Energy Conservation Program: Test Procedures for Fluorescent Lamp Ballasts, 14288-14319 [2010-6374]
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Federal Register / Vol. 75, No. 56 / Wednesday, March 24, 2010 / Proposed Rules
DEPARTMENT OF ENERGY
10 CFR Part 430
[Docket No. EERE–2009–BT–TP–0016]
RIN 1904–AB99
Energy Conservation Program: Test
Procedures for Fluorescent Lamp
Ballasts
Office of Energy Efficiency and
Renewable Energy, Department of
Energy.
ACTION: Notice of proposed rulemaking
and public meeting.
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AGENCY:
SUMMARY: The U.S. Department of
Energy (DOE) proposes major revisions
to its test procedures for fluorescent
lamp ballasts established under the
Energy Policy and Conservation Act.
The proposed test method would
eliminate the use of photometric
measurements in favor of purely
electrical measurements with the goal of
reducing measurement variation. DOE
proposes a set of transfer functions to
convert the measured ballast electrical
efficiency to a ballast efficacy factor
value. These revisions, however, do not
concern the measurement of energy
consumption of ballasts in the standby
and off modes, which DOE addressed in
another rulemaking. DOE also
announces a public meeting to receive
comment on the issues presented in this
notice.
DATES: DOE will hold a public meeting
on Monday, April 26, 2010, beginning at
9 a.m. in Washington, DC. The agenda
for the public meeting will first cover
this test procedure rulemaking for
fluorescent lamp ballasts, and then the
concurrent energy conservation
standards rulemaking (see proposal in
today’s Federal Register) for the same
products. Any person requesting to
speak at the public meeting should
submit such a request, along with an
electronic copy of the statement to be
given at the public meeting, before 4
p.m., Monday, April 12, 2010.
DOE will accept comments, data, and
information regarding this notice of
proposed rulemaking (NOPR) before or
after the public meeting, but no later
than June 7, 2010. See section V, ‘‘Public
Participation,’’ of this NOPR for details.
ADDRESSES: The public meeting will be
held at the U.S. Department of Energy,
Forrestal Building, Room 8E–089, 1000
Independence Avenue, SW.,
Washington, DC 20585–0121. To attend
the public meeting, please notify Ms.
Brenda Edwards at (202) 586–2945.
Please note that foreign nationals
participating in the public meeting are
subject to advance security screening
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procedures. If a foreign national wishes
to participate in the workshop, please
inform DOE of this fact as soon as
possible by contacting Ms. Brenda
Edwards at (202) 586–2945 so that the
necessary procedures can be completed.
Any comments submitted must
identify the Fluorescent Lamp Ballast
Active Mode Test Procedures NOPR,
and provide the docket number EERE–
2009–BT–TP–0016 and/or Regulation
Identifier Number (RIN) 1904–AB99.
Comments may be submitted using any
of the following methods:
Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
E-mail: FLB–2009–TP–
0016@ee.doe.gov. Include the docket
number EERE–2009–BT–TP–0016 and/
or RIN 1904–AB99 in the subject line of
the message.
Postal Mail: Ms. Brenda Edwards,
U.S. Department of Energy, Building
Technologies Program, Mailstop EE–2J,
1000 Independence Avenue, SW.,
Washington, DC, 20585–0121. Please
submit one signed paper original.
Hand Delivery/Courier: Ms. Brenda
Edwards, U.S. Department of Energy,
Building Technologies Program, 6th
Floor, 950 L’Enfant Plaza, SW.,
Washington, DC 20024. Telephone:
(202) 586–2945. Please submit one
signed paper original.
For detailed instructions on
submitting comments and additional
information on the rulemaking process,
see section V, ‘‘Public Participation,’’ of
this document.
Docket: For access to the docket to
read background documents or
comments received, visit the U.S.
Department of Energy, 6th Floor, 950
L’Enfant Plaza, SW., Washington, DC
20024, (202) 586–2945, between 9 a.m.
and 4 p.m., Monday through Friday,
except Federal holidays. Please call Ms.
Brenda Edwards at (202) 586–2945 for
additional information regarding
visiting the Resource Room.
FOR FURTHER INFORMATION CONTACT: Ms.
Linda Graves, 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) 586–1851. E-mail:
Linda.Graves@ee.doe.gov. In the Office
of General Counsel, contact Ms. Betsy
Kohl, U.S. Department of Energy, Office
of the General Counsel, GC–71, 1000
Independence Avenue, SW.,
Washington, DC 20585. Telephone:
(202) 586–7796. E-mail:
Betsy.Kohl@hq.doe.gov.
For additional information on how to
submit or review public comments and
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on how to participate in the public
meeting, contact Ms. Brenda Edwards,
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) 586–2945. E-mail:
Brenda.Edwards@ee.doe.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Authority and Background
II. Summary of the Proposal
III. Discussion
A. Scope of Applicability
1. Ballasts Covered
2. Effective Date
B. Existing Test Procedure
C. Drawbacks of Existing BEF Test
Procedure
D. Efficiency Metric for Fluorescent Lamp
Ballasts
E. Test Procedure Improvement Options
1. Resistor-Based Ballast Efficiency
Correlated to Ballast Efficacy Factor
2. Lamp-Based Ballast Efficiency
Correlated to Ballast Efficacy Factor
3. Improvements to Existing Test
Procedure
4. Relative System Efficacy
F. Proposed Test Procedure
1. Test Conditions
2. Test Setup
3. Test Method
4. Calculations
5. Transfer Equations—General Method
6. Transfer Equations—Testing, Analysis,
and Results
7. Resistor Value Determination
8. Non-Operational Ballasts When
Connected to a Resistor
9. Existing Test Procedure Update
10. References to ANSI C82.2–2002
G. Burden to Conduct the Proposed Test
Procedure
H. Impact on Measured Energy Efficiency
I. Certification and Enforcement
IV. Procedural Issues and Regulatory Review
A. Executive Order 12866
B. National Environmental Policy Act
C. Regulatory Flexibility Act
D. Paperwork Reduction Act
E. Unfunded Mandates Reform Act of 1995
F. Treasury and General Government
Appropriations Act, 1999
G. Executive Order 13132
H. Executive Order 12988
I. Treasury and General Government
Appropriations Act, 2001
J. Executive Order 13211
K. Executive Order 12630
L. Section 32 of the Federal Energy
Administration Act of 1974
V. Public Participation
A. Attendance at Public Meeting
B. Procedure for Submitting Requests to
Speak
C. Conduct of Public Meeting
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
1. All Aspects of the Existing Test
Procedure for Active Mode Energy
Consumption
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2. Appropriate Usage of ANSI Standards
3. Method of Measurement for Dimming
Ballasts
4. Resistor-based Ballast Efficiency Test
Method
5. Alternative Approaches to Amending
the Test Procedure
6. Ballasts that do not Operate Resistors
7. Ballast Factor Variation Due to
Variations in Measured Lamp Power
8. Ballast Factor Binning
9. Transfer Equations
10. Scaling Transfer Equations
11. Burden on Manufacturers and Testing
Facilities
VI. Approval of the Office of the Secretary
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I. Authority and Background
Title III of the Energy Policy and
Conservation Act (42 U.S.C. 6291 et
seq.; EPCA or the Act) sets forth a
variety of provisions designed to
improve energy efficiency. Part A of
Title III (42 U.S.C. 6291–6309)
establishes the ‘‘Energy Conservation
Program for Consumer Products Other
Than Automobiles,’’ which covers
consumer products and certain
commercial products (all of which are
referred to below as ‘‘covered
products’’), including fluorescent lamp
ballasts (ballasts). (42 U.S.C. 6291(1)(2)
and 6292(a)(13))
Under the Act, the overall program
consists essentially of the following
parts: testing, labeling, and Federal
energy conservation standards. The
testing requirements consist of test
procedures, prescribed under EPCA,
that manufacturers of covered products
must use as the basis for certifying to
the DOE that their products comply
with energy conservation standards
adopted under EPCA and for
representations as to the efficiency of
their products. Also, these test
procedures must be used whenever
testing is required in an enforcement
action to determine whether covered
products comply with EPCA standards.
Section 323 of EPCA (42 U.S.C. 6293)
sets forth generally applicable criteria
and procedures for DOE’s adoption and
amendment of test procedures. It states,
for example, that ‘‘[a]ny test procedures
prescribed or amended under this
section shall be reasonably designed to
produce test results which measure
energy efficiency, energy use,* * * or
estimated annual operating cost of a
covered product during a representative
average use cycle or period of use, as
determined by the Secretary [of Energy],
and shall not be unduly burdensome to
conduct.’’ (42 U.S.C. 6293(b)(3)) In
addition, if DOE determines that a test
procedure amendment is warranted, it
must publish proposed test procedures
and offer the public an opportunity to
present oral and written comments on
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them. (42 U.S.C. 6293(b)(2)) Finally, in
any rulemaking to amend a test
procedure, DOE must determine ‘‘to
what extent, if any, the proposed test
procedure would alter the measured
energy efficiency * * * of any covered
product as determined under the
existing test procedure.’’ (42 U.S.C.
6293(e)(1)) If DOE determines that the
amended test procedure would alter the
measured efficiency of a covered
product, DOE must amend the
applicable energy conservation standard
accordingly. (42 U.S.C. 6293(e)(2))
As to fluorescent lamp ballasts
specifically, DOE must ‘‘prescribe test
procedures that are in accord with
ANSI 1 standard C82.2–1984 2 or other
test procedures determined appropriate
by the Secretary.’’ (42 U.S.C. 6293(b)(5))
DOE’s existing test procedures for
ballasts, adopted pursuant to these and
the above-described provisions, appear
at 10 CFR Part 430, Subpart B,
Appendix Q.
This test procedure rulemaking will
fulfill the periodic review requirement
prescribed by the Energy Independence
and Security Act of 2007. ‘‘At least once
every 7 years, the Secretary shall review
test procedures for all covered products
and—amend test procedures with
respect to any covered product * * * or
publish notice in the Federal Register of
any determination not to amend a test
procedure.’’ (42 U.S.C. 6293(b)(1)(A)
DOE invites comment on all aspects of
the existing test procedures for
fluorescent lamp ballasts for active
mode energy consumption that appear
at Title 10 of the CFR Part 430, Subpart
B, Appendix Q (‘‘Uniform Test Method
for Measuring the Energy Consumption
of Fluorescent Lamp Ballasts’’).
In a separate rulemaking proceeding,
DOE is considering amending energy
conservation standards for fluorescent
lamp ballasts (docket number EERE–
2007–BT–STD– 0016; hereinafter
referred to as the ‘‘fluorescent lamp
ballast standards rulemaking’’). DOE
initiated that rulemaking by publishing
a Federal Register (FR) notice
announcing a public meeting and
availability of the framework document
(‘‘Energy Efficiency Program for
Consumer Products: Public Meeting and
Availability of the Framework
Document for Fluorescent Lamp
Ballasts,’’) on January 22, 2008. 73 FR
3653. DOE has completed the
preliminary analyses for the energy
conservation standard rulemaking and
published in today’s Federal Register a
1 American
National Standards Institute.
National Standards for Fluorescent
Lamp Ballasts—Methods of Measurement.’’
Approved October 21, 1983.
2 ‘‘American
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notice announcing a public meeting and
availability of the preliminary technical
support document.
On February 6, 2008, DOE held a
public meeting in Washington, DC, to
discuss the framework document for the
fluorescent lamp ballast energy
conservation standards rulemaking
(hereinafter referred to as the ‘‘2008
public meeting’’). At that meeting,
attendees also discussed potential
revisions to the test procedure for active
mode energy consumption. All
comments on the fluorescent lamp
ballast standards rulemaking regarding
the measurement of active mode energy
consumption are discussed in section III
of this proposed rulemaking.
DOE has also completed a standby
mode and off mode test procedure. The
Energy Independence and Security Act
of 2007 (Pub. L. 110–140) amended
EPCA to require that, for each covered
product for which DOE’s current test
procedures do not fully account for
standby mode and off mode energy
consumption, DOE amend the test
procedures to include standby mode
and off mode energy consumption into
the overall energy efficiency, energy
consumption, or other energy descriptor
for that product. If an integrated test
procedure is technically infeasible, DOE
must prescribe a separate standby mode
and off mode energy use test procedure,
if technically feasible. (EPCA section
325(gg)(2)(A); 42 U.S.C. 6295(gg)(2)(A))
DOE published a final rule addressing
standby mode and off mode energy
consumption for fluorescent lamp
ballasts in the Federal Register on
October 22, 2009. 74 FR 54445.
II. Summary of the Proposal
In this notice of proposed rulemaking
(NOPR), DOE proposes to modify the
current test procedures for fluorescent
lamp ballasts to revise the scope of
applicability of this test procedure for
consistency with the ongoing
fluorescent lamp ballast standards
rulemaking, improve measurement
variability, and update the referenced
standards. DOE also proposes
provisions for manufacturers to submit
compliance statements and certification
reports for fluorescent lamp ballasts.
The following paragraphs summarize
these proposed changes.
In the preliminary technical support
document for the fluorescent lamp
ballast standards rulemaking, DOE
makes a preliminary determination of
the scope of coverage. Today’s proposed
test procedure includes specific
procedures for ballasts identified in the
preliminary determination of scope. If
the scope of coverage changes in the
fluorescent lamp ballast standards
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rulemaking, DOE will add or remove
provisions from the test procedure so
that it is consistent with the final scope
of coverage of standards. The
preliminary determination of scope
includes ballasts that operate multiple
numbers of lamps (one through six), all
values of ballast factor, and many
different lamp classes including 4-foot
medium bipin T8 and T12 lamps, 4-foot
T5 miniature bipin lamps, 8-foot single
pin slimline T8 and T12 lamps, and 8foot recessed double contact high output
T8 and T12 lamps. See section III.A.1
for further detail.
In addition to matching the scope of
coverage for the active mode test
procedure to the scope of coverage being
considered in the fluorescent lamp
ballast standards rulemaking, the
proposed amendments seek to reduce
the measurement variation inherent in
the existing test procedure. The existing
test procedure exhibits variation in
measurements of a similar magnitude to
the spread in efficiency within many
fluorescent lamp ballast product classes
analyzed in the preliminary
determination. The test measurement
variation can be attributed to reference
lamp variation, lamp operation
conditions, and ballast wiring. DOE
believes a test procedure with reduced
variation will allow for more precise
standard setting and certification,
compliance, and enforcement testing.
