, 2010)), do not appear in the forecast.
5
DOE is aware of multiple agency efforts to determine the appropriate range of values used in evaluating the potential economic benefits of reduced Hg emissions. DOE has decided to await further guidance regarding consistent valuation and reporting of Hg emissions before it once again monetizes Hg in its rulemakings.
The benefits and costs of today's proposed standards, for products sold in 2014-2043, can also be expressed in terms of annualized values. The annualized monetary values shown in Table I.2 are the sum of (1) the annualized national economic value, expressed in 2009$, of the benefits from consumer operation of products that meet the proposed standards (consisting primarily of operating cost savings from using less energy, minus increases in equipment purchase and installation costs, which is another way of representing consumer NPV), and (2) the annualized monetary value of the benefits of emission reductions, including CO
2
emission reductions.
6
The value of the CO
2
reductions, otherwise known as the Social Cost of Carbon (SCC), is calculated using a range of values per metric ton of CO
2
developed by a recent interagency process. The monetary costs and benefits of emissions reductions are reported in 2009$ to permit comparisons with the other costs and benefits in the same dollar units. The derivation of the SCC values is discussed in section 0.
6
DOE used a two-step calculation process to convert the time-series of costs and benefits into annualized values. First, DOE calculated a present value in the same year used for discounting the NPV of total consumer costs and savings. To calculate the present value, DOE used discount rates of three and seven percent for all costs and benefits except for the value of CO
2
reductions. For the latter, DOE used a range of discount rates, as shown in Table I.2. From the present value, DOE then calculated the corresponding time-series of fixed annual payments over a 30-year period starting in the same year used for discounting the NPV of total consumer costs and savings. The fixed annual payment is the annualized value. Although DOE calculated annualized values, this does not imply that the time-series of cost and benefits from which the annualized values were determined would be a steady stream of payments.
Although combining the values of operating savings and CO
2
emission reductions provides a useful perspective, two issues should be considered. First, the national operating savings are domestic U.S. consumer monetary savings that occur as a result of market transactions while the value of CO
2
reductions is based on a global value. Second, the assessments of operating cost savings and CO
2
savings are performed with different methods that use quite different time frames for analysis. The national operating cost savings is measured for the lifetime of ballasts shipped between 2014 and 2043. The SCC values, on the other hand, reflect the present value of all future climate-related impacts resulting from the emission of one ton of CO
2
in each year. These impacts go well beyond 2100.
Using a 7-percent discount rate and the SCC value of $21.40/ton in 2010 (in 2007$), which was derived using a 3-percent discount rate (see note below Table I.2), the cost of the standards proposed in today's rule is $276 million-437 million per year in increased equipment costs, while the annualized benefits are $931 million-1,359 million per year in reduced equipment operating costs, $44 million-111 million in CO
2
reductions, and $1.6 million-2.8 million in reduced NO
X
emissions. In this case, the net benefit amounts to $701 million-1,036 million per year. Using a 3-percent discount rate and the SCC value of $21.40/ton in 2010 (in 2007$), the cost of the standards proposed in today's rule is $311 million-539 million per year in increased equipment costs, while the benefits are $1,153 million-1,800 million per year in reduced operating costs, $44 million-111 million in CO
2
reductions, and $2.1 million-3.3 million in reduced NO
X
emissions. At a 3-
percent discount rate, the net benefit amounts to $887 million-1,376 million per year.
Table I.2—Annualized Benefits and Costs of Proposed Standards for Ballasts for 2014-2043 Analysis Period
Discount rate
Monetized
million 2009$/year
Primary estimate
Low estimate (emerging technologies, roll-up
scenario)
High estimate (existing technologies, shift
scenario)
Benefits
Operating Cost Savings
7%
3%
1,145
1,477
931
1,153
1,359.
1,800.
CO
2
Reduction at $4.7/t *
5%
20
12
28.
CO
2
Reduction at $21.4/t *
3%
78
44
111.
CO
2
Reduction at $35.1/t *
2.5%
122
68
177.
CO
2
Reduction at $64.9/t *
3%
237
134
340.
NO
X
Reduction at $2,519/t *
7%
3%
2.2
2.7
1.6
2.1
2.8.
3.3.
Total (Operating Cost Savings, CO
2
Reduction and NO
x
Reduction)†
7% plus CO
2
range
7%
3%
3% plus CO
2
range
1,167 to 1,384
1,225
1,557
1,499 to 1,716
945 to 1,067
977
1,199
1,167 to 1,289
1,389 to 1,702.
1,473.
1,915.
1,831 to 2,144.
Costs
Incremental Product Costs
7%
3%
357
425
276
311
437.
539.
Net Benefits/Costs
Total (Operating Cost Savings, CO
2
Reduction and NO
x
Reduction, Minus Incremental Product Costs)†
7% plus CO
2
range
7%
3%
3% plus CO
2
range
810 to 1,027
868
1,131
1,074 to 1,291
669 to 790
701
887
856 to 977
952 to 1,264.
1,036.
1,376.
1,292 to 1,604.
* The CO
2
values represent global monetized values (in 2007$) of the social cost of CO
2
emissions in 2010 under several scenarios. The values of $4.7, $21.4, and $35.1 per ton are the averages of SCC distributions calculated using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $64.9 per ton represents the 95th percentile of the SCC distribution calculated using a 3-percent discount rate. The value for NO
x
(in 2009$) is the average of the low and high values used in DOE's analysis.
† Total Benefits for both the 3-percent and 7-percent cases are derived using the SCC value calculated at a 3-percent discount rate, which is $21.4/ton in 2010 (in 2007$). In the rows labeled as “7% plus CO
2
range” and “3% plus CO
2
range,” the operating cost and NO
x
benefits are calculated using the labeled discount rate, and those values are added to the full range of CO
2
values with the $4.7/ton value at the low end, and the $64.9/ton value at the high end.
DOE has tentatively concluded that the proposed standards represent the maximum improvement in energy efficiency that is technologically feasible and economically justified, and would result in the significant conservation of energy. DOE further notes that products achieving these standard levels are already commercially available for all product classes covered by today's proposal. Ballasts are commercially available at the proposed standard level for all representative ballast types. Based on the analyses described above, DOE found the benefits of the proposed standards to the nation (energy savings, positive NPV of consumer benefits, consumer LCC savings, and emission reductions) outweigh the burdens (loss of INPV for manufacturers and LCC increases for some consumers).
Based on consideration of the public comments DOE receives in response to this notice and related information collected and analyzed during the course of this rulemaking effort, DOE may adopt energy use levels presented in this notice that are either higher or lower than the proposed standards, or some combination of level(s) that incorporate the proposed standards in part.
II. Introduction
The following section briefly discusses the statutory authority underlying today's proposal as well as some of the relevant historical background related to the establishment of standards for fluorescent lamp ballasts.
A. Authority
Title III of EPCA sets forth a variety of provisions designed to improve energy efficiency. Part B of Title III (42 U.S.C. 6291-6309) provides for the Energy Conservation Program for Consumer Products Other than Automobiles.
7
EPCA covers consumer products and certain commercial equipment (referred to collectively hereafter as “covered products”), including the types of fluorescent lamp ballasts that are the subject of this rulemaking.
8
(42 U.S.C. 6292(a)(13)) EPCA prescribes energy conservation standards for these products (42 U.S.C.
6295(g)(5), (6), and (8)), and also requires that DOE conduct two rulemakings to determine (1) whether EPCA's original standards for ballasts in 42 U.S.C. 6295(g)(5) should be amended, including whether such standards should apply to the ballasts in 42 U.S.C. 6295(g)(6) and other fluorescent ballasts; and (2) whether the standards then in effect for ballasts should be amended, including whether such standards should apply to additional ballasts. (42 U.S.C. 6295(g)(7)(A)-(B)) As explained in further detail in section II.C, “Background,” this rulemaking is the second of the two required rulemakings. In this rulemaking, DOE considers whether to amend the existing standards for ballasts, including those in 42 U.S.C. 6295(g)(8), and also considers standards for additional ballasts. See section 0 for a discussion of additional fluorescent lamp ballasts DOE considered for coverage. In addition, under 42 U.S.C. 6295(m), DOE must periodically review established energy conservation standards for covered products.
7
This part was titled Part B in EPCA, but was subsequently codified as Part A in the U.S. Code for editorial reasons.
8
Ballasts are used primarily in the commercial and industrial sectors. While Part B includes a range of consumer products that are used primarily in the residential sector, such as refrigerators, dishwashers, and clothes washers, Part B also includes several products used primarily in the commercial sector, including fluorescent lamp ballasts. (Part C of Title III—Certain Industrial Equipment, codified in the U.S. Code as Part A-1, concerns products used primarily in the commercial and industrial sectors, such as electric motors and pumps, commercial refrigeration equipment, and packaged terminal air conditioners and heat pumps.)
Under EPCA, DOE's energy conservation program for covered products consists essentially of four parts: (1) Testing, (2) labeling, (3) the establishment of Federal energy conservation standards, and (4) certification and enforcement procedures. The Federal Trade Commission (FTC) is primarily responsible for labeling, and DOE implements the remainder of the program. EPCA authorizes DOE, subject to certain criteria and conditions, to develop test procedures to measure the energy efficiency, energy use, or estimated annual operating cost of each covered product. (42 U.S.C. 6293) Manufacturers of covered products must use the prescribed DOE test procedure as the basis for certifying to DOE that their products comply with the applicable energy conservation standards adopted under EPCA and when making representations to the public regarding the energy use or efficiency of those products. (42 U.S.C. 6293(c) and 6295(s)) Similarly, DOE must use these test procedures to determine whether the products comply with standards adopted under EPCA.
Id.
The test procedures for ballasts currently appear at title 10, Code of Federal Regulations (CFR), part 430, subpart B, appendix Q.
EPCA provides criteria for prescribing amended standards for covered products. As indicated above, any amended standard for a covered product must be designed to achieve the maximum improvement in energy efficiency that is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, EPCA precludes DOE from adopting any standard that would not result in a significant conservation of energy. (42 U.S.C. 6295(o)(3)) Moreover, DOE may not prescribe a standard: (1) For certain products, including ballasts, if no test procedure has been established for the product, or (2) if DOE determines by rule that the proposed standard is not technologically feasible or economically justified. (42 U.S.C. 6295(o)(3)(A)-(B)) EPCA also provides that, in determining whether a proposed standard is economically justified, DOE must determine whether the benefits of the standard exceed its burdens. (42 U.S.C. 6295(o)(2)(B)(i)) DOE must do so after receiving comments on the proposed standard, and by considering, to the greatest extent practicable, the following seven factors:
1. The economic impact of the standard on manufacturers and consumers of the products subject to the standard;
2. The savings in operating costs throughout the estimated average life of the covered products in the type (or class) compared to any increase in the price, initial charges, or maintenance expenses for the covered products that are likely to result from the imposition of the standard;
3. The total projected amount of energy, or as applicable, water, savings likely to result directly from the imposition of the standard;
4. Any lessening of the utility or the performance of the covered products likely to result from the imposition of the standard;
5. The impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from the imposition of the standard;
6. The need for national energy and water conservation; and
7. Other factors the Secretary of Energy (Secretary) considers relevant. (42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))
EPCA also contains what is known as an “anti-backsliding” provision, which prevents the Secretary from prescribing any amended standard that either increases the maximum allowable energy use or decreases the minimum required energy efficiency of a covered product. (42 U.S.C. 6295(o)(1)) Also, the Secretary may not prescribe an amended or new standard if interested persons have established by a preponderance of the evidence that the standard is likely to result in the unavailability in the United States of any covered product type (or class) of performance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as those generally available in the United States. (42 U.S.C. 6295(o)(4))
Further, EPCA establishes a rebuttable presumption that a standard 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.
See
42 U.S.C. 6295(o)(2)(B)(iii).
EPCA requires DOE to specify a different standard level than that which applies generally to a type or class of products for any group of covered products that have the same function or intended use if DOE determines that products within such group (A) consume a different kind of energy from that consumed by other covered products within such type (or class); or (B) have a capacity or other performance-related feature which other products within such type (or class) do not have and such feature justifies a higher or lower standard. (42 U.S.C. 6294(q)(1)) In determining whether a performance-related feature justifies a different standard for a group of products, DOE must consider such factors as the utility to the consumer of the feature and other factors DOE deems appropriate.
Id.
Any rule prescribing such a standard must include an explanation of the basis on which such higher or lower level was established. (42 U.S.C. 6295(q)(2))
Federal energy conservation requirements generally supersede State laws or regulations concerning energy conservation testing, labeling, and standards. (42 U.S.C. 6297(a)-(c)) DOE can, however, grant waivers of Federal preemption for particular State laws or regulations, in accordance with the procedures and other provisions of section 327(d) of the Act. (42 U.S.C. 6297(d))
Finally, EPCA requires that energy conservation standards address standby mode and off mode energy use. (42 U.S.C. 6295(gg)) Specifically, when DOE adopts a standard for a covered product after July 1, 2010, DOE must, if justified by the criteria for adoption of standards in 42 U.S.C. 6295(o), incorporate standby mode and off mode energy use into the standard, if feasible. If incorporation is not feasible, DOE must adopt a separate standard for such energy use for that product, if justified under 42 U.S.C. 6295(o). (42 U.S.C. 6295(gg)(3)(A)-(B)) DOE has determined
that ballasts do not operate in an “off mode” as defined by EPCA (42 U.S.C. 6291(gg)(1)(A)(ii)), and that the only ballasts that consume power in a “standby mode” as defined by EPCA (42 U.S.C. 6291(gg)(1)(A)(iii)) are those that incorporate an electronic circuit enabling the ballast to communicate with and be part of a lighting control system. DOE's current test procedures for ballasts address such standby mode energy use. 74 FR 54455 (October 22, 2009); 10 CFR part 430, subpart B, appendix Q, section 3.5. In this rulemaking, as discussed in section 0, DOE has not proposed amended standards for dimming ballasts currently covered by standards (42 U.S.C. 6295(g)(8)) because DOE has not found any of these covered products in the marketplace. As the scope of coverage does not include any additional dimming ballasts, this NOPR does not include energy conservation standards for standby mode energy use.