DOE’s proposed test method greatly
reduces the impact of reference lamps
on measurement variation. The method
calculates a ballast input power and
output power using only electrical
measurements and resistors that
simulate the load placed on a ballast by
a fluorescent lamp at a given operating
condition. Because a resistor can be
manufactured with much smaller
performance tolerances than a
fluorescent lamp, the resistor introduces
much less variation to the operating
characteristics of the ballast. This
revised test method delivers increased
precision, thereby allowing for greater
resolution. The procedure proposed in
this rulemaking measures ballast input
power and ballast output power and
then calculates ballast electrical
efficiency (output power divided by
input power). The ballast electrical
efficiency is then converted to ballast
efficacy factor (BEF) using a transfer
equation to maintain the reported metric
for energy efficiency as BEF for
consistency with use of BEF in 42
U.S.C. 6295(g)(5) and (g)(8). DOE
developed the transfer equation by
measuring several ballasts within a
product class for ballast efficiency (BE)
using the proposed BE test procedure
and for BEF using the existing test
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procedure, and then calculating a line of
best fit for the combined data. This
proposed method is hereafter referred to
as the resistor-based ballast efficiency
test procedure.
Prior to selecting the proposed test
method, DOE also considered three
other methods as potential
improvements in the revised test
procedure: (1) The lamp-based ballast
efficiency (correlated to BEF) method,
(2) the existing BEF method with
revisions to reduce variation; and (3) the
relative system efficacy (RSE) method.
DOE’s initial assessment of the lampbased ballast efficiency method, which
uses a lamp as a load, rather than a
resistor, indicated that, similar to the
resistor-based ballast efficiency method,
there could be significant improvements
by eliminating light output-based
measurements. However, adopting that
method would result in a test procedure
that was still susceptible to lamp-tolamp variability. DOE explored the
existing light-output-based test
procedure and found improvements
could be made without making
fundamental changes. DOE believes that
tightening tolerances on certain
specifications and clarifying looselydefined directions can reduce
measurement variation relative to the
existing test procedure for fluorescent
ballasts, but to a lesser extent than the
proposed resistor-based BE test
procedure. DOE found the RSE method
to exhibit larger variation than the
proposed resistor-based BE test
procedure because it uses the same
measurement techniques as the existing
test procedure.
In any rulemaking to amend a test
procedure, DOE must determine ‘‘to
what extent, if any, the proposed test
procedure would alter the measured
energy efficiency * * * of any covered
product as determined under the
existing test procedure.’’ (42 U.S.C.
6293(e)(1)) If DOE determines that the
amended test procedure would alter the
measured efficiency of a covered
product, DOE must amend the
applicable energy conservation standard
accordingly. (42 U.S.C. 6293(e)(2)) The
proposed test procedure would change
the measured energy efficiency of some
products relative to the existing test
procedure. To ensure that the standards
developed in the ongoing fluorescent
lamp ballast standards rulemaking
account for any changes to the test
procedure, DOE is developing the
standards based on the measured energy
efficiency generated by the active mode
test procedure proposed in this
rulemaking. As a result, DOE proposes
an effective date for this revised test
procedure, to be published as Appendix
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Q1 of 10 CFR part 430 Subpart B,
concurrent with the compliance date of
the fluorescent lamp ballast standards
rulemaking (approximately June 30,
2014). DOE plans to publish the final
rule establishing the procedures in
Appendix Q1 in the same rule
document as the final rule establishing
any amended standards.
DOE notes that ballasts that operate
one or two 40 or 34 watt (W) 4-foot T12
medium bipin lamps (F40T12 and
F34T12), two 75 W or 60 W 8-foot T12
single pin slimline lamps (F96T12 and
F96T12/ES); and two 110 W and 95 W
8-foot T12 recessed double contact high
output lamps (F96T12HO and
F96T12HO/ES) are covered by existing
energy conservation standards. 10 CFR
430.32(m). Until the proposed effective
date of the test procedure to be
published at Appendix Q1, these
ballasts should continue to be tested
using the existing test procedure to
determine compliance with existing
standards. DOE proposes in this NOPR
to make minor updates to the existing
test procedure, published at Appendix
Q to Subpart B of part 430. DOE would
update the reference to ANSI C82.2–
1984 in the existing test procedure
(appendix Q) to ANSI C82.2–2002.
Because DOE does not believe the
updated standard will impose increased
testing burden or alter the measured
BEF of fluorescent lamp ballasts, DOE
proposes that the amendments to
Appendix Q be effective 30 days after
publication of this test procedure final
rule. DOE notes that because use of the
test method in Appendix Q1 is not
appropriate for those ballasts that
cannot operate a resistor load bank,
manufacturers would continue to test
those ballasts using the test method set
forth in Appendix Q. In addition, the
test procedures for any ballasts that
operate in standby mode are also
located in Appendix Q.
DOE also proposes amending the
language in 10 CFR 430.62 to require
fluorescent lamp ballast manufacturers
to submit compliance statements and
certification reports. This provision
would also be effective 30 days after
publication of this test procedure final
rule. Ballast manufacturers would begin
to submit these documents to certify
compliance with existing fluorescent
lamp ballast energy conservation
standards using the test procedures at
Appendix Q one year following
publication of this final rule. Ballast
manufacturers would certify compliance
with any amended standards using the
test procedures at Appendix Q1
beginning one year following the
compliance date of the amended
standards.
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III. Discussion
A. Scope of Applicability
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1. Ballasts Covered
Today’s proposed test procedure is
applicable to the fluorescent lamp
ballasts covered in the preliminary
determination of scope outlined in the
preliminary technical support document
for the fluorescent lamp ballast
standards rulemaking. The preliminary
determination of scope is as follows:
(1) Ballasts that operate one, two, three,
four, five, or six straight-shaped lamps
(commonly referred to as 4-foot medium
bipin lamps) with medium bipin bases, a
nominal overall length of 48 inches, a rated
wattage 3 of 25 watts (W) or more, and an
input voltage at or between 120 volts (V) and
277 V;
(2) Ballasts that operate one, two, three,
four, five, or six U-shaped lamps (commonly
referred to as 2-foot U-shaped lamps) with
medium bipin bases, a nominal overall
length between 22 and 25 inches, a rated
wattage of 25 W or more, and an input
voltage at or between 120 V and 277 V;
(3) Ballasts that operate one or two rapidstart lamps (commonly referred to as 8-foot
high output lamps) with recessed double
contact bases, a nominal overall length of 96
inches and an input voltage at or between
120 V and 277 V;
(4) Ballasts that operate one or two instantstart lamps (commonly referred to as 8-foot
slimline lamps) with single pin bases, a
nominal overall length of 96 inches, a rated
wattage of 52 W or more, and an input
voltage at or between 120 V and 277 V;
(5) Ballasts that operate one or two straightshaped lamps (commonly referred to as 4foot miniature bipin standard output lamps)
with miniature bipin bases, a nominal length
between 45 and 48 inches, a rated wattage of
26 W or more, and an input voltage at or
between 120 V and 277 V;
(6) Ballasts that operate one, two, three, or
four straight-shaped lamps (commonly
referred to as 4-foot miniature bipin high
output lamps) with miniature bipin bases, a
nominal length between 45 and 48 inches, a
rated wattage of 49 W or more, and an input
voltage at or between 120 V and 277 V;
(7) Ballasts that operate one, two, three, or
four straight-shaped lamps (commonly
referred to as 4-foot medium bipin lamps)
with medium bipin bases, a nominal overall
length of 48 inches, a rated wattage of 25 W
or more, an input voltage at or between 120
V and 277 V, a power factor of less than 0.90,
and designed and labeled for use in
residential applications; and
(8) Ballasts that operate one, two, three,
four, five, or six rapid-start lamps (commonly
referred to as 8-foot high output lamps) with
3 The July 14, 2009 final rule establishing
amended energy conservation standard for general
service fluorescent lamps and incandescent
reflector lamps (74 FR 34080) adopted a new
definition for ‘‘rated wattage’’ that can be found in
10 CFR 430.2. Please see https://
www1.eere.energy.gov/buildings/
appliance_standards/residential/
incandescent_lamps.html for further information.
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recessed double contact bases, a nominal
overall length of 96 inches, an input voltage
at or between 120 V and 277 V, and that
operate at ambient temperatures of 20
degrees Fahrenheit (°F) or less and are used
in outdoor signs.
For the proposed test procedure in
this rulemaking, DOE would establish
particular test setups and calculations
depending on the product class. When
evaluating and establishing energy
conservation standards, DOE divides
covered products into product classes
by the type of energy used, capacity, or
other performance-related features that
affect efficiency, considering factors
such as the utility of the product to
users. (See 42 U.S.C. 6295(q)) The
fluorescent lamp ballast standards
rulemaking delineates product classes
based on the maximum number of
lamps operated by a ballast, ballast
factor, starting method, lumen package,4
lamp base, market sector, and lamp
length. Ballasts contained in the same
product class are subject to the same
energy conservation standards.
At the 2008 Framework public
meeting for the fluorescent lamp ballast
standards rulemaking, the Appliance
Standards Awareness Project (ASAP)
asked DOE to elaborate on how the
schedules for the fluorescent lamp
ballast energy conservation standard
and active mode test procedure
rulemakings interact. (ASAP,5 Public
Meeting Transcript, No. 9 at p. 29)
Because the fluorescent lamp ballast
standards rulemaking is in the
preliminary analysis phase of the
rulemaking process, the proposed scope
of coverage is still in draft form. To
ensure consistency in the scope of
coverage, DOE plans to publish the final
rule for this test procedure rulemaking
concurrently with the ballasts standards
rulemaking final rule (scheduled for
June 30, 2011). Concurrent publication
affords DOE the opportunity to
synchronize its test procedure with the
final scope of coverage for the
fluorescent lamp ballast standards
4 Lumen package refers to the quantity of light
generated by a lamp and ballast system. For
example, 8-foot RDC high output HO lamps and 4foot miniature bipin (MiniBP) HO lamps tend to
operate at higher currents than 8-foot single pin
(SP) slimline lamps and 4-foot MiniBP standard
output (SO) lamps, respectively. This difference in
operating design increases the quantity of light per
unit of lamp length.
5 A notation in the form ‘‘ASAP, Public Meeting
Transcript, No. 9 at p. 29’’ identifies a statement
made in a public meeting that DOE has received
and has included in the docket of this rulemaking.
This particular notation refers to a comment: (1)
Submitted during the public meeting on February
6, 2008; (2) in document number 9 in the docket
of this rulemaking; and (3) appearing on page 29 of
the transcript.
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rulemaking. If a ballast type 6 is
removed from the scope of coverage,
DOE will eliminate the pertinent test
procedures from the active mode test
procedure in the final rule. Conversely,
in the event additional ballasts are
added to the scope of coverage, DOE
will develop test procedures for these
ballasts and update the active mode test
procedure in a subsequent rulemaking.
For example, in the preliminary
analyses of the fluorescent lamp ballast
standards rulemaking, DOE’s
preliminary scope of coverage that does
not include ballasts capable of dimming.
As DOE invites comment on this in the
fluorescent lamp ballast standards
rulemaking, if DOE’s final scope of
coverage includes dimming ballasts,
DOE will need finalize test procedures
for these ballasts. DOE also invites
comment in this test procedure
rulemaking on suggested methods of
measuring the efficiency of dimmingcapable ballasts.
2. Effective Date
Because some of the test procedure
amendments proposed for Appendix Q1
will change measured efficiency and
therefore affect compliance with
existing standards, DOE proposes an
effective date of the revised test
procedure in Appendix Q1 to Subpart B
concurrent with the compliance date of
the energy conservation standards
prescribed by the fluorescent lamp
ballast standards rulemaking. DOE also
plans to publish the final rule
establishing the procedures in
Appendix Q1 in the same rule
document as the final rule establishing
any amended standards. In the
fluorescent lamp ballast standards
rulemaking, DOE is developing
standards that correspond with the
active mode test procedure proposed in
this rulemaking. The proposed active
mode test procedure would be used to
test ballast efficiency on or after the
compliance date of the fluorescent lamp
ballast standards rulemaking
(approximately June 2014). Until this
compliance date, fluorescent lamp
ballasts would continue to be tested
using the existing test procedure in
Appendix Q to determine compliance
with existing standards. Because the
modifications to Appendix Q (an update
to referenced industry standards) do not
affect the measured efficiency, DOE
proposes that they be effective 30 days
after publication of this test procedure
final rule. DOE notes that because use
6 Ballast type refers to a grouping of ballasts that
use the same starting method, and operate lamps of
the same diameter, lumen package, base type, and
length. For example, instant-start ballasts that
operate 4-foot medium bipin T8 lamps.
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of the test method in Appendix Q1 is
not appropriate for those ballasts that
cannot operate a resistor load bank,
manufacturers would continue to test
those ballasts using the test method set
forth in Appendix Q. In addition, the
test procedures for any ballasts that
operate in standby mode are also
located in Appendix Q.
Certification and compliance
procedures for fluorescent lamp ballasts
are also proposed in this rulemaking.
Because these provisions also do not
affect measured efficiency, DOE
proposes that they be effective 30 days
after publication of this test procedure
final rule. Accordingly, manufacturers
of fluorescent lamp ballasts would be
required to submit compliance
statements and certification reports to
certify compliance with existing
standards, using the test procedures at
Appendix Q, one year following
publication of the test procedure final
rule. Ballast manufacturers would
certify compliance with any amended
standards using the test procedures at
Appendix Q1 beginning one year
following the compliance date of the
amended standards.
B. Existing Test Procedure
The existing ballast test procedure (in
Appendix Q to Subpart B of 10 CFR part
430) used to determine the energy
efficiency of a fluorescent lamp ballast
is based on light output measurements
and ballast input power. The metric
used is called ballast efficacy factor
(BEF). BEF is the relative light output
divided by the power input of a
fluorescent lamp ballast, as measured
under test conditions specified in ANSI
standard C82.2–1984, or as may be
prescribed by the Secretary. 42 U.S.C.
6291(29)(C)
The BEF metric uses light output of
the lamp and ballast system instead of
ballast electrical output power in its
calculation of the efficiency of a ballast.
To measure relative light output, ANSI
C82.2–1984 directs the user to measure
the photocell output 7 of the test ballast
operating a reference lamp and the light
output of a reference ballast operating
the same reference lamp. Dividing
photocell output of the test ballast by
the photocell output of the reference
ballast yields relative light output or
ballast factor (BF). Concurrent with
measuring relative light output, the user
7 The photocell output of a light source is
measured in units of watts. Photocell output (watts)
is one method of measuring the light output of a
light source. Through the remainder of this
document, DOE refers to the output of a fluorescent
lamp as ‘‘light output,’’ even though the existing test
procedure indicates measuring the light with
photocell output.
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is directed to measure ballast input
power. BEF is then calculated by
dividing relative light output by input
power. A ballast that produces more
light than another ballast with the same
input power will have a larger BEF.
C. Drawbacks of Existing BEF Test
Procedure
In response to the framework
document for the fluorescent lamp
ballast standards rulemaking, DOE
received numerous written and verbal
comments from interested parties on the
usage of ballast efficacy factor as the
metric for describing the energy
consumption of fluorescent lamp
ballasts. The National Electrical
Manufacturers Association (NEMA)
commented that in previous
rulemakings regarding efficiency of
ballasts, the variation in BEF
measurements was less of an issue
because the range of efficiency in the
market was much larger. The spread in
the measured energy efficiency between
magnetic and electronic ballasts, for
example, was much larger than the
measurement variation inherent to the
existing test procedure. However, in the
current market, the spread in efficiency
between ballasts has a much smaller
range. (NEMA, Public Meeting
Transcript, No. 9 at p. 23, pp. 56–57)
NEMA commented that DOE should
change the metric away from BEF
because BEF measurements made in
accordance with the current fluorescent
lamp ballast test procedure (appendix
Q) can be shown to have a measurement
uncertainty on the order of 5 percent.
NEMA stated that when measuring the
same ballast at different test laboratories
with different examples of the same
reference lamp, the spread in test results
is similar to the range of T8 ballast BEFs
observed in the market today. NEMA
reasoned that in order to have
meaningful verification of a standard
DOE would need a metric that
delineates between the products on the
market. According to NEMA, the ballast
industry would be challenged to come
to consensus on a standard when so
much variation existed in the data.
(NEMA, Public Meeting Transcript, No.
9 at p. 23, pp. 35–36, pp. 56–58;
NEMA,8 No. 11 at p. 2)
DOE understands NEMA’s concerns
regarding the measurement uncertainty
related to the BEF measurement method
under the existing fluorescent lamp
8 A notation in the form ‘‘NEMA, No. 11 at p. 2’’
identifies a written comment that DOE has received
and has included in the docket of this rulemaking
or a written docket submission. This particular
notation refers to a comment: (1) Submitted by
NEMA; (2) in document number 11 in the docket
of this rulemaking; and appearing on page 2.
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ballast test procedure. The measurement
uncertainty would negatively impact
DOE’s ability to set standards for
ballasts, as it could be difficult to
distinguish between typical and highefficiency ballasts. DOE agrees with
NEMA’s description that the range of
efficiencies of ballasts available in the
market have in general decreased and
acknowledges the need for a test method
or metric that reduces systematic error
and generates more reliable test results.
Reduced variation in test procedure
calculations will allow for more precise
standard setting and certification,
compliance, and enforcement testing.
DOE is proposing a test procedure that
is designed to reduce systematic error
and enhance energy conservation
standard-setting capabilities.
NEMA also stated that lamp
manufacturing variations will create
variations in measured BEF values.
(NEMA, Public Meeting Transcript, No.
9 at p. 38; NEMA, No. 11 at p. 6; GE,
Public Meeting Transcript, No. 9 at p.
43) DOE agrees that a number of factors,
in particular the manufacturing
variability of lamps, can contribute to
producing this uncertainty. Due to lamp
manufacturing variability and in order
to reduce the performance variation
among those lamps selected for testing,
industry standards referenced in the test
procedure specify a narrower range of
operating conditions for reference
lamps. ANSI C82.1–1977 (referenced by
ANSI C82.2–1984) specifies that a
reference lamp must not vary more than
2.5 percent from the lamp parameters
given in the ANSI C78 Series (1972
edition and 1975 supplement) for
fluorescent lamp electrical
characteristics. Even this narrowed
variation allowed in the measured lamp
power, however, has a significant
impact on the variation in BEF. Changes
in measured lamp input power result in
disproportionate changes to the
numerator (ballast factor) and the
denominator (input power) in the BEF
metric. The percent change in ballast
factor is not as great as the percent
change in ballast input power for a
given change in measured lamp input
power. Consequently, the same ballast
will generate different values of BEF
when tested on reference lamps with
different measured power.
GE commented that in addition to
reference lamp manufacturing variation,
BEF can vary depending on the testing
facility. (GE, Public Meeting Transcript,
No. 9 at p. 43) DOE agrees that
deviations in test facility environmental
conditions can result in dissimilarities
in measured BEF. ANSI C82.2–1984
(incorporated in the existing test
procedure) allows ambient temperature
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to vary ±1 degrees Celsius (°C) from 25
°C. Through testing, DOE has shown
ambient temperature to have an effect
on BEF measurements. Specifically,
DOE found that changes in ambient
temperature as small as 1 °C resulted in
changes in BEF as much as 1.5 percent.
NEMA commented that the BEF
measurement requires photometric
measurements of a reference lamp
attached to the test ballast; thus, BEF
values cannot be compared across
ballasts that operate different lamp
types. A more appropriate metric would
not depend on lamp parameters or
requirements. (NEMA, Public Meeting
Transcript, No. 9 at p. 38, pp. 124–125;
NEMA, No. 11 at p. 6) NEMA also stated
that an alternative metric that is
comparable across all instant-start or
programmed-start ballasts and capable
of including lamp types yet to be
developed would be preferable to the
existing test procedure using BEF.
(NEMA, Public Meeting Transcript, No.
9 at pp. 76–77, p. 99) NEMA further
commented that some lamps do not
have ANSI standards governing their
operating characteristics. Considerable
variation in lamp operating conditions
exists among manufacturers for these
lamps because the industry has not
reached a formal consensus. (NEMA,
Public Meeting Transcript, No. 9 at pp.
76–77) NEMA suggested that DOE
consider an alternative metric based on
measuring ballast input and output
electrical power as discussed in section
III.E. (NEMA, Public Meeting
Transcript, No. 9 at p. 32, pp. 37–38)
DOE recognizes that BEF is not
comparable across all ballasts. BEF is
measured and calculated using
fluorescent lamps that vary in measured
power, thereby impacting ballast input
power. As a consequence, BEF is
dependent on lamp type.9 DOE plans to
organize the covered ballasts into
different product classes based on
consumer utility and energy efficiency
differences. Because DOE will consider
a separate energy conservation standard
for each of these product classes, the
test procedure must make comparisons
in energy efficiency possible within a
product class. However, the existing
BEF method does not allow for such
comparisons in all circumstances, as
explained in the following paragraph.
DOE recognizes that comparison across
product classes may also be useful for
consumers of fluorescent lamp ballasts.
DOE addresses this issue in its
9 Lamp type describes a grouping of lamps that
have the same length, lumen package, base type,
and diameter.
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discussion of the resistor-based BE
method in section III.E.1.
In the ongoing fluorescent lamp
ballast standards rulemaking, DOE has
tentatively determined there is no
distinct consumer utility difference
between T8 and T12 ballasts. As a
result, DOE is considering grouping T8
and T12 ballasts in the same product
class. Due to the difference in rated
powers of the reference lamps, however,
measured BEF values for T8 and T12
ballasts are not comparable. Because
DOE plans to subject certain T8 and T12
ballasts to the same energy conservation
standard (by including these ballasts in
the same product class), DOE agrees that
amendments to the existing active mode
test procedure to allow for greater
comparability across lamp types is
warranted. Therefore, in this notice DOE
proposes to revise the test procedure
such that the reported BEF for a T12
ballast will be comparable to the
reported BEF for a T8 ballast. These
proposed revisions are discussed in
further detail in section III.F.5.
DOE also agrees that the revised test
procedure and metric should be able to
encompass newly-developed lamps. The
industry has not come to consensus on
operating specification standards for
some of these new, reduced-wattage
lamps. Without consistent industry
standards for lamps, light-output-based
testing of BEF can vary greatly. DOE
proposes to test ballasts while operating
one representative load, characterizing
the lamp wattage most commonly
operated. The development and
marketing of new, reduced-wattage
lamps (with or without ANSI standards)
is not a concern because today’s test
procedure proposes to specify a
particular lamp and ballast combination
for testing. See section III.F.2 for
additional detail on DOE’s preliminary
decision to test ballasts while operating
a load characteristic of the most
common wattage lamp.
NEMA commented that lamp filament
heating introduces variability into the
existing BEF measurement (NEMA,
Public Meeting Transcript, No. 9 at p.
39). DOE agrees the existing ballast test
procedure is unclear on whether or not
electrode heating should be used in the
reference circuit. Electrode heating is
known to increase the efficiency of a
lamp, which means the same amount of
input power produces more light.
Consequently, the ballast factor of a test
ballast tends to be smaller if the
reference circuit uses electrode heating
compared to a reference circuit without
electrode heating. DOE agrees that the
current test procedure inserts some
variability into the measurement of BF
and consequently BEF due to the
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14293
apparent flexibility in the use of
reference circuit heating. In today’s
proposed test procedure, DOE addresses
this issue by specifying that electrode
heating should always be used in the
reference circuit for medium bipin,
recessed double contact, and miniature
bipin lamps. Electrode heating should
not be used in the reference circuit for
single pin lamps. As discussed in
section III.E.3, DOE believes specifying
whether electrode heating should be
used in the reference case limits
opportunity for introducing variation in
the test procedure. DOE also
understands that the efficiency change
due to electrode heating may vary from
lamp to lamp. DOE believes the
variation to be relatively small, though
it does not have quantitative data to
characterize this variation among lamps.
DOE invites comment on reasonable
techniques to reduce this source of
variation.
NEMA also commented that filament
heating should be taken into account in
comparison of ballasts with different
starting methods. (NEMA, Public
Meeting Transcript, No. 9 at p. 39) DOE
is aware starting method can impact the
measurement of ballast output power.
Ballasts that employ constant electrode
heating generate smaller BEF values
than ballasts without constant electrode
heating. Because BEF considers the light
output of a ballast, constant cathode
heating tends to decrease BEF because
some of the ballast output power is used
for purposes other than light
production. From a system viewpoint,
however, BEF reflects the loss in
lighting efficiency due to electrode
heating. Contrary to NEMA, DOE does
not believe that power dissipated by the
lamp electrodes should be included in
the measurement of output power as
this power is not used directly toward
the primary function of producing light.
DOE notes that it will consider setting
specific standards for ballasts that
employ electrode heating based on any
potential consumer utility differences 10
in the ongoing fluorescent lamp ballast
standards rulemaking.
NEMA also indicated T8 ballasts are
particularly impacted by measurement
10 In the fluorescent lamp ballast standards
rulemaking, DOE has tentatively determined that
while rapid-start ballasts do not offer distinct utility
compared to instant-start ballasts, programmed-start
ballasts do offer distinct utility compared to instantstart ballasts. DOE found that consumers frequently
use rapid-start ballasts as replacements for instantstart ballasts. Programmed-start ballasts, however,
can increase lamp lifetime for frequent on/off
cycling applications (e.g. for use with occupancy
sensors), providing consumer utility. Therefore,
DOE has tentatively determined to group rapid-start
ballasts and instant-start ballast in the same product
class and place programmed-start ballasts in a
separate product class.
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uncertainty because much of the T8
ballast market is high-frequency
electronic and T8 lamps are first
operated on a low-frequency (60-hertz)
reference ballast during BEF testing.
NEMA asserted that lamps increase in
efficiency when switching from low- to
high-frequency operation, but that all
lamps will not gain exactly the same
amount of efficiency. NEMA mentioned
it could provide data to show error of
several percent when the same ballast is
tested at different labs with different
lamps due to the high-frequency to lowfrequency comparison. (NEMA, Public
Meeting Transcript, No. 9 at p. 26, p. 39)
DOE agrees that random error is
introduced into the measurement and
calculation of BEF due to variation in
lamp efficiency gains when switching
from magnetic to electronic ballasts. In
general, when a lamp is run at highfrequency (electronic ballasts), the lamp
requires less power to produce the same
amount of light when compared to a
low-frequency (magnetic) ballast.
Electronic ballasts run at high
frequency, so they tend to display
higher BEF values than low-frequency
magnetic ballasts. Part of this difference
is due to the lamp operating at a lower
rated wattage (increased efficiency),
while the remainder is due to
improvements in the electrical
efficiency of the ballast. ANSI does not
specify high-frequency reference
conditions for 32W F32T8, 60W
F96T12/ES, 95W F96T12HO/ES, and
110W F96T12HO fluorescent lamps.
Another source of variation in the
existing test procedure is lamp and
ballast wiring for rapid- and
programmed-start ballasts. These
ballasts have two wires connected to the
pins on each end of the lamp. One of the
two wires supplies power to the lamp
arc, and the second provides power to
the electrode. Depending on which pin
the lamp arc wire is connected to, the
current supplied to the lamp arc will
encounter different amounts of
resistance. The difference in resistance
is due to the position on the lamp
electrode where the current starts and
finishes the lamp arc. When this
position (hotspot) is in the center of the
electrode, wiring differences do not
change the measured BEF. However,
when the hotspot is closer to one end or
the other of the electrode, the current
encounters varied resistances based on
the distance it must travel through the
electrode. Because ballast wires are not
identified as delivering energy to the
lamp arc or electrode and the position
of the hotspot is unknown, this source
of variation cannot be eliminated.
At the framework document public
meeting, DOE received comments that
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ballast manufacturers and independent
test labs use light output measurements
for calculating ballast factor for both
rapid-start and instant-start ballasts.
(GE, Public Meeting Transcript, No. 9 at
p. 73; Philips, Public Meeting
Transcript, No. 9 at p. 74) ANSI C82.2–
1984 suggests the usage of power
measurements for instant-start systems,
but common industry practice has been
the usage of light output measurements
for all ballast starting methods. Ballast
factor can be calculated either as a ratio
of test and reference circuit light output
or as a ratio of measured lamp power.
DOE notes that power measurements are
somewhat impractical to conduct on
ballasts that employ electrode heating
because these ballasts use two wires to
connect to a lamp electrode. The
presence of additional wires requires
more measurements to determine output
power which introduces error into the
results. DOE believes this technique
introduces significant error through
capacitance to ground and loading
effects on ballasts that use electrode
heating. As discussed in section III.E.3,
DOE believes that one way to reduce
this error would be to require lightoutput measurements to be used for all
ballast types.
D. Efficiency Metric for Fluorescent
Lamp Ballasts
A joint comment (hereafter the ‘‘Joint
Comment’’) submitted by ASAP, the
American Council for an EnergyEfficient Economy (ACEEE), the
Alliance to Save Energy (ASE), the
Natural Resources Defense Council
(NRDC), the Northeast Energy Efficiency
Partnerships (NEEP), and the Northwest
Power and Conservation Council
(NPCC) suggested that DOE consider a
metric other than BEF that permits
comparison between different lamp
wattages, ballast types, and numbers of
lamps operated by a ballast. (Joint
Comment, No. 12 at p. 1) NEMA also
recommended that DOE consider
changing the metric away from BEF and
toward an alternate metric. (NEMA, No.