B. Background
1. Current Standards
The current Federal energy conservation standards for ballasts are set forth in Table II.1 and Table II.2 below. The standards in Table II.1 were adopted in a final rule published on September 19, 2000, 65 FR 56739, which completed the first of the two rulemakings required under 42 U.S.C. 6295(g)(7) to consider amending the standards for ballasts (hereafter referred to as the 2000 Ballast Rule). The standards in Table II.2 were established by amendments to EPCA in the Energy Policy Act of 2005 (EPACT 2005), Public Law 109-58.
Table II.1—Energy Conservation Standards From the 2000 Ballast Rule
Application for operation of
Ballast input voltage
Total nominal lamp watts
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 F96T12HO lamps
120
220
0.39
277
220
0.39
10 CFR 430.32(m)(3).
Table II.2—Energy Conservation Standards from EPACT 2005
Application for operation of
Ballast input voltage
Total nominal lamp watts
Ballast efficacy factor
One F34T12 lamp
120/277
34
2.61
Two F34T12 lamps
120/277
68
1.35
Two F96T12/ES lamps
120/277
120
0.77
Two F96T12/HO/ES lamps
120/277
190
0.42
(42 U.S.C. 6295(g)(8)(A); 10 CFR 430.32(m)(5))
In summary, as reflected in the foregoing two tables, the ballasts currently regulated under EPCA consist of 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 (V) with an input current frequency of 60 hertz (Hz).
2. History of Standards Rulemaking for Fluorescent Lamp Ballasts
EPCA establishes energy conservation standards for certain ballasts and requires that DOE conduct two cycles of rulemakings to determine whether to amend the standards for ballasts, including whether to adopt standards for additional ballasts. (42 U.S.C. 6295(g)(5)-(8)) As indicated above, DOE completed the first of these rulemaking cycles in the 2000 Ballast Rule. 65 FR 56740 (Sept. 19, 2000). In this rulemaking, the second rulemaking cycle required by 42 U.S.C. 6295(g)(7), DOE considers whether to amend the existing standards for ballasts and whether to adopt standards for additional ballasts.
DOE initiated this rulemaking on January 14, 2008 by publishing in the
Federal Register
a notice announcing the availability of the “Energy Conservation Standards Rulemaking Framework Document for Fluorescent Lamp Ballasts.” (A PDF of the framework document is available at
http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/ballast_framework_011408.pdf
. In this notice, DOE also announced a public meeting on the framework document and requested public comment on the matters raised in the document. 73 FR 3653 (Jan. 22, 2008). The framework document described the procedural and analytical approaches that DOE anticipated using to evaluate energy conservation standards for the ballasts, and identified various issues to be resolved in conducting this rulemaking.
DOE held the public meeting on February 6, 2008, where it: presented the contents of the framework document; described the analyses it planned to conduct during the rulemaking; sought comments from interested parties on these subjects; and in general, sought to inform interested parties about, and facilitate their involvement in, the rulemaking. Interested parties at the public meeting discussed the active mode test procedure and several major analyses related to this rulemaking. At the meeting and during the period for commenting on the framework document, DOE received many
comments that helped identify and resolve issues involved in this rulemaking.
DOE then gathered additional information and performed preliminary analyses to help develop potential energy conservation standards for ballasts. DOE published in the
Federal Register
an announcement of the availability of the preliminary technical support document (the preliminary TSD) and of another public meeting to discuss and receive comments on the following matters: the product classes DOE planned to analyze; the analytical framework, models, and tools that DOE was using to evaluate standards; the results of the preliminary analyses performed by DOE; and potential standard levels that DOE could consider. 75 FR 14319 (March 24, 2010) (the March 2010 notice). DOE also invited written comments on these subjects.
Id.
The preliminary TSD is available at
http://www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_ballasts_ecs_prelim_tsd.html.
In the notice, DOE requested comment on other relevant issues that would affect energy conservation standards for ballasts or that DOE should address in this notice of proposed rulemaking (NOPR).
Id.
at 14322.
The preliminary TSD provided an overview of the activities DOE undertook in developing standards for ballasts, and discussed the comments DOE received in response to the framework document. It also described the analytical framework that DOE uses in this rulemaking, including a description of the methodology, the analytical tools, and the relationships among the various analyses that are part of the rulemaking. The preliminary TSD presented and described in detail each analysis DOE performed up to that point, including descriptions of inputs, sources, methodologies, and results. These analyses were as follows:
• A
market and technology assessment
addressed the scope of this rulemaking, identified the potential product classes for ballasts, characterized the markets for these products, and reviewed techniques and approaches for improving their efficiency;
• A
screening analysis
reviewed technology options to improve the efficiency of ballasts, and weighed these options against DOE's four prescribed screening criteria;
• An
engineering analysis
estimated the manufacturer selling prices (MSPs) associated with more energy-efficient ballasts;
• An
energy use analysis
estimated the annual energy use of ballasts;
• A
markups analysis
converted estimated MSPs derived from the engineering analysis to consumer prices;
• A
life-cycle cost analysis
calculated, for individual consumers, the discounted savings in operating costs throughout the estimated average life of the product, compared to any increase in installed costs likely to result directly from the imposition of a given standard;
• A
payback period (PBP) analysis
estimated the amount of time it takes individual consumers to recover the higher purchase expense of more energy efficient products through lower operating costs;
• A
shipments analysis
estimated shipments of ballasts over the time period examined in the analysis, which was used in performing the national impact analysis (NIA);
• A
national impact analysis
assessed the national energy savings, and the national net present value of total consumer costs and savings, expected to result from specific, potential energy conservation standards for ballasts; and
• A
preliminary manufacturer impact analysis
took the initial steps in evaluating the effects on manufacturers of new efficiency standards.
The public meeting announced in the March 2010 notice took place on April 26, 2010. At this meeting, DOE presented the methodologies and results of the analyses set forth in the preliminary TSD. Interested parties discussed the following major issues at the public meeting: the pros and cons of various efficiency metrics; how test procedure variation might affect efficiency measurements; special requirements for electromagnetic interference (EMI)-sensitive environments; product class divisions; MSPs and overall pricing methodology; markups; the maximum technologically feasible ballast efficiency; cumulative regulatory burden; and shipments. The comments received since publication of the March 2010 notice, including those received at the April 2010 public meeting, have contributed to DOE's proposed resolution of the issues in this rulemaking. This NOPR responds to the issues raised in the comments received.
Since the April 2010 public meeting, additional changes have been proposed to the active mode test procedure that have directly impacted this rulemaking. After reviewing comments submitted in response to the active mode test procedure NOPR (75 FR 14287, March 24, 2010) and conducting additional research, DOE issued a supplemental NOPR (SNOPR) proposing a lamp-based ballast efficiency metric instead of the resistor-based metric proposed in the NOPR. 75 FR 71570 (November 24, 2010). DOE believes the lamp-based metric more accurately assesses the real-life performance of a ballast. In the SNOPR, DOE sought additional comment on this approach. This NOPR evaluates standards for fluorescent lamp ballasts in terms of the new metric proposed in the active mode test procedure SNOPR. Please refer to section 0 for more details.
3. Compliance Date
EPCA contains specific guidelines regarding the compliance date for any standards amended by this rulemaking. EPCA requires DOE to determine whether to amend the standards in effect for fluorescent lamp ballasts and whether any amended standards should apply to additional ballasts. (42 U.S.C. 6295(g)(7)(B)). As stated above, the existing standards for ballasts are the standards established in the 2000 Ballast Rule and the standards established through the EPCA amendments to EPACT 2005. EPCA specifies that any amended standards established in this rulemaking shall apply to products manufactured after a date that 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. (42 U.S.C. 6295(g)(7)(C)). DOE is required by consent decree to publish any amended standards for ballasts by June 30, 2011.
9
As a result, and in compliance with 42 U.S.C. 6295(g)(7)(C), DOE expects the compliance date to be 3 years after the publication of any final amended standards, by June 30, 2014.
9
Under the consolidated Consent Decree in
New York
v.
Bodman,
No. 05 Civ. 7807 (S.D.N.Y. filed Sept. 7, 2005) and
Natural Resources Defense Council
v.
Bodman,
No. 05 Civ. 7808 (S.D.N.Y. filed Sept. 7, 2005) the U.S. Department of Energy is required to publish a final rule amending energy conservation standards for fluorescent lamp ballasts no later than June 30, 2011.
III. Issues Affecting the Scope of This Rulemaking
A. Additional Fluorescent Lamp Ballasts for Which DOE Is Proposing Standards
1. Scope of EPCA Requirement That DOE Consider Standards for Additional Ballasts
As discussed above, amendments to EPCA established energy conservation standards for certain fluorescent lamp ballasts, (42 U.S.C. 6295(g)(5), (6), and (8)) and directed DOE to conduct two rulemakings to consider amending the standards. The first amendment was completed with the publication of the 2000 Ballast Rule. This rulemaking fulfills the statutory requirement to determine whether to amend standards a second time. EPCA specifically directs DOE, in this second amendment, to determine whether to amend the standards in effect for fluorescent lamp ballasts and 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))
The preliminary TSD notes that a wide variety of fluorescent lamp ballasts are not currently covered by energy conservation standards, and they are potential candidates for coverage under 42 U.S.C. 6295(g)(7). DOE encountered similar circumstances in a recent rulemaking that amended standards for general service fluorescent and incandescent reflector lamps (hereafter referred to as the 2009 Lamps Rule).
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74 FR 34080, 34087-8 (July 14, 2009). In that rule, DOE was also directed by EPCA to consider expanding its scope of coverage to include additional products: General service fluorescent lamps (GSFL). EPCA defines general service fluorescent lamps as fluorescent lamps that can satisfy the majority of fluorescent lamp applications and that are not designed and marketed for certain specified, non-general lighting applications. (42 U.S.C. 6291(30)(B)) As such, the term “general service fluorescent lamp” is defined by reference to the term “fluorescent lamp,” which EPCA defines as “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,” and as including the four enumerated types of fluorescent lamps for which EPCA already prescribes standards. (42 U.S.C. 6291(30)(A); 42 U.S.C. 6295(i)(1)(B)) To construe “general service fluorescent lamp” in 42 U.S.C. 6295(i)(5) as limited by those types of fluorescent lamps would mean there are no GSFL that are not already subject to standards, and hence, there would be no “additional” GSFL for which DOE could consider standards. Such an interpretation would conflict with the directive in 42 U.S.C. 6295(i)(5) that DOE consider standards for “additional” GSFL, thereby rendering that provision a nullity.
10
Documents for the 2009 Lamps Rule are available at:
http://www1.eere.energy.gov/buildings/appliance_standards/residential/incandescent_lamps.html.
Therefore, DOE concluded that the term “additional general service fluorescent lamps” in 42 U.S.C. 6295(i)(5) allows DOE to set standards for GSFL other than the four enumerated lamp types specified in the EPCA definition of “fluorescent lamp.” As a result, the 2009 Lamps Rule defined “fluorescent lamp” to include:
(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.
10 CFR 430.2
In this rulemaking, DOE is directed to consider whether any amended standard should be applicable to additional fluorescent lamp ballasts. (42 U.S.C. 6295(g)(7)(B)) EPCA defines a “fluorescent lamp ballast” as “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.” (42 U.S.C. 6291(29)(A)) For this rule, DOE proposes to reference the definition of fluorescent lamp adopted by the 2009 Lamps Rule. This definition allows DOE to consider expanding coverage to include additional fluorescent lamp ballasts while not eliminating coverage of any ballasts for which standards already exist.
2. Identification of the Additional Ballasts for Which DOE Proposes Standards
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 standards are not already prescribed) that operate fluorescent lamps, as defined in 10 CFR 430.2. For each additional fluorescent lamp ballast, DOE considers potential energy savings, technological feasibility and economic justification when determining whether to include them in the scope of coverage. In its analyses, DOE assessed the potential energy savings from market share estimates, potential ballast designs that improve efficiency, and other relevant factors. For market share estimates, DOE used both quantitative shipment data and information obtained during manufacturer interviews. DOE also assessed the potential to achieve energy savings in certain ballasts by considering whether those ballasts could serve as potential substitutes for other regulated ballasts.