11 at p. 2, pp. 11–12) NEMA suggested
if DOE cannot change the metric from
BEF, it should develop a test procedure
that requires the measurement of some
other metric unrelated to lamp lumen
output, such as ballast efficiency 11 or
relative system efficacy,12 and then give
11 Ballast efficiency aims to capture the electrical
efficiency of a ballast by eliminating usage of lamps
and photometric measurements in the test method.
Ballast efficiency equals ballast output power
divided by ballast input power. See section III.E.4.
12 Relative system efficacy provides a greater
range of comparability among ballast types in
comparison to ballast efficacy factor. RSE is based
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correlations to BEF so that BEF can still
be used in standard-setting. The New
York State Energy Research and
Development Authority (NYSERDA)
also recommended consideration of RSE
as an alternative metric. (NYSERDA, No.
9, pp. 27–28) NEMA asked if DOE might
accept a NEMA- and ANSI-supported
method of measuring BE, and
correlating BE measurements with BEF
values. (NEMA, Public Meeting
Transcript, No. 9 at p. 32, pp. 37–38)
The energy conservation standard is
specified using the metric of ballast
efficacy factor. 42 U.S.C. 6295(g)(5),
(g)(8) In this rulemaking, DOE proposes
measuring an alternate metric (ballast
efficiency) and using a set of correlation
functions so that BEF values can be
reported.
Acuity Brands Lighting also
commented that much of the
marketplace (end-users, lighting
designers, architects, and electrical
engineers) do not use the BEF metric
and may not have knowledge of it.
Acuity Brands indicated that luminaire
manufacturers are the primary users of
BEF values, using them in ballast
purchasing decisions for selection of
products compliant with regulations.
Acuity Brands also indicated that a
change in metric would not impact the
end-user as much it may impact
luminaire manufacturers. (Acuity
Brands Lighting, Public Meeting
Transcript, No. 9 at pp. 45–46) DOE
understands that the lighting design
process involves metrics other than
BEF. Lamp, ballast, and luminaire
combinations may be more or less
efficient when analyzed as a complete
system. End-users may make their
purchasing decisions from this system
viewpoint. DOE appreciates this
comment; however, DOE proposes the
use of transfer equations to convert BE
values to BEF for consistency with use
of the BEF metric in 42 U.S.C. 6295(g)(5)
and (g)(8).
The Joint Comment suggested that an
alternate metric should account for all
power loads served by the ballast,
including lamp arc power, cathode
power, and standby power
consumption. (Joint Comment, No. 12 at
p. 1) DOE understands the importance
of capturing all power loads served by
a fluorescent lamp ballast. DOE notes
that BEF does capture all power modes
listed by the Joint Comment (lamp arc
power and cathode power) except for
standby mode consumption. However,
DOE does not believe it is feasible to
incorporate standby power into the BEF
metric. The BEF metric relates light
on the BEF metric and creates minimal incremental
testing burden. See section III.E.4.
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output (relative to a reference system) to
input power. Ballasts that produce more
light using the same input wattage have
a larger BEF value. Standby mode
power, however, performs a different
function. Instead of using power for
light output, standby mode power is
used to facilitate activation or
deactivation of other functions (active
mode functions, i.e., light output) by a
remote switch. Because BEF is a
measure of light output divided by
input power and not energy
consumption, DOE does not believe it is
feasible to incorporate a measure of
standby mode energy use into the BEF
metric for active mode energy
consumption. While DOE’s preliminary
determination of the scope of coverage
in the fluorescent lamp ballasts
standards rulemaking does not include
ballasts capable of operating in standby
mode, if the scope of coverage changes
to include these ballasts, DOE will set
separate standby mode energy
conservation standards. Test procedures
for the measurement of standby mode
energy consumption for fluorescent
lamp ballasts can be found in Appendix
Q.
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E. Test Procedure Improvement Options
Given that alternative methods of
testing may result in reduced
measurement variation compared to the
existing test procedure for BEF, DOE
considered three new methods for
measuring the efficiency of a ballast and
one improved version of the existing
method. The first method is called the
resistor-based ballast efficiency method,
and requires first measuring an estimate
of ballast electrical efficiency when
operating a resistor load and then
converting the estimate to BEF. The
second method, called the lamp-based
ballast efficiency method, involves
measuring ballast efficiency using a
lamp as the ballast load and then
converting that BE to BEF. The third
method makes small changes to the
existing test procedure to improve the
precision of BEF measurement. The
fourth method measures relative system
efficacy, which is a variation of ballast
efficacy factor that is more comparable
across ballast types. While DOE
proposes the first method to be used as
the new test procedure for
determination of fluorescent lamp
ballast energy consumption, DOE is still
considering all of these options for
improvement of the test procedure and
therefore invites comments on all
alternative methods. The following
sections discuss the merits and
drawbacks of the four methods.
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1. Resistor-Based Ballast Efficiency
Correlated to Ballast Efficacy Factor
NEMA suggested at the framework
document public meeting for the
fluorescent lamp ballast standards
rulemaking that DOE should consider
using the BE metric. (NEMA, Public
Meeting Transcript, No. 9 at p. 32, pp.
37–38) Following the public meeting,
DOE participated in the NEMA task
force on ballast efficiency through June
2009. Through a series of conference
calls and meetings, DOE learned about
the resistor-based BE method and
participated in its development for fourfoot 32W MBP T8 normal ballast factor
ballasts. Using the data gathered and
methodology used in the NEMA task
force DOE then continued development
of the proposed test procedure for other
lamp types. DOE defined additional
resistor values, conducted extensive
testing for both BE and BEF in many
product classes, created transfer
equations so that BEF values could be
reported, and specified instrumentation
specifications in its development of the
proposed test procedure.
Ballast efficiency equals lamp arc
power divided by ballast input power.
Ballast efficiency aims to capture the
electrical efficiency of a ballast by
eliminating usage of lamps and
photometric measurements. Instead of
using a lamp and measuring light
output, the resistor-based BE method
uses resistors (a resistor load bank) to
simulate the lamp and makes an
electrical measurement of power
through the arc-resistor. Because a
resistor can be manufactured with much
smaller performance tolerances than a
fluorescent lamp, the resistor introduces
much less variation into the operating
characteristics of the ballast.
NEMA commented that a BE
measurement does not require lamp
electrical and photometric
measurements and, thus, is both easier
to execute and more accurate. NEMA
also stated that BE measurements have
lower measurement variation (on the
order of 1 to 2 percent) between test
facilities and do not require ANSI
standards for lamps that the ballast is
designed to operate. NEMA believes that
the ballast efficiency metric could be
used to compare all ballasts of a given
type (e.g., all instant-start ballasts, all
programmed-start ballasts), regardless of
the lamp types that the ballasts support
(including lamp types yet to be
developed). (NEMA, Public Meeting
Transcript, No. 9 at pp. 25–27, p. 36, pp.
76–77, pp. 100–101)
DOE agrees that ballast efficiency
would likely show less variation than
BEF and would allow for more equitable
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comparison among ballasts operating
different numbers of lamps or lamp
wattages. As discussed in section III.C,
much of the variation inherent in the
existing test procedure is due to
variation among reference lamps. The
resistor-based BE method reduces much
of the measurement variation due to
reference lamps by using a resistor load
bank to simulate the load placed on a
ballast during the measurement of input
and output power. Decreased
measurement variation allows for more
precise standard setting and
certification, compliance, and
enforcement testing. DOE acknowledges
that the BE metric would allow for
comparability across large portions of
the ballast market and that such
comparability provides benefit to
consumers. DOE proposes conversion to
BEF values, however, to measure energy
efficiency in a repeatable manner that
provides comparison for products in the
same product class and that is also
consistent with the statutory metric set
forth at 42 U.S.C. 6295(g)(5) and (g)(8).
DOE notes that use of ANSI standards
would be required for lamps in today’s
proposed test method because of the
need to define the ballast factor of a
ballast. Ballast factor is a necessary
input to the transfer equations between
BE and BEF as discussed in section
III.F.5. Because DOE proposes to test a
ballast using only one lamp type,
however, new lamps without ANSI
standards will not affect the test
procedure. The test procedure indicates
using currently-available and ANSIspecified lamps for the measurement
and calculation of ballast factor.
While NEMA commented that BE is
the best descriptor for instant-start
energy efficiency measurements, NEMA
also stated that electrode heating effects
should be taken into account for rapidstart and programmed-start systems
(NEMA, Public Meeting Transcript, No.
9 at pp. 37–39). The use of electrode
heating impacts the ratio of ballast input
power to power dissipated in the lamp
arc. Unlike instant-start ballasts,
programmed-start and rapid-start
ballasts use a portion of the ballast input
power to heat the electrodes. Ion
bombardment at the electrode (known
as sputtering) during the voltage pulse
deteriorates the lamp electrode over
time. Electrode heating reduces the
magnitude of the voltage pulse required
to start a lamp, thereby increasing lamp
lifetime for applications that require
frequent on and off switching. Because
the resistor-based BE test method
measures only the power across the
lamp arc resistor, measured output
power (lamp arc power) for ballasts
such as rapid-start and some
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programmed-start ballasts tends to be
smaller than the true total ballast output
power. Instant-start ballasts are less
affected by this issue because these
ballasts do not employ electrode
heating. From a lighting efficiency
perspective, the BE metric captures the
percentage of input power utilized for
lighting in the output stage. DOE
believes accounting for output power in
this way is useful because it does
indicate that instant-start ballasts use a
greater percentage of input power in the
direct production of light. The
fluorescent lamp ballast standards
rulemaking will consider the impact of
starting method on consumer utility and
will set energy conservation standards
accordingly.
DOE investigated the possibility of
measuring the total output power of a
ballast for the BE metric to include
electrode heating and lamp arc power.
To measure the total output power
across the entire resistor load bank, a
user needs to measure the electrode and
lamp arc voltage separately. DOE found
this measurement to introduce too much
error through capacitance to ground and
loading effects on the ballast during
high-frequency operation. Accordingly,
DOE has tentatively concluded that
reducing the number of measurements
to ensure a more accurate measurement
is the more reasonable approach.
Therefore, DOE proposes measuring the
voltage drop across the lamp arc resistor
and the input current to the resistor load
bank to calculate output power for the
ballast efficiency metric.
GE commented that ballast
manufacturers do not have control over
the performance of a lamp or the
measurement variation associated with
the usage of reference lamps in the
existing test procedure. GE noted that
the resistor-based BE metric allows
ballast designers to meet a specification
that is independent of lamp variation.
(GE, Public Meeting Transcript, No. 9 at
p. 43) DOE understands that ballast
designers would prefer ballast energy
efficiency to be measured
independently from a lamp. DOE agrees
that measured BEF is subject to
variations in measured lamp wattage
and intends to reduce this source of
variation. Today’s proposed test
procedure reduces the effect of reference
lamp variation on variation in BEF.
DOE also believes that industry is
starting to adopt BE method. NEMA has
already initiated the usage of BE in its
Premium Ballast Program, where BE is
used in an alternative verification
procedure. NEMA invited DOE and
other interested parties to participate in
the investigation process of the BE
metric. (NEMA, Public Meeting
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Transcript, No. 9 at p. 41, pp. 48–50, p.
53; NEMA, No. 11 at p. 3) In particular,
NEMA indicated that it has been
studying the measurement variation of
ballast efficiency through ballast testing
and wished to collaborate directly with
DOE. NEMA went on to mention that
lamp manufacturers as well as the
technical coordinators for ANSI C82.11
and the ANSI C82.11 Annex are
involved and that lamp manufacturers
are aware of the BE effort and have not
voiced any resistance to the concept.
(NEMA, Public Meeting Transcript, No.
9 at pp. 23–25, p. 42, p. 45, p. 48, pp.
54–55) ASAP stated that DOE’s
participation could speed the metrics
replacement process and that the
presence of non-industry experts would
increase ASAP’s confidence in the new
metric. (ASAP, Public Meeting
Transcript, No. 9 at p. 47, p. 49)
DOE participated in the NEMA task
force on ballast efficiency by taking part
in conference calls, providing technical
expertise, and participating in ballast
testing. NEMA measured ballast
efficiency using the resistor-based BE
method through a round robin activity
(involving multiple ballast
manufacturers and independent test
labs) for ballasts that operate 32W, 4foot medium bipin T8 lamps. Using
these data, the task force honed the
details of the test method and examined
the level of variation present in the data.
DOE’s involvement with the NEMA task
force was for the purpose of
participating in round robin testing.
Once testing was complete, DOE
finalized development of today’s
proposed test procedure.
DOE believes the resistor-based
ballast efficiency method reduces
measurement variation, in comparison
to the existing test method, to a greater
extent than RSE or the improved lightoutput-based test procedure. DOE
prefers a test procedure with reduced
variation as it will allow for more
precise standard setting and
certification, compliance, and
enforcement testing. DOE invites
comment on the effectiveness of the
resistor-based BE test method and its
expected improvement in measurement
variation.
2. Lamp-Based Ballast Efficiency
Correlated to Ballast Efficacy Factor
As an alternative to the resistor-based
ballast efficiency method (with results
correlated through transfer equations to
BEF) discussed in the previous section,
DOE also considered using a similar
method using a lamp (rather than a
resistor load bank) as the ballast load.
This arrangement has several potential
advantages over today’s proposed
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method. As ballasts are designed to
operate lamps, not resistors, testing the
efficiency of a ballast while operating a
lamp may provide for a more accurate
representation of power consumption
and efficiency than when operating a
resistor. For example, a lamp is a
dynamic load which changes
impedance in response to being
operated at different powers. In order to
account for this effect using the resistorbased ballast efficiency method, DOE
proposes using separate resistors for
different bins of ballast factor (as
discussed in section III.F.5). Using a
lamp load to test ballast efficiency,
would allow manufacturers to use a
single lamp to act as the appropriate
load for ballasts of all ballast factors.
Also, as discussed in section III.F.8,
DOE found that several ballasts are
incompatible with the resistor-based
method of testing ballast efficiency. In
order to provide a viable test procedure
for these ballasts, DOE proposes that
manufacturers use the light outputbased test to measure BEF directly.
Using lamp-based ballast efficiency
method could maintain a consistent
testing procedure across these ballast
types. Below is a brief summary of the
lamp-based ballast efficiency (correlated
to ballast efficacy factor) test method.
Similar to the resistor-based ballast
efficiency method, in the lamp-based
ballast efficiency method, input and
output power measurements would be
simultaneously taken by the technician
while the ballast is operating a lamp
(specified by the test procedure). To
calculate ballast efficiency, the
technician would divide the measured
output power by the measured input
power. More specifically, a lamp would
be seasoned at least 12 hours prior to
testing to ensure stable electrical
characteristics. The lamp and ballast
pairing would be selected based on
DOE’s determination of the most
common wattage lamp a ballast operates
and the maximum number of lamps a
ballast is designed to operate. The lamp
or lamps, selected for consistency with
the specifications in ANSI C78.81–2005,
would be mounted in a standard strip
fixture according to ANSI C82.1–2004
and ANSI C78.81–2005. Ballast and
output power would be measured using
a suitable power analyzer and current
probe. DOE would consider the same
specifications as proposed the resistorbased method as follows.
Instrumentation for current, voltage, and
power measurements would be selected
in accordance with ANSI C78.375–1997
Section 9, which specifies that
instruments should be ‘‘of the true RMS
type, essentially free from wave form
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errors, and suitable for the frequency of
operation.’’ Instrument performance
could be further specified within the
guidelines of the ANSI C78.375–1997
and ANSI C82.2–2002. Specifically,
current would be measured using a
galvanically isolated current probe/
monitor with frequency response
between 40 Hertz (Hz) and 20 MHz. In
addition, voltage would be measured
directly by a power analyzer with a
maximum 100 picofarad (pF)
capacitance to ground and have
frequency response between 40 Hz and
1 MHz.
Once the ballast is connected to the
lamp and fixture, the ballast would be
energized at its highest rated input
voltage and the lamp and ballast system
would be stabilized for up to one hour
(at least fifteen minutes) as determined
in ANSI C78.375–1997. Within one hour
of energizing the ballast and after the
lamp and ballast system have stabilized,
the technician would record the input
power and sum of the output powers
measured for each lamp. The technician
would then divide the total output
power by the input power to yield BE.
Finally, if DOE were to adopt the lampbased BE method, similar to the resistorbased BE method, DOE would establish
correlation relationships between BE
and BEF.
While DOE recognizes the several
advantages to the lamp-based BE
method (discussed earlier), DOE
tentatively believes that testing for BE
using resistor load instead of a lamp
load would result in reduced
measurement variation by eliminating
lamp-to-lamp variability. At this time,
DOE does not have test data to support
the validity of the lamp-based BE
method or for the generation of
appropriate transfer equations to
correlate lamp-based BE to BEF. DOE
requests additional information on this
alternative lamp-based BE method,
including repeatability and
reproducibility statistics and test data.
DOE also invites comment on the
burden that the lamp-based BE method
imposes for testing.
3. Improvements to Existing Test
Procedure
As an alternative to the ballast
efficiency methods (with results
correlated through transfer equations to
BEF), DOE considered modifying certain
aspects of the existing test procedure.
DOE believes that some of the
measurement variation inherent in the
existing test procedure can be reduced
without making fundamental changes.
The measurement variation in BEF can
be attributed to operating conditions,
electrode heating in the reference
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circuit, variation in measured power of
reference lamps, inconsistent output
power measurements in determining
ballast factor, and ambient temperature.
DOE investigated methods for
improving the requirements governing
these specifications.
The Illuminating Engineering Society
of North America (IESNA) Lighting
Measurements Testing & Calculation
Guide (LM) IESNA LM–9–1999
describes several options for operating a
reference lamp. DOE believes that the
industry is not uniform in its selection
of operating conditions, which results in
potential for varied BEF measurements.
Under Electrical Settings (section 8.0),
IESNA LM–9–1999 states
‘‘measurements may be taken with the
lamp operating and stabilized at the
specified input volts to the reference
circuit or, alternatively, measurements
may be taken with the lamp stabilized,
at the rated lamp power or at a specified
current.’’ These different operating
conditions can lead to varying reference
ballast light outputs for the calculation
of ballast factor. For example, if the
reference ballast operates the reference
lamp such that it produces less light, the
ballast factor and BEF of the test ballast
will increase. If ballast operators run the
reference circuit only at the specified
input voltage to the reference circuit,
DOE believes the test procedure will be
more reproducible between test
facilities because only a single operating
condition will be permitted. DOE
believes using the specified input
voltage to the reference circuit is the
best option because it is the most
common operating condition used by
industry and simplest to execute. DOE
also notes that the most recent test
procedure final rule for general service
fluorescent lamps also specifies testing
lamps at a constant and specified input
voltage. 74 FR 31829, 31834 (July 6,
2009).
The existing ballast test procedure is
unclear as to whether electrode heating
should be used in the reference circuit.
Electrode heating is known to increase
the efficiency of a lamp, which means
the same amount of input power
produces more light. Compared to a
reference circuit that employs electrode
heating, the ballast factor of the test
ballast tends to be larger if the reference
circuit does not use electrode heating.
An issue arises when instant-start
ballasts (no electrode heating) are
compared to a reference circuit that uses
electrode heating. The additional lamp
efficiency in the reference circuit
decreases the ballast factor and BEF for
an instant-start ballast compared to a
test method that uses no electrode
heating in the reference circuit.
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Although DOE acknowledges the effect
on BEF due to electrode heating in the
reference circuit for instant-start test
ballasts, it notes there are no industry
supported standards defining reference
circuit operating conditions for medium
bipin, miniature-bipin, and recessed
double contact lamps without electrode
heating. These lamps are specified in
ANSI standards according to operation
with reference ballasts using electrode
heating, but instant-start, rapid-start, or
programmed-start ballasts can operate
these lamps. One cannot simply remove
electrode heating from the circuit, as it
would alter the way the ballast operates
the lamp. Without industry standards,
DOE is unable to quantify the effect new
operating conditions might have on
ballast factor. DOE expects the effect on
BEF as a result of increased of lamp
efficiency in the reference circuit to be
relatively small and consistent among
all instant-start ballasts such that no
particular product is affected to a greater
or lesser extent than any other product.
DOE believes that requiring electrode
heating in the reference circuit for all
ballasts that operate medium bipin,
miniature-bipin, and recessed double
contact lamps would limit potential
variation between test facilities.
The existing test procedure specifies
that the reference lamp electrical
characteristics must not vary more than
2.5 percent from the specifications in
the ANSI C78 Series (1972 Edition and
1975 Supplement) for fluorescent lamp
electrical characteristics. While this
spread in operating conditions is less
than the general requirements for the
manufacturing of fluorescent lamps, it
still leads to much of the variation in
ballast input power and BEF. Tightening
the tolerance on lamp electrical
characteristics to ± 1 percent of the
specifications found in the ANSI C78
Series (1972 Edition and 1975
Supplement) would decrease
measurement variation due to
variability in measured lamp power.
DOE believes this change alone could
result in a large reduction in
measurement variation.
Decreasing the tolerance for ambient
temperature would also reduce
measurement variation. Differences in
ambient temperature change the
effective load a lamp places on a ballast
which affects BEF through changes in
the input power measurement. DOE
found that changes in ambient
temperature as small as 1 °C resulted in
changes in BEF as large as 1.5 percent.
DOE believes limiting ambient
temperature to 25 °C ± 0.5 °C would
reduce the measurement variation of
BEF.
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In response to the fluorescent lamp
ballast standards rulemaking framework
document, DOE also received several
comments related to the ANSI standard
referenced by the current fluorescent
lamp ballast test procedure. In written
and verbal comments, NEMA
acknowledged that ANSI C82.2–1984
cited in the current fluorescent lamp
ballast test procedure is intended only
for low-frequency ballasts and, thus, can
be confusing for technicians attempting
to test high-frequency electronic
ballasts. NEMA indicated that ANSI is
creating an update of ANSI C82.11–2002
and the associated C82.11–2002 Annex
(collectively known as ANSI C82.11
Consolidated-2002 13) that specifies an
appropriate measurement method for
high-frequency electronic ballasts.
(NEMA, Public Meeting Transcript, No.
9 at pp. 71–73; NEMA, No. 11 at p. 2)
DOE agrees that the ANSI C82.2–1984
cited in the current test procedure may
be confusing for high-frequency ballast
operation. Thus, DOE believes updating
ANSI C82.2–1984 to ANSI C82.2–
2002 14 and indicating the use of ANSI
C82.11–2002 and ANSI C82.11 Annex
would improve the clarity of the
electronic ballast test method. DOE
believes these changes would reduce
measurement inconsistencies but not
affect the measured energy efficiency of
the ballast. Specifically, DOE believes
the input power measurement of ANSI
C82.2–2002 reduces the interference of
instrumentation on the input power
measurement as compared to ANSI
C82.2–1984. DOE also believes,
however, that because modern
instrumentation does not significantly
interfere with input power
measurements, the differences between
the input power measurements of the
two test procedures are negligible. DOE
believes ANSI C82.2–2002 should be
used as the guide for measurement for
both high- and low-frequency ballasts.
For ballast operating conditions, DOE
believes ANSI C82.1–2004 should be
used for low-frequency (60 Hz) ballasts
and ANSI C82.11 Consolidated-2002 for
high-frequency ballasts. As discussed
later in section III.F.9, while DOE is
proposing to adopt the resistor-based BE
test method for compliance with any
future amended standards (using
transfer equations so BEF values can be
reported), DOE also proposes updating
the ANSI C82.2–1984 reference in the
existing test procedure for purposes of
13 American National Standards for Lamp
Ballasts—High Frequency Lamp Ballasts—
Supplements,’’ approved January 17, 2002.
14 ‘‘American National Standards for Lamp
Ballasts—Method of Measurement of Fluorescent
Lamp Ballasts,’’ approved June 6, 2002.
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compliance with the existing standards.
DOE invites comment on this issue.
In the existing test procedure, ballast
factor can be calculated either as a ratio
of test and reference circuit light output
or as a ratio of measured lamp power.
Requiring light output measurements to
be used for all starting methods in the
calculation of ballast factor should
reduce measurement variation and
increase the consistency and
comparability of results. In instant-start
systems, power measurements are
possible because fewer measurements
are required to measure lamp power.
For programmed-start and rapid-start
ballasts, two wires attach to each end of
the lamp, requiring additional voltage
and current measurements compared to
the instant-start system. During highfrequency operation, these extra
measurements make it difficult to
accurately capture lamp power due to
capacitance and loading effects on the
ballast. For this reason, light output
measurements are used for rapid-start
and programmed-start ballasts for the
measurement of ballast factor. Although
the existing test procedure indicates the
usage of power measurements for
instant-start ballasts, industry practice
has been to use light output
measurements for all starting methods.
DOE believes the use of light output for
the measurement of ballast factor for all
ballast types would render the values of
BF more consistent between testing
facilities.
Many ballasts are capable of operating
lamps with different lamp wattages. For
example, a ballast designed to operate
two four-foot 32W medium bipin (MBP)
T8 lamps can also operate two 30W,
28W, or 25W lamps. The BEF will vary
based on the rated wattage of the lamp
operated by the ballast. When a ballast
operates a lamp with a lower rated
wattage, BEF tends to increase due to
reduced ballast input power. In an
improved light-output-based test
procedure, DOE would specify
particular lamp-and-ballast
combinations for testing such that a
ballast is only tested while operating
one specific load. DOE believes this
method would mitigate testing burden
on manufacturers, provide a
representative measurement of ballast
energy consumption, and make the test
procedure more flexible to new lampand-ballast combinations. See section
III.F.2 for additional detail on using one
lamp (resistor) and ballast combination
for testing.
To test every lamp-and-ballast
combination, manufacturers would need
to purchase and maintain the requisite
number of reference lamps (or in the
case of the resistor-based BE method,
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resistors) for every lamp wattage that a
ballast can operate. In the example
mentioned above, this would require six
lamps (or resistors) in addition to the
two required for the 32W lamp. For
ballasts that operate more than two
lamps, the impact on manufacturers is
more significant. Furthermore, ANSI
standards do not exist for every reduced
wattage lamp. Because industry has not
reached a consensus regarding the
performance characteristics of each
lamp, DOE did not choose a resistor to
represent those lamps for which an
industry standard does not exist. Thus,
to mitigate the testing burden on
manufacturers, in the fluorescent lamp
ballast standards rulemaking, DOE is
considering setting standards based on
the ballast operating the most common
lamp wattage. Consequently, the test
procedure only requires one lamp-andballast combination to be tested in each
product class. See section III.F.2 for
additional discussion on why DOE
believes testing a ballast while operating
one representative load is a reasonable
means of determining the efficiency of
a ballast.
Similar to lamp wattage, ballasts are
designed to operate a certain maximum
number of lamps. Many ballasts can
operate fewer than the maximum
number of lamps. As discussed in
section III.F.2, DOE found testing a
ballast on all its possible loads (possible
numbers of lamps) was unnecessary.
DOE believes requiring testing of
fluorescent lamps ballasts while
operating the maximum number of
lamps for which the ballast is designed
would reduce testing burden on
manufacturers and produce
representative energy consumption
measurements. Therefore, this test
procedure would not require testing of
ballasts with every possible number of
lamps it can operate.
Some ballasts are also capable of
operating at multiple input voltages
(universal voltage ballasts). The existing
energy conservation standards require
ballasts to be tested at both 120 V and
277 V, which increases the testing
burden on manufacturers. The Joint
Comment suggested testing these multivoltage ballasts at 277 V for commercial
ballasts and 120 V for residential
ballasts. (Joint Comment, No. 12 at p. 5)
DOE believes that 277 V is the most
common input voltage for commercial
ballasts and that 120 V is the most
common for residential ballasts.
Therefore, DOE agrees with the Joint
Comment and has tentatively concluded
that a revised light-output-based test
procedure should test all universal
voltage commercial ballasts at 277 V
and universal voltage residential
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ballasts at 120 V.15 Ballasts capable of
operating only at a single voltage would
be tested at the rated ballast input
voltage.
DOE believes the aforementioned
improvements to the existing test
procedure would decrease measurement
variation. Furthermore, DOE does not
believe the changes would result in
significantly increased testing burden
for manufacturers. DOE believes,
however, that the proposed resistorbased BE method reduces measurement
variation to a greater extent than the
improved light-output-based test
procedure while also imposing only a
nominal increase in testing burden. DOE
invites comment on the effectiveness of
the improved light-output-based test
procedure to reduce measurement
variation and on the burden it imposes
for testing.
4. Relative System Efficacy
DOE considered the RSE metric as
another alternative to the existing BEF
test procedure. The RSE metric is
intended to normalize the existing
metric of BEF to rated lamp efficacy to
make it more comparable across ballasts
operating different numbers of lamps
and different lamp wattages. DOE
received comments suggesting use of the
RSE metric in response to the
framework document for the fluorescent
lamp ballast standards rulemaking.
NEMA, NYSERDA, and the Joint
Comment recommended the
investigation of RSE as a potential
replacement for the BEF metric.