In the preliminary TSD, DOE considered extending the scope of coverage to several additional ballast types including those that operate: Additional numbers and diameters of 4-foot MBP lamps, additional numbers and diameters of 8-foot high output (HO) lamps, additional numbers and diameters of 8-foot slimline lamps, 4-foot miniature bipin (miniBP) standard output (SO) lamps, 4-foot miniBP high output lamps, and 8-foot high output cold temperature lamps commonly used in outdoor signs. DOE also considered whether to extend coverage to dimming ballasts, but determined that those ballasts represent a very small portion of the overall market and are unlikely to be substituted for covered products due to their high first cost. The California investor-owned utilities (the California Utilities), and the Northwest Energy Efficiency Alliance (NEEA) and Northwest Power and Conservation Council (NPCC) agreed with the expanded scope of coverage presented in the preliminary TSD. In particular, the California Utilities commented that there is a wide range of efficiencies among the products included in the proposed coverage and that cost-effective standards will lead to significant energy savings. The National Electrical Manufacturers Association (NEMA) generally agreed with the expanded scope of coverage, but requested a specific exemption for
magnetic ballasts that operate in EMI-sensitive applications. (NEMA, No. 29 at p. 2; California Utilities, No. 30 at p. 1; NEEA and NPCC, No. 32 at p. 2)
11
The sections below discuss the comments received in more detail.
11
A notation in the form “NEMA, No. 29 at p. 2” identifies a written comment that DOE has received and has included in the docket of this rulemaking. This particular notation refers to a comment: (1) Submitted by NEMA; (2) in document number 29 of the docket, and (3) on page 2 of that document.
a. Dimming Ballasts
Historically, energy conservation standards have exempted ballasts designed for dimming to 50 percent or less of their maximum output. (10 CFR 430.32(m)(4, 6-7)) However, in 2010, exemptions included in EPACT 2005 expired for dimming ballasts that operate certain reduced-wattage lamps. (10 CFR 430.32(m)(6-7)) DOE research has revealed no dimming ballasts currently on the market that operate these lamps because the gas composition of reduced-wattage lamps makes them undesirable for use in dimming applications. Additionally, dimming ballasts employ cathode heating to facilitate dimming and therefore operate lamps with two pins. Because 8-foot slimline lamps have only a single pin, these lamps are not suitable for use with dimming ballasts. Based on data from the 2005 U.S. Census and interviews with manufacturers, DOE determined in the preliminary TSD that dimming ballasts of all types had less than 1 percent market share. DOE also concluded that these ballasts are already used in energy-saving systems. After examining the potential for substitution from other ballast types, DOE believed there was 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 up-front cost. For all of these reasons, DOE did not consider expanding coverage of dimming ballasts in the preliminary TSD.
NEMA, the California Utilities, and the NEEA and NPCC agreed with the exclusion of additional dimming ballasts. (NEMA, No. 29 at p. 2; California Utilities, No. 30 at p. 1; NEEA and NPCC, No. 32 at p. 3) Philips and Osram Sylvania emphasized that dimming ballasts are part of high-efficiency systems that realize greater energy savings than fixed-light-output systems. (Philips, Public Meeting Transcript, No. 34 at pp. 122-123; OSI, No. 34, Public Meeting Transcript, No. 34 at pp. 124-125) The California Utilities and the NEEA and NPCC also cited the lack of an industry-standard test procedure as a potential barrier to including dimming ballasts in this rulemaking. NEMA concurred, stating that industry has not agreed on the appropriate dimmed level for evaluation and that measuring at many levels is burdensome. (California Utilities, No. 30 at p. 1; NEEA and NPCC, No. 32 at p. 3; NEMA, No. 29 at p. 2)
DOE agrees that dimming ballasts have a very small market share and are already used in energy-saving systems. They are unlikely to become a substitute for fixed-light output ballasts due to their high up-front cost. The lack of an industry-standardized test procedure for newer dimming products makes it difficult for DOE to determine whether energy conservation standards for additional dimming ballasts are technologically feasible. For these reasons, DOE is not proposing to expand the coverage of dimming ballasts in this NOPR. However, the dimming ballasts that operate the four reduced-wattage lamp combinations described in 10 CFR 430.32(m)(5) (EPACT 2005 standards) will continue to be covered by existing energy conservation standards.
b. Sign Ballasts
Current energy conservation standards exclude ballasts designed to operate two F96T12HO lamps at ambient temperatures of 20 degrees Fahrenheit (°F) or less and for use in an outdoor sign. (10 CFR 430.32(m)) In the preliminary TSD, DOE considered whether to include these ballasts in the scope of coverage for this rulemaking. DOE found that the market share of cold temperature sign ballasts was about 1 percent in 2005. Despite their relatively small market share, the energy savings potential per ballast is substantial due to their operation of large numbers of high output lamps. Replacing a magnetic with an electronic
12
sign ballast could reduce energy consumption by as much as 25 percent to 35 percent. Given that sign ballasts exist at more than one level of efficiency, DOE has determined it is technologically feasible to improve the energy efficiency of sign ballasts. Preliminary results from the LCC and NIA analyses indicated that setting standards would be economically justified. For these reasons, DOE included them in the scope of coverage in the preliminary TSD.
12
When DOE refers to an electronic ballast throughout this document, it is referring to a high frequency ballast as defined by as defined in ANSI C82.13-2002. Similarly, when DOE refers to a magnetic ballast, it is referring to a low frequency ballast as defined by the same ANSI standard.
The Appliance Standards Awareness Project (ASAP) and the NEEA and NPCC agreed with DOE's decision to expand coverage to include cold temperature outdoor sign ballasts. Although these products comprise a relatively small percentage of overall fluorescent ballast shipments, the NEEA and NPCC note that these ballasts have much higher energy use compared to other covered ballast types due to their high system input power and low efficiency of present systems. (ASAP, Public Meeting Transcript, No. 34 at pp. 121-122; NEEA and NPCC, No. 32 at p. 3) DOE received no comments suggesting that DOE should not include these ballasts in the scope of coverage for this rulemaking. Therefore, for the reasons set forth above, DOE proposes to include them in the scope of coverage for this NOPR. 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 a single sign ballast can be designed to operate a range of loads including HO lamps between 1.5 feet and 10 feet with one to six lamps per ballast. Because only 8-foot HO lamps are included in the definition of fluorescent lamp (10 CFR 430.2), DOE proposes to include sign ballasts that can operate 8-foot HO lamps in the scope of coverage.
c. T5 Ballasts
In the preliminary TSD, DOE considered whether to expand the scope of coverage to include ballasts that operate standard output and high output 4-foot miniBP T5 lamps. The U.S. Census reports that T5 HO 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. 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. The shipment analysis confirms that T5 SO and T5 HO ballasts represent a significant portion of the market. Because higher-efficiency versions of some of these ballasts are already present in the market, DOE concluded that standards to increase the energy efficiency of these ballasts were technologically feasible. Based on LCC and NIA results in the preliminary TSD, coverage of T5 ballasts would be economically justified. For these reasons, DOE included T5 ballasts in the
scope of coverage in the preliminary TSD.
DOE did not receive any adverse comment to its inclusion of T5 ballasts in the scope of coverage for the preliminary TSD. Therefore, for the reasons stated above, DOE proposes to include them in the scope in this NOPR. 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 ballasts designed to operate nominally 4-foot lengths of standard output and high output T5 miniBP lamps.
d. Residential Ballasts
In the preliminary TSD, DOE considered whether to include residential ballasts in the scope of coverage. Residential ballasts, defined as ballasts that have a power factor less than 0.9 and are designed for use only in residential building applications, are currently exempt from existing energy conservation standards. 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. In the preliminary TSD, DOE stated its belief that the 2005 market share and total shipments of residential ballasts was much higher than the 1.5 percent reported for magnetic residential ballasts in the U.S. census. First, many residential ballasts are manufactured overseas by foreign companies that do not share shipment data with the U.S. Census. Second, electronic ballasts are a common option for residential fluorescent lighting fixtures, but they were not reported in the Census data. Because of these omissions, DOE believes residential ballasts represent a more sizeable portion of the overall ballast market and represent significant potential energy savings.
DOE also found that residential ballasts exist at a range of efficiencies. They can be magnetic or electronic and exist for both T8 and T12 lamps. Therefore, DOE believed standards to increase the energy efficiency of residential ballasts were technologically feasible. Preliminary results in the LCC and NIA indicated that standards for residential ballasts were economically justified. For these reasons, DOE included residential ballasts in the scope of coverage in the preliminary TSD.
ASAP and the NEEA and NPCC agreed with DOE's decision to expand coverage to include residential ballasts. The NEEA and NPCC noted that the residential ballast market is expected to grow substantially as residential lighting energy codes become more stringent. They noted that California, Oregon, and Washington have codes that require fluorescent or higher-efficacy systems. Similarly, the 2009 International Energy Conservation Code requires that 50 percent of all permanently installed lighting in residences have a minimum efficacy of 45 lumens per watt. (ASAP, Public Meeting Transcript, No. 34 at pp. 121-122; NEEA and NPCC, No. 32 at pp. 2-3) DOE did not receive any adverse comments regarding coverage of residential ballasts. Therefore, for the reasons stated above, DOE proposes to include residential ballasts that operate 4-foot medium bipin or 2-foot U-shaped lamps in the scope of coverage for this NOPR.
e. Ballasts That Operate T8 4-Foot MBP and 2-Foot U-Shaped Lamps
Existing energy conservation standards do not apply to ballasts that operate T8 lamps. In the preliminary TSD, DOE considered whether to extend coverage to these types of ballasts. Ballasts that operate 4-foot T8 MBP and 2-foot T8 U-shaped lamps exhibit a range of efficiencies, indicating that standards to increase the energy efficiency of these ballasts are technologically feasible. 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, due to existing 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. Thus, there is potential for significant energy savings by regulating the 4-foot T8 ballast market. Furthermore, preliminary results in the LCC and NIA demonstrated the potential for significant economic savings, indicating that standards for these ballasts would be economically justified. For these reasons, DOE included ballasts that operate 4-foot T8 MBP and 2-foot T8 U-shaped lamps in the scope of coverage in the preliminary TSD.
DOE did not receive any adverse comments regarding coverage of these ballasts. Therefore, for the reasons stated above, DOE proposes to include ballasts that operate 4-foot T8 MBP and 2-foot T8 U-shaped lamps in the scope of coverage for this NOPR.
f. Ballasts That Operate T8 8-Foot Slimline Lamps
Similar to ballasts that operate 4-foot T8 MBP and 2-foot T8 U-shaped lamps, ballasts that operate 8-foot T8 slimline lamps are also not subject to existing energy conservation standards. According to the U.S. Census, 8-foot slimline T8 ballasts had about 2 percent market share in 2005, while 8-foot slimline T12 ballasts had about 3 percent market share. Although the market share for 8-foot slimline T8 ballasts as reported by the U.S. Census is relatively small, the 2009 Lamps Rule will eliminate all currently commercially available T12 lamps in 2012, further increasing demand for T8 lamp-and-ballast systems. In addition, while some 8-foot slimline T12 systems are being replaced by two 4-foot T8 systems, others are being replaced by 8-foot slimline T8 systems. In addition, given that these ballasts exist at a range of efficiencies, DOE believes that energy conservation standards are technologically feasible. Thus, DOE believes there is potential for significant energy savings by covering ballasts that operate 8-foot slimline T8 lamps. Based on DOE's preliminary LCC and NIA results for these ballasts, coverage of these ballasts would be economically justified. For these reasons, in the preliminary TSD, DOE included ballasts that operate 8-foot SP slimline T8 lamps in the scope of coverage.
DOE did not receive any adverse comments regarding coverage of these ballasts. Therefore, for the reasons stated above, DOE proposes to include ballasts that operate 8-foot SP slimline T8 lamps in the scope of coverage for this NOPR.
g. Ballasts That Operate T8 8-Foot HO Lamps
In the preliminary TSD, DOE considered whether to cover ballasts designed to operate recessed double contact (RDC) HO T8 lamps. 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. However, according to analysis conducted for the 2009 Lamps Rule, most currently commercially available T12 HO lamps do not meet energy conservation standards that come into effect in 2012. Therefore, DOE believes that T8 HO ballast shipments will increase in
response to those standards. There is a range of efficiency levels for 8-foot T8 HO ballasts currently in the market; therefore, energy conservation standards to increase the energy efficiency of these ballasts are technologically feasible. In addition, preliminary LCC and NIA results demonstrated the potential for significant economic savings. Based on these findings, DOE included 8-foot HO T8 ballasts in the scope of coverage in the preliminary TSD.
DOE did not receive any adverse comments regarding coverage of these ballasts. Therefore, for the reasons stated above, DOE proposes to include ballasts that operate 8-foot RDC HO T8 lamps in the scope of coverage for this NOPR.
h. Ballasts That Operate in EMI-Sensitive Environments
At the public meeting, Philips commented that magnetic ballasts are currently used in certain EMI-sensitive environments, and that the proposals in the preliminary TSD would not allow these types of ballasts to exist in the future. (Philips, Public Meeting Transcript, No. 34 at pp. 125-126) GE agreed with Philips and cited critical care suites, surgery suites, airport control towers, and nuclear medicine laboratories as examples of situations where ballasts that generate low or no EMI are needed. (GE, Public Meeting Transcript, No. 34 at p. 126) In written comments, NEMA stated that DOE needs to address an exemption for magnetic ballasts in EMI-sensitive applications and proposed that they should be high-performance T8 ballasts, which would be more expensive than electronic ballasts (NEMA, No. 29 at p. 2).
DOE conducted research and interviews with fluorescent lamp ballast and fixture manufacturers to identify the following applications as potentially sensitive to EMI: Medical operating room telemetry or life support systems; airport control systems; electronic test equipment; radio communication devices; radio recording studios; correctional facilities; clean rooms; facilities with low signal-to-noise ratios; and aircraft hangers or other buildings with predominantly metal construction.
To understand the specifications that ballast consumers require for different applications, DOE researched existing regulations for EMI. DOE identified EMI standards for general applications such as commercial buildings, residential buildings, naval vessels, and other spaces. These standards include (1) the Federal Communications Commission (FCC) standards in 47 CFR part 18 for conducted EMI and (2) Department of Defense MIL-STD-461F
13
CE102 limits for all applications for conducted emissions from power leads between 10kHz and 10MHz. Table III.1 below shows the existing FCC and military standards for conducted electromagnetic interference. The frequency column indicates the frequency of the electromagnetic interference rather than the frequency at which the ballast operates.
13
Department of Defense MIL-STD-461F is available at
http://www.cvel.clemson.edu/pdf/MIL-STD-461F.pdf.
Table III.1—Conducted EMI Requirements for Fluorescent Lamp Ballasts
Frequency
(MHz)
FCC Title 47 Part 18
conducted EMI, Maximum RF line voltage measured with a 50 micro Henry (μH)/50 ohm line impedance stabilization
network
(LISN) micro volt (μV)
CE 102 MIL-STD 461F, limit level for conducted emissions for all
applications
(μV)
Non-consumer equipment:
0.45 to 1.6
1,000
1,000
1.6 to 30
3,000
1,000 *Applies up to 10 MHz
Consumer equipment:
0.45 to 2.51
250
1,000
2.51 to 3.0
3,000
1,000
3.0 to 30
250
1,000 *Applies up to 10 MHz
In addition to using low-frequency magnetic ballasts in fixtures, DOE researched other ways that fixture manufacturers can reduce EMI. It is possible to install an external EMI filter on the input side of the ballast to limit conducted EMI that escapes the ballast from continuing to propagate through the building wiring. In addition, a grid lens can be installed to cover the lamp chamber to increase the impedance to a specific frequency or to bring radiated EMI to ground. DOE received mixed feedback from manufacturers concerning whether inline filters, special lenses, grounding cages, fixture design, and other external filters would be sufficient to reduce EMI from electronic ballasts to acceptable levels for EMI-sensitive applications. Electronic ballasts typically operate at a frequency above 20 kHz, which can turn the fluorescent lamp arc into an emitter of high-frequency electromagnetic waves. The switch mode power supply within electronic ballasts can also radiate high-frequency electromagnetic waves. Because the intensity of EMI is directly proportional to its frequency, the EMI from lighting systems containing high-frequency electronic ballasts may penetrate grid lenses and may affect other equipment over a farther range than the EMI from magnetic ballasts.
DOE learned from manufacturer interviews that magnetic ballasts are typically recommended for situations in which EMI has been or is expected to be a concern. These manufacturers believe the engineering investment to develop specialty electronic ballasts for EMI-sensitive applications would be burdensome and not economically justifiable given the very limited demand. Furthermore, manufacturers indicated uncertainty over the effectiveness of these measures for each individual application. DOE was also unable to determine whether EMI related issues with electronic ballasts could be eliminated with the methods described above. Manufacturers
suggested that an exemption for T8 magnetic ballasts would not constitute a risk for magnetic ballast substitution in current electronic ballast applications because magnetic ballasts are generally heavier, more expensive, and use more energy than electronic ballast alternatives. Customers generally prefer magnetic ballasts only in situations where EMI is a particular concern.
Based on its analysis of EMI-sensitive ballast applications, DOE proposes that T8 magnetic ballasts designed and labeled for use in EMI-sensitive environments only and shipped by the manufacturer in packages containing not more than 10 ballasts be exempt from the standards established in this NOPR. Because of the diversity in magnetic T8 ballast applications, DOE has designed the exemption similar to the previous fluorescent lamp ballast exemptions for replacement ballasts. DOE believes the exemption is necessary because in some environments, EMI can pose a serious safety concern that is best mitigated with magnetic ballast technology. DOE does not believe magnetic ballasts would likely be used as substitutes in current electronic ballast applications due to their higher cost and weight. See appendix 5E of the TSD for more details.
3. Summary of Fluorescent Lamp Ballasts to Which DOE Proposes To Extend Coverage
With the exception of the comments discussed above, DOE received no other input related to coverage of fluorescent lamp ballasts. In addition, DOE's revised analyses indicate that energy conservation standards for the ballasts to which DOE preliminarily decided to extend coverage in the preliminary TSD are still expected to be technologically feasible, economically justified, and would result in significant energy savings. Therefore, in summary, DOE is proposing to cover the following additional fluorescent lamp ballasts:
(1) Ballasts that operate 4-foot medium bipin lamps with a rated wattage
14
of 25W or more, and an input voltage at or between 120V and 277V;
14
The 2009 Lamps Rule adopted a new definition for rated wattage that can be found in 10 CFR 430.2.
(2) Ballasts that operate 2-foot medium bipin 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 8-foot high output lamps with an input voltage at or between 120V and 277V;
(4) Ballasts that operate 8-foot slimline lamps with a rated wattage of 52W or more, and an input voltage at or between 120V and 277V;
(5) Ballasts that operate 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 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 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 are designed and labeled for use in residential applications; and
(8) Ballasts that operate 8-foot high output lamps with an input voltage at or between 120V and 277V, and operate at ambient temperatures of 20 degrees F or less and are used in outdoor signs.
B. Off Mode and Standby Mode Energy Consumption Standards
EPCA requires energy conservation standards adopted for a covered product after July 1, 2010 to address standby mode and off mode energy use. (42 U.S.C. 6295(gg)(3)) Because DOE is required by consent decree to publish a final rule establishing any amended standards for fluorescent lamp ballasts by June 30, 2011, this rulemaking is subject to this requirement. DOE determined that it is not possible for the ballasts at issue in this rulemaking to meet the off-mode criteria because there is no condition in which a ballast is connected to the main power source and is not in a mode already accounted for in either active or standby mode. In the test procedure addressing standby mode energy consumption, DOE determined that the only ballasts that consume energy in standby mode 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). 74 FR 54445, 54447-8 (October 22, 2009). DOE believes that the only commercially available ballasts that incorporate an electronic circuit to communicate with a lighting control interface are dimming ballasts.
As discussed in section 0, DOE does not propose to expand the scope of coverage to include additional dimming ballasts. Therefore, the only covered dimming ballasts are the products that operate the four reduced-wattage lamp combinations specified in 10 CFR 430.32(m)(5). DOE research has not revealed any dimming ballasts currently on the market that operate these lamps because the gas composition of reduced-wattage lamps makes them undesirable for use in dimming applications. Additionally, these ballasts employ cathode heating to facilitate dimming and therefore operate lamps with two pins. Because 8-foot slimline lamps have only a single pin, these lamps are not suitable for use with dimming ballasts. Because DOE did not discover any dimming products that are covered by existing standards, DOE was not able to characterize standby mode energy consumption. Thus, DOE is not able to set standards for standby mode energy consumption for these ballasts in accordance with 42 U.S.C. 6295(o). DOE did not receive any comments regarding this subject in response to the preliminary TSD. Therefore, for the reasons stated above, DOE does not propose to adopt provisions to address ballast operation in standby mode as part of the energy conservation standards that are the subject of this rulemaking.
IV. General Discussion
A. Test Procedures
As noted above, DOE's current test procedures for ballasts appear at 10 CFR part 430, subpart B, appendix Q. DOE issued a NOPR in which it proposed revisions to these test procedures. 75 FR 14288 (March 24, 2010). The principal change DOE proposed to the existing test methods, in an effort to reduce measurement variation, was to eliminate photometric measurements used to determine ballast efficacy factor (BEF). Instead, DOE proposed to use electrical measurements to determine ballast efficiency (BE), which could then be converted to BEF using empirically derived transfer equations. The proposed changes also specified that the ballast operate a resistive load rather than a lamp load during performance testing. No changes were proposed for the measurement of ballast factor (which required photometric measurements) for consistency with previous methods. Finally, DOE also proposed an update to an industry standard referenced in the existing test procedure.
Id.
at 14290, 14308. DOE also proposed to add methods for testing ballasts that are not currently covered by energy conservation standards, but that DOE is considering for standards in this rulemaking.
Id.
at 14289-91. Finally, DOE proposed provisions for manufacturers to report to DOE on the compliance of their ballasts with applicable standards.
Id.
at 14289, 14290, 14309.
More recently, DOE published a supplementary NOPR in which it proposed revisions to its test procedures
for fluorescent lamp ballasts established under EPCA. 75 FR 71570 (Nov. 24, 2010). This test procedure proposes to measure a new metric, ballast luminous efficiency (BLE), which more directly assesses the electrical losses in a ballast compared to the existing ballast efficacy factor (BEF) metric. Rather than testing a ballast while operating a resistive load, the BLE test procedure measures the performance of a ballast while it is operating a fluorescent lamp. DOE found that a resistive load can model the effective resistance of a lamp operated only at a particular ballast factor, requiring multiple ballast factor specific resistors to be specified and increasing the testing cost to manufacturers. In written comments in response to the NOPR, NEMA suggested that ballast factor be calculated using a combination of electrical measurements and reference lamp arc power values from ANSI C78.81-2010. The SNOPR proposal outlines a new method for determination of ballast factor which requires only electrical measurements.
DOE also notes that EPCA requires DOE to amend its test procedures for all covered products, including those for ballasts, to include the measurement of standby mode and off mode energy consumption, except where current test procedures fully address such energy consumption or where an integrated or separate standard is technically infeasible. (42 U.S.C. 6295(gg)(2)) As indicated above, ballasts do not operate in the off mode and DOE has already amended its test procedures for ballasts to address standby mode energy use. 74 FR 54445 (Oct. 22, 2009). As a result, DOE's current test procedure rulemaking for ballasts does not address standby or off mode energy use.
B. Technological Feasibility
1. General
In each standards rulemaking, DOE conducts a screening analysis based on information it has gathered on all current technology options and prototype designs that could improve the efficiency of the products or equipment that are the subject of the rulemaking. As the first step in such analysis, DOE develops a list of design options for consideration in consultation with manufacturers, design engineers, and other interested parties. DOE then determines which of these means for improving efficiency are technologically feasible. DOE considers technologies incorporated in commercially available products or in working prototypes to be technologically feasible. 10 CFR part 430, subpart C, appendix A, section 4(a)(4)(i).
Once DOE has determined that particular design options are technologically feasible, it further evaluates each of these design options in light of the following additional screening criteria: (1) Practicability to manufacture, install, or service; (2) adverse impacts on product utility or availability; and (3) adverse impacts on health or safety. Section 0 of this notice discusses the results of the screening analysis for ballasts, particularly the designs DOE considered, those it screened out, and those that are the basis for the trial standard levels (TSLs) in this rulemaking. For further details on the screening analysis for this rulemaking,
see
Chapter 4 of the NOPR TSD.
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt an amended standard for a type or class of covered product, it must determine the maximum improvement in energy efficiency or maximum reduction in energy use that is technologically feasible for that product. (42 U.S.C. 6295(p)(1)) Accordingly, DOE determined the maximum technologically feasible (“max tech”) ballast efficiency in the engineering analysis, using the design options identified in the screening analysis (
see
chapter 5 of the NOPR TSD).
As a first step to identifying the maximum technologically feasible efficiency level, DOE conducted testing of commercially available ballasts. In the preliminary analysis, DOE was not able to identify working prototypes that had a higher efficiency than the tested products. Therefore, the “max tech” level determined for the preliminary analysis was based on the most efficient commercially available ballasts tested. DOE presented additional research in appendix 5D of the preliminary TSD to explore whether technologies used in products similar to ballasts could be used to improve the efficiency of ballasts currently on the market.
DOE received several comments regarding its determination of max tech ballast efficiency. These comments are discussed in section 0. For this NOPR, DOE conducted additional analysis to determine the appropriate max tech levels for fluorescent lamp ballasts. Based on the additional testing conducted for this NOPR, DOE has determined that TSL 3 represents the highest efficiency level that is technologically feasible for a sufficient diversity of products (spanning several ballast factors, number of lamps per ballast, and types of lamps operated) within each product class. Table IV.1 presents the max tech efficiency levels for each product class.
Table IV.1—Max Tech Levels
Product class
Equation
*
IS and RS ballasts that operate
1.32 * ln (total lamp arc power) + 86.11.
4-foot MBP lamps
8-foot slimline lamps
PS ballasts that operate
1.79 * ln (total lamp arc power) + 83.33.
4-foot MBP lamps
4-foot MiniBP SO lamps
4-foot MiniBP HO lamps
IS and RS ballasts that operate
1.49 * ln (total lamp arc power) + 84.32.
8-foot HO lamps
PS ballasts that operate
1.46 * ln (total lamp arc power) + 82.63.
8-foot HO lamps
Ballasts that operate
1.49 * ln (total lamp arc power) + 81.34.
8-foot HO lamps in cold temperature outdoor signs
*Equation includes 0.8 percent reduction for testing variation.
Although DOE identified certain ballasts that achieved efficiencies higher than TSL 3, these ballasts were suitable for only a limited range of applications within their product class. DOE does not have sufficient data at this time to determine that a higher efficiency level is technologically feasible for the full range of ballast applications with alternate ballast factors, numbers of lamps, and lamp types. Before making this determination, DOE evaluated the possibility of improving the efficiency of three selected ballasts by inserting improved components in the place of existing components of commercially available ballasts. DOE's experiments with improving ballast efficiency through component substitution did not result in prototypes with improved overall ballast efficiency.