According to comments, the relative
system efficacy metric would allow
comparisons to be made across different
ballast types, thereby enabling the usage
of fewer product classes in the energy
conservation standard. (NYSERDA,
Public Meeting Transcript, No. 9 at pp.
27–28, p. 75; NEMA, Public Meeting
Transcript, No. 9 at p. 100; Joint
Comment, No. 12 at pp. 6–7)
Relative system efficacy is equal to
BEF divided by 100 and multiplied by
total rated lamp power. RSE provides a
greater range of comparability among
ballast types in comparison to BEF.
Because RSE is based on the BEF metric,
it creates minimal incremental testing
burden over the existing test procedure.
RSE allows for improved comparison
among ballasts designed to operate
different number of lamp systems and
ballasts designed to operate different
lamp wattages. Lamp and ballast
15 ANSI C82.77–2002 specifies commercial
ballasts must have a power factor greater than 0.9,
while residential fluorescent ballasts (with an input
power below 120 W) must have a power factor of
0.5 or greater. Residential ballasts are designed and
labeled for use in residential applications.
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systems operating more lamps or higherrated-wattage lamps tend to have lower
BEF values. When these lower BEF
values are multiplied by
correspondingly larger total-rated-lamp
powers, the resulting value is more
comparable across different product
classes.
NEMA stated that it is attempting to
correlate the BE and RSE metrics to the
existing BEF metric. NEMA also stated
that the RSE metric is likely to be more
closely correlated to BE than the BEF
metric is to BE. (NEMA, Public Meeting
Transcript, No. 9 at p. 28, p. 33) DOE
believes NEMA may be correct in its
prediction that RSE is more closely
correlated to BE than BEF to BE.
However, DOE proposes the use of
transfer equations to convert BE values
to BEF for consistency with use of the
BEF metric in 42 U.S.C. 6295(g)(5) and
(g)(8). Therefore, DOE did not consider
correlating RSE to BE as an option for
this proposed test procedure.
Although the RSE metric improves on
the BEF metric through increased
comparability between product classes
with minimal incremental burden, DOE
believes RSE would ultimately have the
same measurement uncertainty
associated with the existing test
procedure or the improved light-output
based test procedure. In particular,
because RSE includes the usage of
reference lamps in test measurements,
RSE is based on the same varied inputs
as BEF. This rulemaking’s test
procedure revision is intended to reduce
measurement variation, and DOE
believes the proposed resistor-based BE
method reduces measurement variation
to a greater extent than RSE. DOE
invites comment on its tentative
decision not to adopt RSE as a potential
test method.
F. Proposed Test Procedure
In consideration of the comments and
analysis discussed above, today’s
proposed test procedure for measuring
active mode power consumption is the
resistor-based BE method, with results
correlated to BEF through the use of
transfer equations. This method consists
of the following steps: (1) Measurement
of input power to the ballast; (2)
measurement of simulated lamp arc
power to estimate ballast output power;
and (3) correlation of the ballast
efficiency metric to BEF. DOE believes
the resistor-based BE method results in
the largest reduction in measurement
variation over the existing test
procedure. Interested parties are invited
to comment on the proposed resistorbased ballast efficiency method, the
lamp-based ballast efficiency method,
the improvements to the BEF method,
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and the RSE method described in
section III.E, or on any other procedures
they believe would be appropriate.
In the sections 1 through 8 that
follow, DOE discusses the language
proposed for a new appendix Q1 to
subpart B of 10 CFR part 430 (hereafter
‘‘appendix Q1’’). The new appendix Q1
will contain the new test procedure that
correlates measured BE to BEF that will
be used for the purposes of compliance
with future amended standards. Section
9 describes an update to the existing test
procedure in appendix Q to subpart B
of 10 CFR part 430. The change to
appendix Q updates an industry
reference from ANSI C82.2–1984 to the
current ANSI C82.2–2002. DOE
proposes to create a separate appendix
Q1 for the proposed new test procedure.
DOE will retain the existing BEF test
procedure for compliance with existing
standards and, once amended standards
become effective, for use with ballasts
that cannot operate resistors. Section 10
discusses amendments DOE is
proposing regarding references to ANSI
C82.2–2002.
1. Test Conditions
DOE proposes that prior to
measurement, the ballasts would be
thermally conditioned at room
temperature (25 °C ± 2 °C) for at least 4
hours. During this conditioning period,
ballasts are not operating or energized.
Providing time for thermal conditioning
helps to generate reproducible results as
electrical products’ performance
characteristics tend to change in
response to temperature.
In addition, DOE proposes that
ballasts be tested using the electrical
supply characteristics found in section
4 of ANSI C82.2–2002 with the
following changes: (1) Ballasts capable
of operating at a single voltage would be
tested at the rated ballast input voltage;
(2) users of universal voltage ballasts
would disregard the input voltage
directions in section 4.1 of ANSI C82.2–
2002 that indicate a ballast capable of
operating at multiple voltages should be
tested at both the lowest and highest
USA design center voltage; and (3)
manufacturers use the most recent
revisions to the normative references
associated with ANSI C82.2–2002.
Instead of testing universal voltage
ballasts at the voltages indicated in
ANSI C82.2–2002, DOE believes that
testing ballasts at a single voltage is
more appropriate and less burdensome.
DOE believes 277 V is the most common
input voltage for commercial ballasts
and that 120 V is the most common for
residential ballasts. Therefore, DOE
proposes that all universal voltage
commercial ballasts be tested at 277 V
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and that universal voltage residential
ballasts be tested at 120 V.
2. Test Setup
The resistor load bank is a network of
resistors used to model the load placed
on a ballast by a fluorescent lamp. It
consists of five resistors, two for each of
the two electrodes and one for the lamp
arc. In a lamp, current can arc from one
electrode to the other from any two
positions (known as hotspots) on the
lamp electrodes. The position can be
different each time the current flow
alternates from one direction to the
other. The exact position determines the
effective resistance of the electrode by
determining the distance through which
current must travel in the electrode. If
the hotspots are at the ends of the
electrodes for an instant-start system,
the total electrode resistance will be
greater than if the hotspots are both at
the center of the electrode. When the arc
begins at the center of the electrode, the
length of the resistor is divided in half,
creating a circuit with two equivalent
resistors in parallel. The hotspots’
positions change over time, but the
design of the resistor load bank is
limited to one fixed position. Therefore,
DOE needed to select a position for the
hotspot, and model the resistor load
bank accordingly.
The selection of the hotspot position
was based largely on the design of
rapid-start and programmed-start
ballasts because the position of the
hotspot impacts the measured value of
BE. These ballasts use two wires to carry
ballast output power to the lamp. One
of these wires supplies power for
electrode heating, while the other
provides power for the lamp arc.
Electrode heating requires significantly
less power than the lamp arc, so
different levels of current and voltage
exist in the two ballast wires leading to
the lamp. Because these two wires are
not labeled by the respective loads they
serve, the user does not know which
wire is which. With two different
resistors, depending on which wire was
attached to the larger or smaller resistor,
the circuit would display two different
output powers. Therefore, DOE modeled
a lamp with the hotspot in the middle
of the electrode so that the resistance of
each path would be equal. Section
III.F.7 describes how DOE determined
resistor values for each type of lamp.
DOE proposes that the ballast be
connected to a main power source and
to the resistor load bank according to
the ballast manufacturer’s wiring
instructions. Where the wiring diagram
indicates connecting the ballast wire to
a lamp, the lead would be connected to
a resistor load bank. Ballast wire lengths
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would be unaltered from the lengths
supplied by the ballast manufacturer to
accurately capture the ballast efficiency
of the product in its original
manufactured form. Wires running from
the load bank to the power analyzer
would be kept loose or unbundled and
at a minimal working length, to reduce
error introduced to the ballast circuit
because of current bypassing the ballast.
DOE also proposes that the ballast be
connected to the resistor load bank
associated with the most common
wattage lamp the ballast is designed to
operate. In many cases, a ballast can
operate several reduced wattage lamps
in addition to the most common variety.
For example, ballasts designed to
operate four-foot MBP T8 lamps can
operate 32 W, 30 W, 28 W, and 25 W
lamps. Because ballasts operate
differently when connected to different
loads, a single resistor load bank is
unable to simulate the load induced by
all lamp wattages. To test every lampand-ballast combination, manufacturers
would need to purchase and maintain
the requisite number of reference lamps
(or in the case of the proposed method,
resistors and lamps) for every lamp
wattage that a ballast can operate.
Maintaining this number of lamps and
resistors would impose a significant
burden on manufacturers. Additionally,
ANSI standards do not exist for every
reduced wattage lamp. Because industry
has not reached a consensus regarding
the performance characteristics of each
lamp, DOE could not choose a resistor
to represent those lamps for which an
industry standard does not exist. Thus,
to mitigate the testing burden on
manufacturers, the proposed test
procedure would only require one lampand-ballast combination to be tested in
each product class. Therefore, DOE
proposes a test procedure based on the
ballast operating the most common
lamp wattage, resulting in a ballast
efficiency that represents the way the
product is primarily used in the market
and reducing the testing burden on
manufacturers.
DOE proposes to test fluorescent lamp
ballasts operating the maximum number
of lamps for which they are designed.
Many ballasts can operate fewer than
the maximum number of lamps they are
designed to operate. DOE compared the
BEF of a ballast operating the maximum
number of lamps for which it was
designed to a ballast operating the same
number of lamps but which was
designed to operate more lamps. For
example, a 4-lamp ballast operating two
lamps has a similar efficiency to a 2lamp ballast operating two lamps. When
operating the same number of lamps,
DOE found no correlation between the
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ballasts capable of operating different
maximum numbers of lamps and BEF.
Therefore, today’s proposed test
procedure requires testing of a ballast
only while it is operating the number of
resistor load banks equal to the
maximum number of lamps for which it
was designed.
In response to the framework
document for the fluorescent lamp
ballast standards rulemaking, the Joint
Comment stated that DOE should
establish performance requirements at
specific dimming levels (such as 100,
75, 50, and 25 percent) such that
dimming ballasts can be consistently
compared. (Joint Comment, No. 12 at p.
5) DOE agrees that a test procedure for
dimming ballasts should specify the
dimming level or levels at which ballast
efficiency should be tested. The
preliminary determination of the scope
of coverage in the fluorescent lamp
ballast standards rulemaking, however,
does not include dimming ballasts
because these ballasts have an overall
market share of about one percent and
are already used in energy-saving
systems. Thus, DOE did not include
them in the preliminary scope of
coverage. If DOE determines in the
fluorescent lamp ballast standards
rulemaking that the scope of coverage
should include dimming ballasts, DOE
will develop a test procedure for these
ballasts. DOE invites comment on
potential methods of measurement for
determining the efficiency of dimming
ballasts in the event dimming ballasts
are added to the scope of coverage in the
ongoing fluorescent lamp ballast
standards rulemaking.
Ballast wiring is different depending
on starting method. Instant-start ballasts
have only one wire connecting the
ballast to each end of the load, while
rapid-start and programmed-start
ballasts have two wires connected to
each end. The second wire in rapid-start
and programmed-start systems is used
for electrode heating. The resistor load
banks have two input wires connected
to two electrode resistors. In this test
procedure, DOE proposes that the single
output wire on an instant-start ballast be
shorted with the two input electrode
resistors to be consistent with current
industry practice. DOE notes that this
circuit topology is consistent with the
wiring of lamp-and-ballast systems for
bipin lamps. For example, a four-foot 32
W MBP T8 lamp has two pins that are
shorted together with the ballast output
wire using a jumper wire or an adapter.
A programmed-start ballast would not
need to be shorted together because the
ballast uses two wires for ballast output
between the ballast and the lamp.
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measurement for ballasts that operate
MBP, recessed double contact (RDC),
and miniature-bipin (miniBP) lamps
and Figure 2 shows placement for
ballasts that operate single pin (SP)
lamps.
3. Test Method
to increase in temperature. Following
the protocol established in ANSI C82.2–
2002, a lamp is first stabilized on a
reference ballast and then transferred to
a test ballast without being
extinguished. The output of a
fluorescent lamp remains relatively
constant (steady-state) when operated
under defined conditions. When these
defined conditions change (e.g.,
switching from a reference ballast to a
test ballast) the lamp output
ANSI C82.2–2002 specifies operating
the reference lamp with the test ballast
for less than 30 seconds to reduce the
effect of lamp restabilization on light
output and to give the ballast less time
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The power analyzer should have at least
one channel per lamp plus one
additional channel for the ballast input
power measurement.
Figure 1 shows the instrumentation
placement for the output power
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DOE proposes that the power analyzer
voltage leads be attached to the wires
leading to and from the main power
source for input voltage measurements
and that the current probe be placed
around the same wires for input current.
Federal Register / Vol. 75, No. 56 / Wednesday, March 24, 2010 / Proposed Rules
characteristics also change. This change
is not immediate, so by limiting the time
the test ballast is driving the reference
lamp, the reference lamp is kept as close
as possible to its reference conditions.
In addition, as a ballast operates, it
increases in temperature until it reaches
steady-state, though it may take more
than thirty minutes for a ballast to
increase from room temperature to
steady-state temperature. Limiting test
ballast operation to thirty seconds limits
the increase in ballast temperature. DOE
believes that over the course of thirty
seconds, the change in lamp operating
characteristics has a more significant
impact on light output than changes in
ballast temperature.
For the proposed resistor-based test
procedure, DOE found that one minute
of operation was required to provide
sufficient time to prepare for the data
capture while maintaining the ballast
and resistor load bank near room
temperature. DOE recognizes that it is
extending the time of operation
compared to the procedures outlined in
ANSI C82.2–2002, but it does not
believe the additional 30 seconds allow
for a significant increase in temperature
of the ballast or in the resistance of the
resistor load bank. As previously stated,
DOE believes the main driver in ANSI’s
decision to limit operation to 30
seconds was the change in lamp
operating characteristics, not ballast
temperature. DOE proposes that after
one minute of data capture the ballast be
switched off, so that the resistor load
bank duty cycle not exceed 50 percent
(that is, for every operational minute,
the load should be rested for one
minute) to minimize any issue with
thermal drift of the resistor load bank.
Thermal drift describes the
phenomenon of a resistor exhibiting a
different resistance in response to a
change in its internal temperature. DOE
believes that operating a resistor load
bank for one minute followed by one
minute of zero power will sufficiently
reduce the opportunity for the resistor
load bank deviate from its room
temperature resistance rating.
During data acquisition, the power
analyzer should measure the input
voltage and current and the output
voltage and current according to the
setup described in section III.F.2. DOE
proposes that the measured input
parameters be voltage (RMS 16), current
(RMS), power, and power factor
measured in accordance with ANSI
C82.2–2002. The measured output
16 Root mean square (RMS) voltage is a statistical
measure of the magnitude of a voltage signal. RMS
voltage is equal to the square root of the mean of
all squared instantaneous voltages over one
complete cycle of the voltage signal.