DOE is still considering whether an efficiency level higher than TSL 3 is technologically feasible for a sufficient diversity of lamp types, ballast factors, and numbers of lamps within each product class. Although DOE was unable to improve the efficiency of commercially available ballasts, DOE recognizes that component substitution is not the only method available for incrementally improving ballast efficiency. For example, further improvements may be possible through the incorporation of newly designed integrated circuits into the new ballast designs.
In Appendix 5F of the NOPR TSD, DOE presents additional analysis on the potential for an instant-start ballast efficiency level that exceeds TSL 3. DOE requests comments on its selection of the maximum technologically feasible level and whether it is technologically feasible to attain such higher efficiencies for the full range of instant start ballast applications. Specifically, DOE seeks quantitative information regarding the potential change in efficiency, the design options employed, and the associated change in cost. Any design option that DOE considers to improve efficiency must meet the four criteria outlined in the screening analysis: technological feasibility; practicability to manufacture, install, and service; adverse impacts on product or equipment utility to consumers or availability; and adverse impacts on health or safety. DOE also requests comments on any technological barriers to an improvement in efficiency above TSL 3 for all or certain types of ballasts.
C. Energy Savings
1. Determination of Savings
DOE used its NIA spreadsheet to estimate energy savings from new or amended standards for the ballasts that are the subject of this rulemaking. (The NIA spreadsheet model is described in section 0 of this notice and in chapter 11 of the TSD.) DOE forecasted energy savings beginning in 2014, the year that compliance with any new and amended standards is proposed to be required, and ending in 2043 for each TSL. DOE quantified the energy savings attributable to each TSL as the difference in energy consumption between the standards case and the base case. The base case represents the forecast of energy consumption in the absence of new and amended mandatory efficiency standards, and considers market demand for higher-efficiency products. For example, DOE models a shift in the base case from covered fluorescent lamp ballasts toward emerging technologies such as light emitting diodes (LEDs).
The NIA spreadsheet model calculates the electricity savings in “site energy” expressed in kilowatt-hours (kWh). Site energy is the energy directly consumed by ballasts at the locations where they are used. DOE reports national energy savings on an annual basis in terms of the aggregated source (primary) energy savings, which is the savings in energy used to generate and transmit the site energy. (See NOPR TSD chapter 11) To convert site energy to source energy, DOE derived conversion factors, which change with time, from the model used to prepare the Energy Information Administration's (EIA's)
Annual Energy Outlook 2010
(
AEO2010
).
2. Significance of Savings
As noted above, under 42 U.S.C. 6295(o)(3)(B) DOE is prohibited from adopting a standard for a covered product if such standard would not result in “significant” energy savings. While the term “significant” is not defined in the Act, the U.S. Court of Appeals, in
Natural Resources Defense Council
v.
Herrington,
768 F.2d 1355, 1373 (D.C. Cir. 1985), indicated that Congress intended “significant” energy savings in this context to be savings that were not “genuinely trivial.” The energy savings for all of the TSLs considered in this rulemaking are nontrivial, and therefore DOE considers them “significant” within the meaning of section 325 of EPCA.
D. Economic Justification
1. Specific Criteria
As noted in section II.B, EPCA provides seven factors to be evaluated in determining whether a potential energy conservation standard is economically justified. (42 U.S.C. 6295(o)(2)(B)(i)) The following sections discuss how DOE addresses each of those seven factors in this rulemaking.
a. Economic Impact on Manufacturers and Consumers
In determining the impacts of a new or amended standard on manufacturers, DOE first determines the quantitative impacts using an annual cash-flow approach. This includes both a short-term assessment—based on the cost and capital requirements during the period between the announcement of a regulation and when the regulation comes into effect—and a long-term assessment over the 30-year analysis period. The impacts analyzed include INPV (which values the industry based on of expected future cash flows), cash flows by year, changes in revenue and income, and other measures of impact, as appropriate. Second, DOE analyzes and reports the impacts on different types of manufacturers, including an analysis of impacts on small manufacturers. Third, DOE considers the impact of standards on domestic manufacturer employment and manufacturing capacity, as well as the potential for standards to result in plant closures and loss of capital investment. DOE also takes into account cumulative impacts of different DOE regulations and other regulatory requirements on manufacturers.
For individual consumers, measures of economic impact include the changes in LCC and the PBP associated with new or amended standards. The LCC, which is separately specified as one of the seven factors to consider when determining the economic justification for a new or amended standard, (42 U.S.C. 6295(o)(2)(B)(i)(II)), is discussed in the following section. For consumers in the aggregate, DOE calculates the net present value from a national perspective of the economic impacts on consumers over the forecast period used in a particular rulemaking.
b. Life-Cycle Costs
The LCC is the sum of the purchase price of a product (including its installation) and the operating expense (including energy and maintenance and repair expenditures) discounted over the lifetime of the product. The LCC savings for the considered efficiency levels are calculated relative to a base case that reflects likely trends in the absence of new or amended standards. The LCC analysis required a variety of inputs, such as product prices, product energy consumption, energy prices, maintenance and repair costs, product lifetime, and consumer discount rates. DOE assumed in its analysis that
consumers purchase the product in 2014.
To account for uncertainty and variability in specific inputs, such as product lifetime and discount rate, DOE uses a distribution of values with probabilities attached to each value. A distinct advantage of this approach is that DOE can identify the percentage of consumers estimated to achieve LCC savings or experiencing an LCC increase, in addition to the average LCC savings associated with a particular standard level. In addition to identifying ranges of impacts, DOE evaluates the LCC impacts of potential standards on identifiable sub-groups of consumers that may be disproportionately affected by a national standard.
c. Energy Savings
While significant conservation of energy is a separate statutory requirement for imposing an energy conservation standard, EPCA requires DOE, in determining the economic justification of a standard, to consider the total projected energy savings that are expected to result directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) DOE uses the NIA spreadsheet results in its consideration of total projected savings.
d. Lessening of Utility or Performance of Products
In establishing classes of products, and in evaluating design options and the impact of potential standard levels, DOE seeks to develop standards that would not lessen the utility or performance of the products under consideration. The efficiency levels considered in today's NOPR will not affect any features valued by consumers, such as starting method, ballast factor, or cold temperature operation. Therefore, DOE believes that none of the TSLs presented in section 0 would reduce the utility or performance of the ballasts considered in the rulemaking. (42 U.S.C. 6295(o)(2)(B)(i)(IV))
e. Impact of Any Lessening of Competition
EPCA directs DOE to consider any lessening of competition likely to result from standards. It directs the Attorney General to determine the impact, if any, of any lessening of competition likely to result from a proposed standard and to transmit such determination to the Secretary, not later than 60 days after the publication of a proposed rule, together with an analysis of the nature and extent of such impact. (42 U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii)) DOE has transmitted a copy of today's proposed rule to the Attorney General and has requested that the Department of Justice (DOJ) provide its determination on this issue. DOE will address the Attorney General's determination in any final rule.
f. Need of the Nation to Conserve Energy
The non-monetary benefits of the proposed standards are likely to be reflected in improvements to the security and reliability of the nation's energy system. Reduced demand for electricity may also result in reduced costs for maintaining the reliability of the nation's electricity system. DOE conducts a utility impact analysis to estimate how standards may affect the Nation's needed power generation capacity.
Energy savings from the proposed standards are also likely to result in environmental benefits in the form of reduced emissions of air pollutants and greenhouse gases (GHG) associated with energy production. DOE reports the environmental effects from the proposed standards—and from each TSL it considered for ballasts—in the environmental assessment contained in the NOPR TSD. DOE also reports estimates of the economic value of reduced emissions reductions resulting from the considered TSLs.
g. Other Factors
The Act allows the Secretary of Energy to consider any other factors he or she deems relevant in determining whether a standard is economically justified. (42 U.S.C. 6295(o)(2)(B)(i)(VII)) Under this provision, DOE considered subgroups of consumers that may be adversely affected by the standards proposed in this rule. DOE specifically assessed the impact of standards on low-income consumers, institutions of religious worship, and institutions that serve low-income populations. In considering these subgroups, DOE analyzed variations on electricity prices, operating hours, discount rates, and baseline ballasts. See section 0 of this notice for further detail.
2. Rebuttable Presumption
As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA provides for a rebuttable presumption that an energy conservation standard is economically justified if the additional cost to the consumer of a product that meets the standard is less than three times the value of the first-year energy (and, as applicable, water) savings resulting from the standard, as calculated under the applicable DOE test procedure. DOE's LCC and PBP analyses generate values that calculate the payback period for consumers of potential new and amended energy conservation standards. These analyses include, but are not limited to, the 3-year payback period contemplated under the rebuttable presumption test. However, DOE routinely conducts an economic analysis that considers the full range of impacts to the consumer, manufacturer, nation, and environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). The results of this analysis serve as the basis for DOE to evaluate definitively the economic justification for a potential standard level (thereby supporting or rebutting the results of any preliminary determination of economic justification). The rebuttable presumption payback calculation is discussed in section 0 of this NOPR.
V. Methodology and Discussion
DOE used two spreadsheet tools to estimate the impact of today's proposed standards. The first spreadsheet calculates LCCs and payback periods of potential new energy conservation standards. The second provides shipments forecasts and then calculates national energy savings and net present value impacts of potential new energy conservation standards. The Department also assessed manufacturer impacts, largely through use of the Government Regulatory Impact Model (GRIM).
Additionally, DOE estimated the impacts of energy efficiency standards on utilities and the environment. DOE used a version of EIA's National Energy Modeling System (NEMS) for the utility and environmental analyses. The NEMS model simulates the energy sector of the U.S. economy. EIA uses NEMS to prepare its
Annual Energy Outlook,
a widely known baseline energy forecast for the United States. The version of NEMS used for appliance standards analysis is called NEMS-BT, and is based on the
AEO2010
version with minor modifications. The NEMS-BT offers a sophisticated picture of the effect of standards, because it accounts for the interactions between the various energy supply and demand sectors and the economy as a whole.
The EIA approves the use of the name “NEMS” to describe only an
AEO
version of the model without any modification to code or data. Because the present analysis entails some minor code modifications and runs the model under various policy scenarios that deviate from
AEO
assumptions, the name “NEMS-BT” refers to the model as used here. (BT stands for DOE's Building Technologies Program.) For more information on NEMS, refer to
The National Energy Modeling System: An Overview,
DOE/EIA-0581 (98) (Feb. 1998), available at:
http://
tonto.eia.doe.gov/FTPROOT/forecasting/058198.pdf.
A. Market and Technology Assessment
1. General
When beginning an energy conservation standards rulemaking, DOE develops information that provides an overall picture of the market for the products concerned, including the purpose of the products, the industry structure, and market characteristics. This activity includes both quantitative and qualitative assessments based on publicly available information. The subjects addressed in the market and technology assessment for this rulemaking include product classes and manufacturers; historical shipments; market trends; regulatory and non-regulatory programs; and technologies or design options that could improve the energy efficiency of the product(s) under examination.
See
chapter 3 of the TSD for further discussion of the market and technology assessment.
2. Product Classes
In evaluating and establishing energy conservation standards, DOE divides covered products into classes by the type of energy used, or by capacity or other performance-related feature that justifies a different standard for products having such feature. (See 42 U.S.C. 6295(q)) In deciding whether a feature justifies a different standard, DOE must consider factors such as the utility of the feature to users.
Id.
DOE establishes energy conservation standards for different product classes based on the criteria set forth in 42 U.S.C. 6295(o).
In the preliminary TSD, DOE evaluated the performance of a ballast using the BEF metric. DOE considered several potential class-setting factors and ultimately separated product classes based on lamp length, ballast factor, lumen package, maximum number of lamps operated, starting method, and market sector. 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 lamp-and-ballast system; and (3) the use of the ballast in an application for which other ballasts are not suitable. Philips, along with the NEEA and NPCC, generally agreed with DOE's initial determination of the product class structure. (NEEA and NPCC, No. 32 at p. 3; Philips, Public Meeting Transcript, No. 34 at pp. 153-154)
After the April 2010 public meeting, DOE received comments from interested parties that caused it to reevaluate the test method proposed in the active mode test procedure NOPR. As discussed in section 0, DOE published an SNOPR for the active mode test procedure on November 24, 2010. In that document, DOE proposed a lamp-based test procedure for measuring ballast luminous efficiency. Thus, when considering product classes in this NOPR, DOE evaluates potential class-setting factors by considering features that affect BLE instead of BEF.
a. Power Versus Efficiency Relationship
As described in section 0, DOE undertook extensive testing of fluorescent lamp ballasts to evaluate the impact of numerous ballast characteristics on BLE. In its written comments on the active mode test procedure, NEMA suggested that a relationship existed between lamp arc power and BLE such that the product class structure from the preliminary TSD could be greatly simplified. NEMA suggested that instant start ballasts with input power less than or equal to 45 W, greater than 45 W and less than or equal to 125 W, and greater than 125 W could be subject to standards of 85 percent, 88 percent, and 90 percent efficiency respectively. For programmed start ballasts, NEMA recommended standards for the same wattage bins, but with a downward adjustment of 3 percent compared to the instant start values. NEMA provided supplementary information showing that these standard levels in many cases were similar to the levels proposed by DOE in the preliminary TSD. NEMA noted it was only sharing a methodology that could be employed by DOE, not making a formal proposal. (NEMA, No. 15 at p. 9-10)
15
NEMA had previously discussed this methodology as a possible approach at a meeting with DOE in April 2010, subsequent to the public workshop.