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parameters would include lamp arc
resistor voltage, current, and power.
Instrumentation for current, voltage, and
power measurements would be selected
in accordance with ANSI C78.375–
1997 17 Section 9, which specifies that
instruments should be ‘‘of the true RMS
type, essentially free from wave form
errors, and suitable for the frequency of
operation.’’ DOE proposes to further
specify instrument performance within
the guidelines of the ANSI C78.375–
1997 and ANSI C82.2–2002.
Specifically, current would be measured
using a galvanically isolated current
probe/monitor with frequency response
between 40 Hertz (Hz) and 20 MHz. In
addition, voltage would be measured
directly by a power analyzer with a
maximum 100 picofarad (pF)
capacitance to ground and have
frequency response between 40 Hz and
1 MHz.
In addition to making electrical input
and output measurements, today’s
proposed test procedure would also
require measurement of ballast factor for
the conversion to BEF. As discussed in
the ballast factor section of III.F.5,
ballast factor affects the apparent load
placed on a ballast by a lamp, and
consequently the measured BEF. BF
helps assign a ballast to a particular
product class, and it must be
determined empirically. DOE proposes
that ballast factor be measured in
accordance with ANSI C82.2–2002
section 12, with a few modifications.
Because the measurement of ballast
factor requires a reference lamp, DOE
proposes to adopt some of the
improvements to the existing test
procedure described in section III.E.3.
DOE believes specifying particular
electrical operating conditions,
clarifying in which circumstances
electrode heating should be used in the
reference circuit, and using light output
measurements instead of power
measurements for all ballasts will
reduce variation in the measurement of
BF. These changes are discussed in
greater detail below.
First, DOE notes that there are several
options for operating a reference lamp
as described in IESNA LM–9–1999. As
described in section III.E.3, DOE
proposes operating the reference lamp at
the specified input voltage to the
reference circuit. This method is the
simplest to execute and the most
common practice in industry. In
addition, DOE adopted this method in
the test procedure final rule for general
service fluorescent lamps. 74 FR 31829,
17 ‘‘American National Standard for Fluorescent
Lamps—Guide for Electrical Measurements,’’
approved September 25, 1997.
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31834 (July 6, 2009). Second, the
existing ballast test procedure is unclear
on whether electrode heating should be
used in the reference circuit for all
ballasts. As described in section III.E.3,
the presence or absence of electrode
heating in the reference circuit changes
the light output of the reference lamp on
the reference circuit, thereby changing
the measured value of BF. DOE
proposes that electrode heating be used
in the reference circuit for all ballasts
that operate bipin or recessed double
contact lamps (MBP, mini-BP, RDC).
Single-pin lamps should not use heating
in the reference circuit because these
ballasts are not capable of undergoing
electrode heating and are designed for
use with instant-start ballasts. Third,
although the existing test procedure
requires the usage of power
measurements for instant-start ballasts,
industry practice has been to use light
output measurements for all starting
methods. DOE proposes the use of light
output for the measurement of ballast
factor for all ballast types to make the
values of BF more consistent.
In addition, because DOE is
considering establishing a ballast
efficiency (correlated to BEF) test
procedure based on operation of a lamp
at the most common wattage, DOE
proposes that ballast factor also be
measured using the most common
wattage lamp. Ballast factor should be
measured using a reference lamp with
the nominal wattage indicated in
section III.F.7 for a given ballast type.
This nominal wattage also represents
the type of lamp the resistor load bank
simulates. Testing each ballast with
only the most common wattage lamp
produces test results that are most
representative of how the end users
operate fluorescent lamp ballasts.
DOE does not believe that the usage
of reference lamps for the purpose of
ballast factor determination creates
significant measurement variation. DOE
believes that variations in measured
lamp power affect ballast input power to
a much greater extent than ballast factor.
DOE invites comment on the variation
of ballast factor due to lamp
manufacturing variations and its effect
on the measurement variation of BE
converted to BEF.
4. Calculations
As described in Equation 1 below,
ballast efficiency is equal to output
power divided by input power.
BE =
Output Power
Input Power
DOE proposes to relate ballast efficacy
factor to the measured ballast efficiency
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through the empirically derived transfer
equations discussed in section III.F.5.
5. Transfer Equations—General Method
A system of transfer equations is
needed for correlating BE to BEF
consistent with 42 U.S.C. 6295(g). DOE
determined the transfer equations
empirically by testing ballasts using
both the proposed resistor-based BE and
existing BEF test methods. DOE then
plotted the results and computed a
linear regression to generate an equation
for BEF as a function of BE.
The existing test procedure for
fluorescent lamp ballasts allows for
ballasts to operate the reference lamps
under multiple operating modes. The
user may operate at constant lamp
current, voltage, or power. DOE used
constant input voltage to the reference
circuits for all of its BEF measurements
and for lamp resistor determination.
DOE believes this to be the most
common industry practice. Therefore,
the transfer equations that convert BE to
BEF reflect this decision.
Because factors like number of lamps,
ballast factor, starting method, and lamp
diameter affect the correlation between
BE and BEF, DOE considered individual
transfer equations for each product class
proposed in the fluorescent lamp ballast
standards rulemaking. The following
paragraphs discuss each of the factors
considered in the transfer equation
development process. DOE invites
comment on the transfer equations.
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Number of Lamps
The number of lamps operated by a
ballast has a disparate effect on the BE
and BEF metrics. BEF decreases for
ballasts operating increased number of
lamps. This is because ballast input
power increases (denominator) but the
ballast factor (numerator) does not
necessarily change. In contrast, BE
changes much less with varying
numbers of lamps because the
numerator and denominator change by
roughly proportional amounts.
Therefore, DOE parsed the data into
groupings based on the number of lamps
the ballast operates. Within these
groupings, DOE plotted BE versus BEF
and computed a linear regression to
generate an equation for BEF as a
function of BE.
Ballast Factor
For a given ballast type, ballast factor
tends to increase with increased ballast
input power. As ballast input power
increases, so does the ballast output
power and consequently the light
output. When a lamp is running at a
higher lamp current and power
(representative of a ballast with a high
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BF), lamp impedance decreases and the
apparent load the lamp places on the
ballast decreases. Therefore, a high BF
ballast operating a resistor that
simulates normal BF loading will
measure a higher BE than when running
a load of the appropriate resistance. To
account for this change in apparent load
with a resistor load bank, DOE
identified two options: (1) Modify
resistor values to account for the change
in apparent load due to lamp current
and BF; or (2) conduct all testing with
one resistor representing normal BF but
develop separate transfer equations for
three different ranges of ballast factors
(called bins).18
For option one, DOE would need to
determine resistor values for multiple
ballast factors for each ballast type. By
appropriately matching resistance to BF,
the test procedure would more
accurately model the change in apparent
load as a function of ballast factor. This
method would create an additional
burden on DOE at the outset of the test
procedure and an even more significant
burden on manufacturers. For example,
if in order to obtain measurable
improvement in testing accuracy
compared to option 2, DOE were to
assign a separate resistor value to each
ballast factor in the low ballast factor
product class for 4-foot T8 MBP ballasts,
DOE would need to specify four specific
resistor values. Specification of multiple
resistors based on ballast factor would
require the manufacturer to purchase
many more resistors than a test
procedure that used one resistor for all
ballast factors. To limit the impact on
manufacturers, DOE could determine
resistor values for two to three
commonly used BFs per ballast type and
establish bins around these ballast
factors. Keeping the number of BFspecific resistor values to a minimum
would decrease manufacturer burden
but still be more burdensome than
option 2 without offering any
appreciable improvement in testing
accuracy compared to option 2.
Option two specifies that ballasts of
all BFs are tested using the same resistor
value. Under this approach, ballasts
designed with a ballast factor different
than the ballast factor simulated by the
resistor load bank would be operating a
load that is non-representative of the
effective load placed on the ballast by a
real lamp. When testing ballasts of all
ballast factors using one resistor, all else
18 DOE proposes three ballast factor bins: low,
normal, and high. Low-ballast factor ballasts have
a ballast factor of 0.78 or less; ballasts designed
with a ballast factor between 0.78 and 1.10 are
normal-ballast factor; and high-ballast factor
ballasts were defined to have a ballast factor of 1.10
or higher.
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held constant, as BF increases,
measured BE will tend to increase as
well. Because the measured BE will not
accurately describe lamp arc power
divided by ballast input power, DOE
would need to create a scaling
technique. DOE can develop transfer
equations for converting measured BE to
BEF that correspond to bins of ballast
factors. Transfer equations could be
developed for particular ranges of BF so
that DOE can define different
relationships between measured BE and
BEF for different BF bins. DOE proposes
to use three bins because ballasts
currently offered in the market are
generally centered on three different
ballast factors. DOE proposes this option
because DOE believes it appropriately
balances accurate scaling based on
ballast factor with the reduced burden
on manufacturers as a result of using
one resistor for all ballast factors.
DOE notes that placing ballasts into
three bins based on BF results in the
measured efficiency of the ballasts with
the lowest BF in a particular bin to be
relatively smaller than the higher end of
the BF bin. Low BF ballasts tend to
measure a lower BE than a high BF
ballast when operating the same resistor
because of the effects of current on lamp
impedance discussed previously. This
could potentially encourage the
industry to produce ballasts at the upper
ends of these bins, as the associated
energy conservation standard would be
less stringent for the higher BF models.
DOE invites comment on this issue.
DOE considered two mitigating
strategies for reducing the market
interference resulting from specifying a
small number of BF bins. One possible
solution to this problem is to increase
the number of BF bins to reduce the
range in BF within a bin. DOE was not
able to assemble enough data based on
the ballast factors currently offered in
the market to increase the number of BF
bins. The ballast market tends to clump
around two to three popular ballast
factors, rendering empirical
determination of transfer equations for
intermediate ballast factors infeasible.
DOE also considered creating a
continuous function of BE as a function
of BF to normalize BE values for the
deviation in measured BE as a result of
running a ballast on unrepresentative
resistive load. These normalized BE
values would then be used as inputs to
a single transfer equation developed
from data obtained by testing ballasts
with the ballast factor that the resistive
load bank simulates. Similar to efforts to
increase the number of BF bins,
however, DOE found that the market
provided insufficient data for scaling.
With only two to three BFs in the data
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set, DOE could not be certain of the
relationship between BF and measured
BE.
Accordingly, based upon the above
considerations, DOE has tentatively
decided to proceed with option two by
developing three transfer equations
relating to three different ballasts factor
bins. DOE tested ballasts of high-,
normal-, and low-ballast factor varieties
for each ballast type to develop an
equation for BEF as a function of BE
specific to the ballast factor type (high,
normal, or low). DOE plotted BE and
BEF data for a given BF bin (high-,
normal-, or low-BF bins) and calculated
a linear regression to determine an
equation for BEF as a function of BE for
the given BF.
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Starting Method
Starting method also impacts the
correlation between BE and BEF.
Instant-start ballasts are in general more
efficient than rapid-start and
programmed-start ballasts. Because
instant-start ballasts do not supply
electrode heating, there are fewer losses
in the ballasts’ internal circuitry and
more of the output power goes to the
lamp arc. Rapid-start and programmedstart ballasts use part of their output
power to heat the lamp electrodes. In
short, starting method has nonlinear
effects on the light-output-based
measurement of BEF and the BE-based
measurement of BEF such that specific
transfer equations are required for each
starting method. Therefore, DOE parsed
the data into groupings based on starting
method. Within these groupings, DOE
plotted BE versus BEF and computed a
linear regression to generate an equation
for BEF as a function of BE. In the
fluorescent lamp ballast standards
rulemaking, DOE plans to consider
grouping instant-start and rapid-start
ballasts in the same product class and
programmed-start ballasts in a separate
product class based on consumer utility.
To create BEF values which are
comparable for product classes with
instant-start and programmed-start
ballasts, DOE proposes to use one
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transfer equation for converting BE to
BEF. This decision was made on the
basis that ballasts of the same BE should
have the same BEF.
Lamp Diameter
In the fluorescent lamp ballast
standards rulemaking, DOE has
tentatively determined that there is no
distinct consumer utility difference
between T8 and T12 ballasts. As a
result, DOE is grouping T8 and T12
ballasts in the same product class. At
the 2008 public meeting, NEMA
commented that BEF measurement
requires photometric measurements of a
reference lamp attached to the test
ballast; thus, BEF values cannot be
compared across ballasts that operate
different lamp types. (NEMA, Public
Meeting Transcript, No. 9 at pp. 124–
125; NEMA, No. 11 at p. 6) DOE agrees
that under the existing test procedure,
the BEF values measured for T8 and T12
ballasts are not comparable because the
reference lamps for these ballasts have
different rated power. Because certain
T8 and T12 ballasts would be subject to
the same energy conservation standard
(in the preliminary analysis of the
fluorescent ballast standards rulemaking
these ballasts are in the same product
class), DOE proposes to amend the test
procedure such that the reported T12
ballast BEF would be comparable to the
reported BEF for a T8 ballast. To
achieve this, DOE first developed
transfer equations based on data for T8
ballasts in a given product class. To
generate T12 ballast BEF values which
are comparable to T8 ballast BEF values,
DOE proposes using the transfer
equations developed for the relevant T8
ballasts to generate a BEF for T12
ballasts. As such, a T12 ballast BE value
would be used as an input to the
relevant T8 transfer equation. The T8
transfer equation would then output a
T12 ballast BEF value comparable to
BEF values for T8 ballasts. DOE made
this decision based on the assumption
that T8 and T12 ballasts with the same
BE should have the same BEF when
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reporting compliance with energy
conservations standards.
6. Transfer Equations—Testing,
Analysis, and Results
In the fluorescent lamp ballast
standards rulemaking, DOE has
preliminarily categorized ballasts into
70 product classes. In today’s test
procedure, DOE proposes to generate
separate transfer equations for each
product class. DOE targeted
representative product classes and
certain key product classes for extensive
testing with the expectation that scaling
would be required to establish transfer
equations for the remaining product
classes. DOE found strong correlation
between BE and BEF for the product
classes indicated in Table III.1.
DOE believes a linear relationship
should exist between BE and BEF for
ballasts of the same ballast factor,
starting method, number of lamps, and
lamp type. All ballasts under these
constraints send the same amount of
output power to a lamp, and therefore,
ballasts of different efficiency vary in
input power only. A more efficient
ballast requires less input power to
yield the same output power as a less
efficient ballast. Because both BE and
BEF are proportional to the same
expression (the inverse of input power),
a linear relationship should exist
between the two metrics. The test data
indicated a linear relationship between
BE and BEF, consistent with DOE’s
expectation. Although DOE tested
mostly electronic ballasts, which are
generally more efficient than their
magnetic counterparts, DOE believes the
linear relationship between BE and BEF
should exist across all values of BE and
BEF. As such, DOE developed linear
relationships between BE and BEF such
that the equation passed through the
origin (a BE of zero should correspond
to a BEF of zero). DOE developed
transfer equations in the form BEF =
slope * BE, establishing a slope for each
product class for the conversion of BE
to BEF.