16
15
This comment is from the docket for the fluorescent lamp ballast active mode test procedure, which is docket number EERE-2009-BT-TP-0016.
16
A summary of the meeting is available at
http://www.gc.energy.gov/documents/Ex_parte_Meeting_NEMA_05_25_2010.pdf.
Although not a formal proposal for the energy conservation standards rulemaking, this methodology was supported by several manufacturers during interviews for this NOPR. Manufacturers indicated that ballasts that operate similar lamp powers often share similar topologies and component, and thus, should have similar efficiencies. DOE analyzed its test data to attempt to characterize a relationship between BLE and lamp arc power.
It is DOE's understanding that there are both fixed and variable losses in any fluorescent ballast. Fixed losses consist of switching losses, due to components such as transistors, and fixed voltage drops across certain components, such as diodes. These components are necessary for proper ballast operation but will always contribute some amount to overall ballast losses. In ballasts that operate at low powers, fixed losses comprise a significant amount of the power lost. Variable losses consist primarily of resistive losses (also referred to as I
2
R losses) which increase as current increases. Ballasts that operate at higher powers also operate at a higher current and therefore have greater resistive losses. At a certain power level, resistive losses will be greater than fixed losses, as resistive losses continue to increase as power increases.
Using test data, DOE empirically found a relationship between the BLE metric and the natural log of lamp arc power. The logarithmic relationship is consistent with current energy conservation standards for external power supplies.
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42 USC 6295(u)(3)(A). In general, as lamp arc power increases, BLE increases as well. DOE believes this is because the fixed losses of a ballast become proportionally less significant at higher lamp arc powers. Using this relationship has several benefits for determining product classes compared to DOE's approach in the preliminary TSD. Equations allow DOE to set efficiency levels as a function of lamp arc power across a wide range, which simplifies the product class structure and the amount of scaling required between product classes. Furthermore, setting efficiency levels in this manner allows for greater flexibility regarding future innovation. For example, an equation would account for the introduction of new ballast factors. It would also not necessarily have to be revised if the test procedure were modified to require testing with reduced-wattage lamps. By contrast, other approaches could require separate product classes for factors that affect the total wattage operated by a ballast (such as lumen output, ballast factor, and number of lamps operated).
17
External power supplies perform a related function to fluorescent lamp ballasts in that they convert AC to DC, filter unwanted frequencies, and can step up or down voltage.
The sections below discuss specific class-setting factors considered in the preliminary TSD and whether product classes based on these factors are necessary given the power-efficiency relationship.
b. Starting Method
In the preliminary TSD, DOE considered establishing separate product classes based on starting method. DOE found RS and PS ballasts to be inherently less efficient than IS ballasts because RS and PS ballasts provide filament power to the lamp. Although some PS ballasts cut out the filament power during normal operation (using the cathode cutout technology option discussed in chapter 3 of the NOPR TSD), the extra circuitry to remove this power still consumes some amount of power. Whereas RS and IS ballasts are commonly used as substitutes for each other, PS ballasts are not. Programmed start ballasts are commonly used in combination with occupancy sensors because of their ability to maintain the lifetime of the fluorescent lamp. The lifetime of a lamp operated on a PS ballast with occupancy sensors can be as much as three times longer than the lifetime of a lamp operated on an IS or RS ballast in the same application. Thus, DOE's research indicates that use of instant start ballasts with occupancy sensors can result in a significant reduction in lamp lifetime. Because the application in which they are used significantly affects lamp lifetime, programmed start ballasts offer the user a distinct utility. In consideration of their affect on both BEF and utility, DOE established separate product classes for programmed start ballasts in the preliminary TSD.
Philips agreed that RS and PS ballasts would have lower BEFs than IS ballasts. Philips stated that cathode heating of RS and PS ballasts would make the lamps more efficient, which would increase ballast factor and therefore increase overall system efficacy, or BEF. The corresponding increase in ballast input power for these ballasts, however, would offset any overall gain in BEF. Despite this difference in BEF for RS and PS ballasts compared to IS ballasts, Philips did not think NEMA would object to the inclusion of rapid and instant start ballasts in the same product class. Whereas IS and RS ballasts offer the consumer similar utility, Philips believed PS ballasts offered consumers unique utility because of the application in which they are used. Regarding the impact of starting method on ballast efficiency, Philips pointed out that a metric of lamp arc power divided by ballast input power would consider power used to heat cathodes as losses. GE and Philips believed that this should be considered when defining product classes and setting standards. (GE, Public Meeting Transcript, No. 34 at p. 43; Philips, Public Meeting Transcript, No. 34 at pp. 44-46, 71-72)
DOE agrees with GE and Philips that cathode heating is counted as a loss in the BLE metric because it does not directly contribute to the creation of light. Thus, similar to BEF, RS and PS ballasts have lower BLEs than comparable IS ballasts. Because starting method affects BLE in the same way it affects BEF, and DOE has already established a unique utility associated with PS ballasts, DOE proposes to maintain product class divisions for starting method in this NOPR and establish separate product classes for programmed start ballasts and instant and rapid start ballasts.
c. Ballast Factor
Ballast factor (BF) is the ratio of light output of a reference lamp operated by a ballast to the light output of the same lamp operated by a reference ballast. It is typically used to adjust the lumen package of a lamp-and-ballast system. The ballasts proposed for coverage in this rulemaking are available with a variety of ballast factors. In the preliminary TSD, DOE classified 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. In its previous analysis, DOE found that ballasts with high or low BFs had lower BEFs than ballasts with a normal ballast factor. Because BF affected the lumen output of the lamp-and-ballast system, DOE observed that consumers tended to use ballasts with different ballast factors for different applications. DOE believed this behavior constituted a unique utility. Therefore, because of the impact on BEF and utility, DOE established separate product classes in the preliminary TSD for low, normal, and high ballast factor when these products existed for covered ballast types. In the preliminary TSD, however, DOE did not establish separate product classes for high, low, and normal BF for 4-foot T5 MiniBP HO, 8-foot HO, residential, or sign ballasts because products in this category were predominantly offered in one ballast factor range.
The California Utilities commented that DOE should divide residential ballasts into high, normal, and low BF categories because test results showed that residential products existed at more than one BF. (California Utilities, No. 30 at p. 5) Philips commented that the range considered for normal BF was unreasonably large. For T8 ballasts, industry typically considers normal BF to be from 0.85 to 1.00, whereas for T5 ballasts industry considers normal BF to be about 1.00. (Philips, Public Meeting Transcript, No. 34 at p. 136-137)
Because DOE is evaluating a new metric for this NOPR, DOE analyzed the impact of ballast factor on BLE. During interviews, manufacturers stated that as ballast factor increases, BLE should also increase. This is the same observation as the one discussed in section 0, that BLE increases as overall lamp arc power increases, but on a smaller scale. As ballast factor increases, the ballast drives the lamp harder, which increases measured lamp arc power. Because the ballast operates at higher power, its fixed losses become proportionally less significant in comparison to lower BFs. Because BF affects the total power operated by a ballast, and DOE has established a relationship relating total lamp arc power to ballast efficiency, DOE believes the efficiency equation will account for any changes in BF. Thus, in this NOPR, DOE does not propose to establish separate product classes for high, low, or normal BF.
d. 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 HO lamps and 4-foot MiniBP HO lamps tend to operate at higher currents than 8-foot slimline lamps and 4-foot MiniBP 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. In the preliminary TSD, DOE observed that this difference in lamp wattage caused ballasts that operate high output lamps to have lower BEFs than ballasts that operate comparable standard output lamps.
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-lumen-output systems might be installed in lower-ceiling applications such as offices or hospitals, where 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. Therefore, given the observed utility distinctions and notable efficiency differences, DOE established
separate product classes in the preliminary TSD for ballasts that operate SO lamps and ballasts that operate HO lamps.
DOE did not receive any adverse comment to its separation of ballasts that operate HO lamps from those that operate SO lamps due to the impact of larger input powers on BEF. In this NOPR, however, DOE proposes standards based on the BLE metric. Therefore, DOE evaluated the impact of HO lamp operation versus SO lamp operation on BLE. DOE found that BLE is not dependent on system light output, but rather on the total power operated by the ballast. As HO lamps have higher rated powers than SO lamps, DOE believes ballasts that operate HO lamps would be more efficient than comparable ballasts that operate SO lamps. An analysis of test data generally confirmed this prediction. Therefore, because the power-efficiency equation accounts for HO versus SO lamp operation, DOE does not propose to establish separate product classes for ballasts that operate HO lamps, with one exception as explained in the following paragraph.
DOE found that ballasts that operate 8-foot HO lamps did not follow the expected relationship. Compared to 8-foot slimline ballasts, DOE found that 8-foot HO ballasts exhibited lower BLEs although they operated higher lamp powers. DOE believes a separate product class is necessary for 8-foot HO ballasts because there is a significant change in lumen package accompanied by a decrease in BLE. Based on manufacturer interviews, DOE believes 8-foot HO ballasts may have different topology, or circuit design, than other ballast types (
e.g.
4-foot MBP and 8-foot slimline ballasts). Because DOE has established that lumen package offers a unique utility, and in this case a change in lumen package is accompanied by a change in BLE from what the efficiency equation would predict, DOE proposes to establish a separate product class for ballasts that operate 8-foot HO lamps. DOE requests comment on this decision in section 0.
e. Lamp Diameter
Differences in lamp diameter can be accompanied by differences in rated lamp wattage and lumen output. In the preliminary TSD, DOE observed that T8 ballasts generally had higher BEFs than T12 ballasts due to T8 lamps having a lower rated wattage than T12 lamps. DOE noted, however, that T8 lamp-and-ballast systems are commonly used as substitutes for T12 lamp-and-ballast systems, suggesting that there was no unique utility associated with T12 systems. Although the lamps have different wattages, the two systems often have the same lamp lengths and bases, offer comparable lumen output, and can fit within the same fixtures. For these reasons, DOE included T8 and T12 ballasts in the same product class in the preliminary TSD.
In contrast, DOE established separate product classes for ballasts that operate T5 lamps. DOE observed that 4-foot T5 ballasts generally had lower input powers (due to the lower wattage of the test lamp), and therefore higher BEFs, than comparable T8 or T12 ballasts. T5 lamp-and-ballast systems, however, are not always interchangeable with T8 and T12 systems. Because T5 lamps have similar total lumen output to 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. Because of the impact on BEF and consumer utility, DOE established a separate product class in the preliminary TSD for ballasts that operate T5 lamps.
The California Utilities and the NEEA and NPCC supported DOE's conclusion in the preliminary TSD to include T8 and T12 ballasts in the same product class based on their use as substitutes for one another. (California Utilities, No. 30 at p. 1; NEEA and NPCC, No. 32 at p. 3) However, Philips believed that because BEF includes a measure of light output, it should be used to compare ballasts of similar light output only. Philips noted that because F96T12HO/ES lamps have a 13-percent greater lumen output than F96T8HO lamps, ballasts that operate these lamps should not be subject to the same BEF standard. NEMA agreed with Philips and supported different BEF standards for ballasts that operate these lamps. However, NEMA did comment that a single ballast efficiency standard could be set for ballasts that operate F96T8HO and F96T12HO/ES lamps. (Philips, Public Meeting Transcript, No. 34 at pp. 16, 50; NEMA, No. 29 at p. 3, 7)
In this NOPR, DOE considered the impact of lamp diameter on the BLE metric. As described above, differences in lamp diameter can be accompanied by differences in rated lamp wattage and lumen output. Because the efficiency equation sets standards specific to the total lamp power operated by the ballast of interest, the equation will also account for the impact of lamp diameter if there is an associated change in lamp arc power (as is the case with T8HO versus T12HO lamps). In addition, DOE believes that T5HO ballasts operate similar total lamp powers and employ similar technologies to 4-lamp 4-foot MBP PS ballasts that are able to meet the most efficient levels. Furthermore, 2-lamp 4-foot MBP PS ballasts operate similar total lamp power and employ similar technologies to 2-lamp T5 SO ballasts that are able to meet the most efficient levels. Therefore, DOE does not propose to establish separate product classes for ballasts that have different lamp diameters.
f. Lamp Length
Of the fluorescent ballasts DOE proposes to include in the scope of coverage, all are designed to operate lamps with lengths of 4 or 8 feet. As lamp length increases, lamp arc power tends to increase as well. In the preliminary TSD, DOE observed that this increase in lamp power resulted in lower BEFs for ballasts that operate 8-foot lamps as compared to those that operate 4-foot lamps. Furthermore, DOE concluded that 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. Given the impact on both BEF and utility, DOE established separate product classes in the preliminary TSD for ballasts that operate different lamp lengths.
In this NOPR, DOE evaluates impacts of lamp length on BLE. Test data showed that ballasts that operate 8-foot slimline lamps are more efficient than comparable ballasts that operate the same number of 4-foot MBP lamps due to the increased lamp wattage operated by these ballasts. As described in section 0, DOE has developed an efficiency equation for the relationship between BLE and lamp arc power, which accounts for differences in lamp length if there is an associated change in lamp arc power. Therefore, DOE does not propose to establish separate product classes for ballasts that operate 4-foot versus 8-foot lamps.
g. Number of Lamps
Fluorescent lamp 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. In the preliminary TSD, DOE found that BEF decreased with each additional lamp operated because additional lamps increased the ballast's input power. DOE determined that the ability to operate different maximum number of lamps impacts utility because this capacity affects the space required by fixtures (a four-lamp fixture requires more physical space than one-lamp fixture). Given the impact on both BEF and consumer utility, DOE established
separate product classes in the preliminary TSD based on the maximum number of lamps operated by a ballast.
Philips agreed that based on BEF data, 1-lamp ballasts are less efficient than 4-lamp ballasts. (Philips, Public Meeting Transcript, No. 34 at pp. 137-139) In this NOPR, DOE analyzed the impact of operating different numbers of lamps on BLE. Test data generally showed that the more lamps a ballast operates the higher the BLE for that ballast. DOE believes this is because as a ballast operates a larger total lamp power, fixed losses are diluted over a greater power. DOE believes that this relationship is accounted for in the efficiency equation described in section 0, because an increase in the number of lamps operated is associated with an increase in total lamp arc power. Therefore, DOE does not propose to establish separate product classes for ballasts that operate different numbers of lamps.
h. Residential Ballasts
Separate minimum power factor and electromagnetic interference requirements exist for residential and commercial ballasts. Residential ballasts have more stringent (or lower maximum allowable) EMI requirements than commercial ballasts; they also have less stringent (or lower minimum allowable) power factor requirements.
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In the preliminary TSD, DOE concluded these requirements impact utility because they serve distinct market sectors and applications. In addition, DOE believed that the differing requirements caused residential ballasts to have lower BEFs than commercial ballasts. For these reasons, in the preliminary TSD, DOE established a separate product class for ballasts that are designed for use in the residential sector.
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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.
Philips agreed that the FCC has more stringent EMI requirements for residential ballasts than commercial ballasts. The NEEA and NPCC commented that they have not seen evidence of any impact on efficiency due to the FCC EMI standards. Philips disagreed, stating that the FCC Class B requirements necessitate a more sophisticated EMI filter that results in greater losses than the commercial FCC requirements. Philips noted, however, these losses are offset by the difference in power factor requirements for the two market sectors. The power losses associated with the high power factor requirements in the commercial sector are greater than the losses associated with the more stringent EMI requirements in the residential sector. As evidence, Philips indicated that compliance data from the California Energy Commission (CEC) database indicates that some residential ballasts have higher BEFs than commercial ballasts. (Philips, Public Meeting Transcript, No. 34 at p. 134-6; NEEA and NPCC, Public Meeting Transcript, No. 34 at p. 135)
In this NOPR, DOE evaluated the impact of the more stringent EMI and less stringent power factor requirements on the BLE of residential ballasts. DOE tested several residential ballasts including models with the highest reported BLEs in the CEC database. DOE found that residential ballasts achieved the same efficiencies as their commercial counterparts. DOE believes that because these two ballast types can achieve the same efficiency, it is not necessary to establish a separate product class for residential ballasts, and therefore does not propose to do so in this NOPR.
i. Sign Ballasts
Ballasts designed for use in cold temperature outdoor signs have slightly different characteristics than those ballasts that operate in the commercial sector. First, sign ballasts are designed to operate in cold temperature environments—as low as negative 20 degrees Fahrenheit (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 regular 8-foot HO ballasts in the commercial sector. Thus, sign ballasts are inherently less efficient. In the preliminary TSD, DOE concluded that regular 8-foot HO ballasts cannot serve as substitutes for sign ballasts due to their inability to operate in cold temperature environments. For these reasons, DOE believes that cold temperature sign ballasts offer the consumer a distinct utility. Therefore, DOE established a separate product class for cold temperature sign ballasts in the preliminary TSD.
At the public meeting, DOE received several comments regarding which characteristics distinguish sign ballasts from regular ballasts designed to operate 8-foot HO lamps. OSI stated that a “cold temperature starting” label means the ballast can start a lamp at temperatures typically as low as −20 degrees F. (OSI, Public Meeting Transcript, No. 34 at pp. 116-117) Philips stated that there are two UL safety ratings for outdoor environments: type 1 outdoor which requires a basic moisture resistant enclosure, and type 2 outdoor which requires a hermetic enclosure to prevent all moisture from entering the ballast. However, the outdoor rating is not of concern regarding efficiency. Instead, Philips stated that a cold-temperature sign ballast delivers increased ignition voltages to the lamp, resulting in more resistive losses in the secondary transformer. If two high output ballasts have the same input power but one has a higher open circuit voltage, the ballast with the higher open circuit voltage will generally be less efficient. (Philips, Public Meeting Transcript, No. 34 at pp. 118-119, 139-140) The California Utilities, however, questioned whether cold-temperature sign ballasts were inherently less efficient because they noted some regular 8-foot HO ballasts are capable of starting lamps at temperatures of negative 20 degrees F or lower. (California Utilities, No. 30 at p. 2)
In this NOPR, DOE reviewed whether sign ballasts had different BLEs than regular 8-foot HO ballasts. Based on its test data, DOE found that sign ballasts did not achieve the expected BLE predicted by the power-efficiency relationship. Test data indicated these ballasts were not as efficient as regular 8-foot HO ballasts. DOE believes this is because sign ballasts are generally more robust and flexible. For example, sign ballasts are often specified to operate multiple-lamp-length combinations as well as both T12HO and T8HO lamps. As a result, a sign ballast is not optimized for the operation of a particular lamp whereas a regular 8-foot HO ballast is designed specifically for a T8HO or T12HO lamp. Regular 8-foot HO ballasts cannot always serve as substitutes for sign ballasts due to their lack of moisture seals and the more limited load specifications. For these reasons—and the associated differences in BLE compared to ballasts of similar lamp arc power—DOE proposes to establish separate a product class for sign ballasts.
j. Premium Features
During product research and manufacturer interviews, DOE found that several high-efficiency ballasts possess premium features such as a low temperature rating, type CC protection, lamp striation control, and small can size. Below DOE discusses each feature and considers whether to propose separate product classes for them.
Low Temperature Rating
DOE surveyed the market and found that all ballast types covered by this rulemaking have cold temperature ratings. This rating was typically associated with high-performance products; standard-efficiency ballasts were less likely to have this feature. Ballasts with low temperature ratings (−20 degrees F) can be used in applications such as parking garages, warehouses, and cold storage areas. In cold temperature environments, a fluorescent ballast must supply a higher starting voltage to establish the lamp arc. To create this higher voltage, the output transformer may have additional windings. In addition, components throughout the ballast must be able to withstand this higher voltage, even if only for a short amount of time. The additional windings and slightly different components may increase resistive losses.
DOE conducted research to determine how this rating might impact BLE. DOE was unable to find pairs of the same ballasts in which one had a cold temperature rating and one did not. Thus, DOE looked at groups of ballasts that achieved the same efficiency level based on its test data. The data showed no clear trend of a cold temperature rating impacting BLE. In most cases, DOE found the most efficient ballast in a particular category had the lowest rated starting temperature. Thus, DOE believes that the rated starting temperature of a ballast does not substantively impact overall efficiency. Therefore, DOE does not propose to establish a separate product class based on this feature.
Type CC
Arcing can occur when a lamp is not well connected to its socket or when it is removed from a fixture. To prevent this phenomenon, UL 1598 requires luminaires using instant start ballasts with bipin lamp holders to: (1) Include ballasts identified as Type CC, or (2) be constructed with lampholders marked with a circle “I.” Ballasts labeled as Type CC include extra circuitry to monitor frequency and remove power to the lamp if any unwanted arcing is detected. Additional circuitry has the potential to increase resistive losses.
A survey of the market found that ballasts with Type CC protection were available, although far fewer models were offered with this feature than without it. Analysis of catalog data found that ballasts with Type CC protection had slightly lower BEFs than ballasts without this feature. However, as UL 1598 can be met with different lampholders rather than adding circuitry within the ballast itself, DOE believes that Type CC protection does not provide a unique utility. Therefore, DOE does not propose to establish a separate product class for ballasts with a Type CC rating.
Lamp Striation Control
Lamp striations are a series of bright and dim regions in a fluorescent lamp and are considered an undesirable visual effect. Striations are most common when ballasts operate reduced-wattage, energy-saving lamps due to their different fill-gas composition. To prevent this effect from occurring, ballasts with lamp striation control usually have additional circuitry, which has the potential to increase resistive losses.
During manufacturer interviews, DOE learned that striation control is a necessary feature for ballasts that can operate reduced-wattage, energy-saving lamps. DOE observed that most ballasts already offer lamp striation control as a standard feature on both regular and high-efficiency product lines. Test data showed that the most efficient 4-foot MBP and 8-foot slimline ballasts already included lamp striation control. Thus, this feature does not prevent ballasts from reaching the highest efficiency levels identified by this rulemaking. Therefore, DOE does not propose to establish a separate product class for ballasts with lamp striation control.
Small Case Size
During interviews, DOE learned that smaller fixtures can have reduced material costs and higher optical efficiency. Optical efficiency describes the percentage of light emanated from the lamps that exits the fixture or reaches the desired surface. Therefore, ballast manufacturers are beginning to offer ballasts with smaller case sizes than what is offered as standard in the industry. A ballast with a small case size may use different components due to size restraints.
With a limited number of small case size ballasts commercially available, DOE is uncertain of the relationship between ballast enclosure size and efficiency. Furthermore, interested parties did not provide comments on the product class structure put forward in the preliminary TSD suggesting that DOE should not include ballasts of all enclosure sizes in the same product class. Based on this uncertainty and absence of contrary comments in the preliminary TSD, DOE proposes to include ballasts of all enclosure sizes in the same product class.
k. Summary
In summary, after evaluating all potential class-setting factors, DOE decided to establish separate product classes based on starting method, ballasts that operate 8-foot HO lamps, and ballasts designed for use in cold-temperature outdoor signs. Table V.1 summarizes the five product classes.
Table V.1—Fluorescent Lamp Ballast NOPR Product Classes
Description
Product class number **
IS and RS ballasts that operate
4-foot MBP lamps *
1
8-foot slimline lamps
PS ballasts that operate
4-foot MBP lamps *
2
4-foot MiniBP SO lamps
4-foot MiniBP HO lamps
IS and RS ballasts that operate
8-foot HO lamps
3
PS ballasts that operate
8-foot HO lamps
4
Ballasts that operate
8-foot HO lamps in cold temperature outdoor signs
5
* Includes both commercial and residential ballasts.
** Efficiency levels for all product classes are based on an equation.
3. Technology Options
In the technology assessment, DOE identifies technology options that appear to improve product efficiency. This assessment provides the technical background and structure on which DOE bases its screening and engineering analyses. DOE received one comment on the technology options identified in the preliminary TSD.
Philips agreed that ballasts that employ integrated circuits can have higher efficiencies but pointed out that the integrated circuit itself does not provide the efficiency, but rather integrated circuits are required by more efficient topologies. Philips also noted that integrated circuits are generally used with topologies that operate lamps in series rather than those that operate lamps in parallel. For parallel lamp operation, integrated circuits may be cost prohibitive. (Philips, Public Meeting Transcript, No. 34 at pp. 142-143)
In response, DOE agrees with Philips that in many cases inclusion of an integrated circuit does not increase efficiency on its own. DOE believes, however, that some integrated circuits directly influence BLE. For example, there is an integrated circuit that can increase ballast efficiency by replacing transistors in the direct current (DC) to alternating current (AC) inverter.
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Therefore, DOE proposes to maintain integrated circuits as a technology option in this NOPR. Regarding the high cost of an integrated circuit, DOE does not evaluate technology options based on cost. Rather, DOE calculates prices for each efficiency level in the engineering analysis and evaluates economic impacts on consumers, manufacturers, and the nation in subsequent analyses.
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International Rectifier.
International Rectifier Introduces Robust Self-Oscillating Electronic Ballast Lighting Control IC.
November 22, 2005. (Last accessed October 25, 2010.)
http://www.irf.com/whats-new/nr051122.html
B. Screening Analysis
As discussed in chapter 3 of the preliminary 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. DOE uses the following four screening criteria to determine which design options are suitable for further consideration in a standards rulemaking:
1.
Technological feasibility.
DOE will consider technologies incorporated in commercially available 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 compliance with the standard is required, 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.
10 CFR part 430, subpart C, appendix A, (4)(a)(4) and (5)(b).
For the preliminary TSD analysis, DOE consulted with industry, technical experts, and other interested parties to develop a list of technology options for consideration. DOE identified the following technology options that could improve the efficiency of a ballast:
Table V.2—Technology Options
Technology option
Description
Electronic Ballast
Use an electronic ballast design.
Improved Components
Transformers
Use grain-oriented silicon steel, amorphous steel, or laminated sheets of 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 the lamp has started.
Integrated Circuits
Substitute discrete components with an integrated circuit.
Starting Method
Use IS instead of RS as a starting method for lamp operation.
In the preliminary TSD, DOE screened out “using laminated sheets of amorphous steel” because this option increases the size and weight of the ballast and therefore is not “practicable to manufacture, install, and service.” Larger magnetic components could cause problems in installing and servicing ballasts because the ballast could be too large to fit in a fixture. DOE also stated that this technology option could have adverse impacts on consumer utility. Specifically, increasing the size and weight of the ballast could limit the places a consumer could use the ballast in a building.
The NEEA and NPCC agreed with DOE's decision to eliminate laminated sheets of amorphous steel as a design option. (NEEA and NPCC, No. 32 at p. 4) Earthjustice commented, however, that size and weight constraints for ballasts needed to be defined before DOE could screen out a technology option based on increased size or weight. (Earthjustice, Public Meeting Transcript, No. 34 at p. 148) Regarding size constraints, the NEEA and NPCC commented that new ballasts being installed during retrofits are significantly smaller than older ballasts being removed. They believe that technology options that would result in small increases in ballast size are not necessarily problematic for retrofits because new ballasts would still fit in the fixtures designed for older ballasts. (NEEA and NPCC, Public Meeting Transcript, No. 34 at pp. 148-149) Philips disagreed with the idea that increasing ballast size was not
problematic, commenting that newer ballasts have smaller cross-sections than older ballasts. Smaller ballasts have allowed luminaire manufacturers to decrease the size and material requirements of their luminaires while also improving optics. (Philips, Public Meeting Transcript, No. 34 at pp. 149-150) Acuity Brands agreed with Philips that newer luminaires are designed around the smaller sizes of current ballasts and confirmed that the smaller designs have improved optics. Acuity Brands stated that a few luminaires could accommodate an increase in the length of the ballast, but that many luminaires are already designed around the smaller size of current ballasts. (Acuity Brands, Public Meeting Transcipt, No. 34 at p. 150)
While older ballasts can be larger than newer ones, DOE's research indicates that the overall market trend is to create increasingly smaller ballast sizes for use in smaller and more highly optimized fixtures. As the trend toward smaller fixtures has existed for a number of years, new building designs are already incorporating smaller plenum spaces. Thus, an increase in the size of a ballast could affect its ability to be used in certain existing buildings or in new construction. Accordingly, DOE considers any increase in the existing footprint of a ballast to have adverse impacts on product utility and product availability.
Based on the above discussion, DOE maintains the elimination of laminated sheets of amorphous steel as a design option because it fails to meet the screening criteria of practicality to manufacture, install, and service, and adverse impacts on product utility. DOE considers the remaining technology options as design options in the engineering analysis.
C. Engineering Analysis
1. Approach
The engineering analysis develops cost-efficiency relationships to show the manufacturing costs of achieving increased efficiency. DOE has identified the following three methodologies to generate the manufacturing costs needed for the engineering analysis: (1) The design-option approach, which provides the incremental costs of adding to a baseline model design options that will improve its efficiency; (2) the efficiency-level approach, which provides the relative costs of achieving increases in energy efficiency levels, without regard to the particular design options used to achieve such increases; and (3) the cost-assessment (or reverse engineering) approach, which provides “bottom-up” manufacturing cost assessments for achieving various levels of increased efficiency, based on detailed data as to costs for parts and material, labor, shipping/packaging, and investment for models that operate at particular efficiency levels.
In the preliminary TSD, 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 solely on product lists or minimum cost data supplied by manufacturers. DOE conducted teardowns for unpotted ballasts and ballasts removed from a manufacturing facility before the potting procedure because potting (a tar-like fill material) inhibits visual observation of the components). Details of the engineering analysis are in NOPR TSD chapter 5. The following discussion summarizes the general steps of 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” primarily because of their high market volumes. DOE extrapolates the efficiency levels (ELs) from representative product classes to those product classes it does not analyze directly.
Select 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. For ballasts subject to existing Federal energy conservation standards, a baseline ballast is a commercially available ballast that just meets existing 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 efficiency. To determine energy savings and changes in price, DOE compares each higher energy-efficiency level with the baseline unit.
DOE tested a range of ballasts from multiple manufacturers to identify baseline ballasts and determine their BLE. Appendix 5C of the NOPR TSD presents the test results. DOE selects specific characteristics such as starting method, ballast factor, and input voltage to characterize the most common ballast at the baseline level. DOE also selects multiple baseline ballasts in certain product classes to ensure consideration of different ballast types and their associated consumer economics.
Select Representative Ballasts.
DOE selects commercially available ballasts with higher BLEs as replacements for each baseline ballast in the representative product classes by considering the design options identified in the technology assessment and screening analysis (NOPR TSD chapter 4). In general, DOE can identify the design options associated with each more efficient ballast. Where design options cannot be identified by the product number or catalog description, DOE determines the design options likely to be used in the ballast to achieve a higher BLE based on information gathered during manufacturer interviews. In identifying more efficient substitutes, DOE uses a database of commercially available ballasts. DOE then tests these ballasts to establish their appropriate BLE. Appendix 5C of the NOPR TSD presents these test results.
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 also includes two substitution cases in the engineering analysis. In the first case, the consumer is not able to change the spacing of the fixture and therefore replaces one baseline ballast with a more efficient ballast. This generally represents the lighting retrofit scenario where fixture spacing is predetermined by the existing installation. In this case, light output is generally maintained to within 10 percent of the baseline system lumen output.
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In the second case, the consumer is able to change the spacing of the fixture and either purchases more or fewer ballasts to maintain light output. This represents a new construction scenario in which the consumer has the flexibility to assign fixture spacing based on the light output of the new system. In this case, DOE normalizes the light output relative to the baseline ballast.
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In some instances (
e.g.,
when switching from T12 to T8 ballasts), light output exceeds these limits.
Determine Efficiency Levels.
DOE develops ELs based on two factors: (1) The design options associated with the specific ballasts studied; and (2) the maximum technologically feasible efficiency level. As discussed in section 0, DOE's efficiency levels are based on
test data collected from products currently on the market.
Conduct Price Analysis.
DOE generated a bill of material (BOM) by disassembling multiple manufacturers' ballasts that spanned a range of efficiency levels for some of the representative ballast types. DOE generated BOMs for two- and four-lamp T8 MBP IS, two-lamp T8 MBP PS, and 2-lamp, 8-foot slimline ballasts only because these ballasts were not filled with potting (a tar like substance). As stated previously, potting obscures the identification of individual components. The BOMs describe the products in detail, including all manufacturing steps required to make and/or assemble each part. DOE then developed a cost model that converts the BOMs for each efficiency level into manufacturer production costs (MPCs). By applying derived manufacturer markups to the MPCs, DOE calculated the manufacturer selling prices
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and constructed industry cost-efficiency curves. In those cases where DOE was not able to generate a BOM for a given ballast, DOE estimated an MSP based on the relationship between teardown data, blue book prices, and manufacturer-supplied MSPs.
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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.
a. Metric
One change to engineering approach from the preliminary TSD is the use of a new metric, BLE. Although DOE evaluates ballast efficiency in terms of the BLE metric in this NOPR, DOE received several comments regarding the relationship between ballast efficiency (as determined by the method proposed in the active mode test procedure NOPR) and ballast efficacy factor (BEF). OSI commented that there might be variation introduced into the BEF values due to the fact that it is correlated to BE, and both of these metrics have a distribution of error. (OSI, Public Meeting Transcript, No. 34 at p. 166-167) GE agreed that there was error in the correlation equations because a BEF for a 2-lamp 4-foot normal BF IS ballast could be correlated back to 93 percent efficiency, which is higher than any efficiency measured during NEMA's round robin testing. (GE, Public Meeting Transcript, No. 34 at p. 171) The NEEA and NPCC pointed out that it is not worth discussing the measurement variation associated with the ballast efficiency metric if correlating it to BEF introduces significant error. (NEEA and NPCC, Public Meeting Transcript, No. 34 at pp. 167-168) On the other hand, Philips commented that when considering only their products, the BEFs determined by the correlation equations were very close to the values obtained during testing in their own lab. (Philips, Public Meeting Transcript, No. 34 at p. 168)
DOE agrees with stakeholders that calculating BEF as a function of ballast efficiency could introduce error into the BEF value. In the separate test procedure SNOPR, however, DOE proposes to directly evaluate ballasts using BLE, and the measurement variation present in the BLE metric is significantly less than that which existed for BEF due to the elimination of photometric measurements. More detail regarding measurement variation can be found in section 0 of this notice or in the active mode test procedure SNOPR.
b. Test Data
In the preliminary TSD, DOE conducted an extensive amount of testing in support of the active mode test procedure. DOE provided this data in appendix 5C. The appendix contained various ballast characteristics such as starting method, maximum number of lamps operated, ballast factor, and other relevant characteristics. It also contained each ballast's BEF value as measured by the existing light-output based procedure and, for some ballasts, ballast efficiency as measured by the resistor-based method proposed in the active mode test procedure NOPR. DOE provided the raw data in the appendix so that interested parties could form their own conclusions regarding the two metrics. Throughout the rest of the chapters and appendices in the preliminary TSD, however, the BEF values used in the analysis were calculated using the correlation equations specified in the active mode test procedure NOPR. DOE received several comments related to the test data.
The California Utilities, ASAP, and the NEEA and NPCC commented on the discrepancy between the tested BEF values and the values contained in other sources—such as product catalogs and the CEC database. The California Utilities cited an example of the CEC database containing several ballasts with a reported BEF higher than the max tech BEF for the relevant product class in the preliminary TSD. The NEEA and NPCC noted that the largest discrepancies existed for IS and RS ballasts that operate T12 and T8 lamps. They concluded that these differences are due to manufacturers overstating catalog data. The NEEA and NPCC believe that this practice can adversely affect a building's lighting systems to the extent that it may not meet code requirements. (California Utilities, Public Meeting Transcript, No. 34 at pp. 157-8; ASAP, Public Meeting Transcript, No. 34 at p. 160; NEEA and NPCC, No. 32 at p. 2)
DOE agrees with the above-mentioned groups that the tested BEF values are different than those presented in catalogs or the CEC database. To gather BEF values for various ballasts, DOE could have consulted manufacturer catalogs, the CEC database, or its own database of tested ballasts. It became clear during DOE's initial testing that manufacturers were overstating BEF values in their catalogs. Thus, DOE sought an alternate source of information. The CEC maintains a public database of BEF values submitted to show compliance with state-level energy conservation standards. Philips pointed out that the CEC database should, by definition, contain test data from certified laboratories whereas catalogs do not. (Philips, Public Meeting Transcript, No. 34 at pp. 162-163) Although the California Utilities pointed out that the CEC database reported higher BEFs than the max tech level reported in the preliminary TSD, Philips commented that the highest candidate standard level (CSL) in the 2-lamp 4-foot MBP IS/RS product class was close enough to the higher values in the CEC database to be within the margin of error associated with the BEF metric. (Philips, Public Meeting Transcript, No. 34 at pp. 158-159)
While the CEC database represented an improvement over catalog data, commenters voiced concern with the information in the database. Philips commented that according to the CEC database, some manufacturers reported the same BEF for multiple ballast models. (Philips, Public Meeting Transcript, No. 34 at pp. 158-9) This indicates that all ballast models listed may not have been individually tested. In addition, Philips cited several other factors to consider when reviewing data from the CEC database, such as: Different manufacturers offering their most efficient ballasts at different efficiencies, measurement variation between testing labs; and measurement variation due to the test procedure itself. (Philips, Public Meeting Transcript, No. 34 at pp. 162-163)
DOE agrees that because each manufacturer likely tested their ballasts in different labs, the CEC database does not provide the best comparison. It is less meaningful for DOE to compare the BEF of a ballast tested in lab A to the
BEF of a different ballast tested in lab B, as measurement variation will exist between the two labs. DOE also acknowledges that there will be additional measurement variation within a lab due to tolerances allowed in the BEF test procedure. Although test procedure variation cannot be eliminated, the lab-to-lab variation can be eliminated by testing all ballasts in the same lab. Thus, in the preliminary TSD and this NOPR, DOE chose to rely on data obtained from its own testing. DOE acknowledges that manufacturers may use different labs for testing and certification purposes. Therefore, DOE accounts for both these sources of variation by decreasing efficiency levels by 0.8 percent. See section 0 for more details.
The California Utilities and the NEEA and NPCC noticed the discrepancy between DOE's test data contained in Appendix 5C and the values reported in chapter 5 of the preliminary TSD. They noted that the measured input power reported for a representative unit in the chapter 5 of the preliminary TSD did not match the input power listed in Appendix 5C for a ballast with the same BEF. In addition, all CSLs reported in the chapter 5 of the preliminary TSD for T5 standard output ballasts were lower than the BEFs reported in Appendix 5C. (California Utilities, No. 30 at p. 3; NEEA and NPCC, No. 32 at p. 5)
DOE acknowledges that the BEFs are not the same. The reason for the differences is that the data provided in Appendix 5C included DOE's test results for BEF and BE. BEF was measured according to the test procedure outlined in 10 CFR Part 430, Subpart B, Appendix Q—a procedure which includes photometric measurements. Ballast efficiency was measured according to the resistor-based method in the active mode test procedure NOPR. In chapter 5 of the preliminary TSD, DOE presented data based on its proposed test procedure—which included measuring a resistor-based ballast efficiency and using a correlation equation to calculate BEF. Thus, the BEFs presented in chapter 5 of the preliminary TSD are calculated values, whereas the BEFs presented in Appendix 5C are actual measured values.
DOE also received several comments regarding the ballasts it selected for testing. The NEEA and NPCC believed that DOE did not select any low- or high-BF products for testing. They therefore expressed concern that DOE had scaled efficiency levels to two-thirds of the product classes but had not obtained any test data for those classes. The NEEA and NPCC encouraged DOE to conduct additional testing to look at the relationsh
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