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Based on the test data for 4-foot 32W
MBP T8 ballasts, DOE established
scaling ratios for ballast factor type,
number of lamps operated, and starting
method. For ballast factor type, DOE
calculated the ratio of the slopes for
product classes 2 and 14 compared to
product class 8 and used these ratios for
scaling all other normal ballast factor
product classes to their high and low
ballast factor counterparts. For starting
method, DOE employed a similar
technique to the ballast factor type
scaling method. DOE calculated the
ratio of the slopes for product class 8
and product class 26 to establish a
relationship between the combined
instant- and rapid-start ballast product
classes and the programmed-start
product classes. Again, DOE based
scaling for all other combined instantand rapid-start ballast product classes to
their programmed-start counterparts on
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this ratio between instant- and rapidstart ballast and programmed-start
ballasts. For number of lamps operated
by a ballast, DOE fit a power regression
equation to the slopes for 4-foot MBP T8
instant- and rapid-start normal BF
ballasts that operate one, two, or three
lamps (product classes 7, 8, and 9). DOE
used the equation to extrapolate the
slopes for products classes 10, 11, and
12 (four, five, and six lamps) DOE then
used the slopes for product classes 7
through 12 to establish ratios between
the slopes for ballasts that operate 1, 3,
4, 5, or 6 lamps and the slope for
ballasts that operate 2 lamps. Again,
DOE based scaling for all other 2 lamp,
normal BF ballasts to their 1, 3, 4, 5, and
6 lamp counterparts on the number of
lamps ratios generated with product
classes 7 through 12.
DOE focused its testing on 4-foot 32W
MBP T8 ballasts for the establishment of
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scaling ratios between BF, number of
lamps, and starting method. DOE tested
smaller quantities of ballasts from other
product classes, but found 8-foot T8 SP
slimline ballasts to have a strong
correlation between BE and BEF in the
available dataset. For 4-foot T5 SO, 4foot T5 HO, 8-foot RDC HO, and sign
ballasts, DOE developed a relationship
between total rated lamp power and the
slope of the line relating BE to BEF.
Total rated lamp power is the sum of the
rated lamp wattages (as defined in 10
CFR 430.2) operated by a particular
ballast. DOE fit a power regression
equation to the slopes and total rated
input powers for product classes 19 7, 8,
9, 49, and 50. Using this relationship,
DOE extrapolated and interpolated
slopes for product classes product
19 Product classes are identified by numbers in
Table III.1.
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Table III.2 lists the slope of the line
developed by DOE for converting
measured BE to BEF. Using the equation
BEF = slope * BE, measured BE is
converted to BEF.
2005.21 In some cases, the resistor value
was calculated from data published in
ANSI C78.81–2005. ANSI C78.81–2005
provides electrical characteristics of
lamps under either high-frequency or
low-frequency operation. For T8 and
T12 lamps, ANSI C78.81–2005 provides
electrical characteristics for lowfrequency operation, and for T5 lamps,
the standard provides characteristics for
high-frequency operation. Since
electronic ballasts operate in highfrequency, DOE needed to empirically
determine high-frequency resistances
for testing electronic ballasts that
operate T8 and T12 lamps. Since all T5
ballasts currently offered in the market
are electronic, DOE did not need to
empirically determine resistor values for
low-frequency operation. DOE
determined one resistor value per lamp
and did not modify the resistance based
The resistor-based BE method
requires a resistive load bank to be used
in place of a lamp during ballast
operation. Therefore, DOE determined 20
the resistive value corresponding to
different lamp types operating at
conditions described in ANSI C78.81–
20 DOE determined the simulated lamp arc
resistor value at BF = 0.88 for 4-foot 32 W MBP T8
ballasts because 0.88 was used in the NEMA round
robin and is the most common BF for this ballast
type.
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21 American National Standards for Electric
Lamps, Double-Capped Fluorescent Lamps—
Dimensional and Electrical Characteristics,’’
approved August 11, 2005.
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data to establish a slope. DOE invites
comment on its scaling technique for
number of lamps operated by a ballast,
starting method, ballast factor, and total
rated lamp power.
7. Resistor Value Determination
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classes 39, 40, 43 through 46, 53, 54,
and 65 through 70. DOE estimated the
slopes based on total rated lamp power
for these product classes because there
was insufficient correlation in the test
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on each individual different ballast
factors as discussed in section III.F.5.
Table III.3 lists the resistor values
determined empirically and those
specified by ANSI C78.81–2005.
TABLE III.3—SIMULATED LAMP RESISTOR VALUES
Nominal
lamp
wattage
Ballast type
Ballasts that operate one, two, three, four, five, or six
straight-shaped lamps (commonly referred to as 4-foot medium bipin lamps) with medium bipin bases, a nominal
overall length of 48 inches, a rated wattage of 25 W or
more, and an input voltage at or between 120 V and 277 V.
Ballasts that operate one, two, three, four, five, or six Ushaped lamps (commonly referred to as 2-foot U-shaped
lamps) with medium bipin bases, a nominal overall length
between 22 and 25 inches, a rated wattage of 25 W or
more, and an input voltage at or between 120 V and 277 V.
Ballasts that operate one or two rapid-start lamps (commonly
referred to as 8-foot high output lamps) with recessed double contact bases, a nominal overall length of 96 inches
and an input voltage at or between 120 V and 277 V.
Ballasts that operate one or two instant-start lamps (commonly referred to as 8-foot slimline lamps) with single pin
bases, a nominal overall length of 96 inches, a rated wattage of 52 W or more, and an input voltage at or between
120 V and 277 V.
Ballasts that operate one or two straight-shaped lamps (commonly referred to as 4-foot miniature bipin standard output
lamps) with miniature bipin bases, a nominal length between 45 and 48 inches, a rated wattage of 26 W or more,
and an input voltage at or between 120 V and 277 V.
Ballasts that operate one, two, three, or four straight-shaped
lamps (commonly referred to as 4-foot miniature bipin high
output lamps) with miniature bipin bases, a nominal length
between 45 and 48 inches, a rated wattage of 49 W or
more, and an input voltage at or between 120 V and 277 V.
Ballasts that operate one, two, three, or four straight-shaped
lamps (commonly referred to as 4-foot medium bipin
lamps) with medium bipin bases, a nominal overall length
of 48 inches, a rated wattage of 25 W or more, an input
voltage at or between 120 V and 277 V, a power factor of
less than 0.90, and that are designed and labeled for use
in residential applications.
Ballasts that operate one, two, three, four, five, or six rapidstart lamps (commonly referred to as 8-foot high output
lamps) with recessed double contact bases, a nominal
overall length of 96 inches, an input voltage at or between
120 V and 277 V, and that operate at ambient temperatures of 20 °F or less and are used in outdoor signs.
Lamp diameter and base
Low-frequency operation
resistance (ohms)
Electrode
(R1/2E)
Lamp Arc
(Rarc)
High-frequency operation resistance (ohms)
Electrode
(R1/2E)
Lamp Arc
(Rarc)
32
34
T8 MBP .......
T12 MBP .....
5.75
4.8
439
151
5.75
4.8
760
204
32
34
T8 MBP .......
T12 MBP .....
5.75
4.8
439
151
5.75
4.8
760
204
86
95
T8 HO RDC
T12 HO RDC
N/A
1.6
N/A
131
4.75
1.6
538
204
59
N/A*
876
N/A*
1256
60
T8 ................
slimline SP ..
T12 ..............
slimline SP ..
N/A*
313
N/A*
431
28
T5 Mini-BP ..
N/A
N/A
20
950
54
T5 Mini-BP ..
N/A
N/A
4
255
32
34
T8 MBP .......
T12 MBP .....
5.75
4.8
439
151
5.75
4.8
760
204
86
110
T8 HO RDC
T12 HO RDC
N/A
1.6
N/A
166
4.75
1.6
538
275
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MBP, Mini-BP, RDC, and SP represent medium bipin, miniature bipin, recessed double contact, and single pin, respectively.
* The resistor load bank representing 8-foot slimline single pin (SP) lamps does not have electrode resistors.
ANSI C78.81–2005 specifies the
electrode resistance a lamp
manufacturer must achieve through
design and manufacturing. Electrode
resistance is assumed to be the same for
low-frequency and high-frequency
operation because a tungsten filament
(lamp electrode) has high impedance at
both frequencies. For the lamp arc, the
ANSI standard provides electrical
characteristics for either high or low
frequency, depending on the lamp type.
By dividing lamp arc wattage by the
square of lamp current, DOE calculated
the resistance of the lamp arc resistor.
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Where lamp specification sheets do
not specify electrical characteristics for
the desired frequency of operation, DOE
determined resistor values empirically.
DOE empirically determined resistor
values for high-frequency operation of
32 W F32T8, 60 W F96T12/ES, 95 W
F96T12HO/ES, and 110 W F96T12HO
lamps. To determine the resistor values
empirically, DOE first measured the
light output of a reference lamp
operated by a reference ballast at low
frequency. Next, DOE connected the
same reference lamp to a reference
ballast operating at high frequency. By
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adjusting the voltage and current
provided to the lamp, DOE achieved the
same light output for high-frequency
operation as measured in low-frequency
operation. Then, DOE calculated the
apparent resistance of the lamp under
high-frequency operation using
measured current and voltage.
DOE notes that the measurement of
lamp arc power is slightly different than
actual lamp arc power due to the
empirical method of determining the
resistor value. DOE calculated the lamp
arc resistor using measured lamp
voltage and current at a predetermined
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light output. Part of this voltage is
applied across the lamp electrodes, so
the calculated lamp arc resistor value
tends to be slightly larger than reality.
DOE believes the increase in calculated
lamp arc resistance due to voltage drop
in the electrodes to be minimal in
comparison to the true lamp arc
resistance. Because DOE cannot
measure lamp electrode resistance
independently of the lamp arc, DOE was
unable to account for this problem.
Design of the fluorescent lamp prevents
DOE from making this measurement. In
addition, DOE does not identify the
resistance for a discrete electrode
resistor for ballasts that operate eightfoot slimline SP lamps because DOE
could not determine this value
empirically and ANSI C78.81–2005 does
not list the resistance. In effect, the
empirical resistor value determination
method includes the resistance of the
electrodes in the resistance of the lamp
arc resistor. Because the SP lamps only
have one pin, the electrodes and lamp
arc are all connected in series. When
DOE measured the resistance for the
‘‘lamp arc resistor,’’ DOE was unable to
separate the resistance of the electrodes
from the lamp arc due to design of a
fluorescent lamp. While it was
necessary to use electrode resistors in
medium bipin, miniature-bipin, and
recessed double contact lamps to allow
for an electrode heating circuit, singlepin lamps do not have this functionality
and are only designed for use with
instant-start ballasts. Therefore, the
lamp arc resistor for single-pin lamps
includes the effective resistance of the
entire lamp in a single resistor.
In addition, today’s proposed highfrequency lamp arc resistor values for
ballasts that operate one, two, three,
four, five, or six straight-shaped and Ushaped lamps with medium bipin bases,
a nominal overall length of 48 inches, a
rated wattage of 25 W or more, and an
input voltage at or between 120 V and
277 V are based on a ballast factor of
0.88. This value resulted from DOE’s
participation in the NEMA round robin
testing for the development of the
resistor-based BE method. DOE selected
a resistor for four-foot MBP ballasts that
represented a 0.88 ballast factor, which
is the most common ballast factor for
this ballast type. For other ballast types,
DOE used the electrical characteristics
in ANSI C78.81–2005 to develop highfrequency lamp arc resistor values.
These characteristics correspond to a
ballast factor of 1.0. DOE does not
believe that the quality of the test
procedure is affected by the use of a
different ballast factor for the 4-foot T8
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MBP ballasts. DOE invites comment on
this issue.
8. Non-Operational Ballasts When
Connected to a Resistor
During the testing process, DOE
targeted certain product classes
spanning ranges of ballast factor,
starting method, lamp type, and number
of lamps for extensive testing of both
BEF and BE. See section III.F.6 for
additional detail on the specific product
classes chosen for testing. DOE selected
several ballasts, ranging from one to
approximately fifteen, within each
chosen product class and tested three
samples of each ballast. As part of its
testing process for developing transfer
equations between BEF and BE, DOE
identified seven different ballast models
that did not operate the resistor load
bank. Therefore, DOE was therefore
unable to calculate these ballasts’ BE.
These ballasts were from different
product classes and different
manufacturers. In some cases, all three
examples of a particular ballast did not
operate a resistor, while in the other
cases only one or two ballast examples
did not operate a resistor. DOE also
confirmed that the ballasts did operate
properly when connected to fluorescent
lamps. DOE does not know specifically
why some ballasts do not operate
resistor load banks. It appears these
ballasts sensed the load was not a real
fluorescent lamp and turned off. For
ballasts found to not operate resistors,
DOE proposes that manufacturers use
the existing BEF test procedure found in
appendix Q. In addition, DOE is
considering an alternative proposal in
which it would include improvements
to the light-output-based test procedure
in the procedure for ballasts that do not
operate resistors. DOE believes this
would improve the precision of the BEF
measurements for ballasts that do not
operate resistors. The improved lightoutput-based test procedure could be
outlined as a separate section in
Appendix Q1 only for use with ballasts
that do not operate resistors. DOE
invites comment on why some ballasts
do not operate when connected to a
resistor load bank.
9. Existing Test Procedure Update
As discussed in III.E.2, DOE proposes
to update the reference in the existing
test procedure (appendix Q) from ANSI
C82.2–1984 to ANSI C82.2–2002, and to
specify that where ANSI C82.2–2002
references ANSI C82.1–1997, the
operator shall use ANSI C82.1–2004 for
testing low-frequency ballasts and shall
use ANSI C82.11–2002 for highfrequency ballasts. These changes to the
existing test procedure to modernize the
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ANSI reference would be effective 30
days following publication of the test
procedure final rule. DOE does not
believe the updated standard will
impose increased testing burden, nor
will it alter the measured BEF of
fluorescent lamp ballasts. Because the
active mode and standby mode test
procedures now both reference ANSI
C82.2–2002, DOE proposes to both
update the reference and reorganize the
test procedure outlined in appendix Q
for clarity.
10. References to ANSI C82.2–2002
As stated, in this NOPR DOE is
proposing amendments to the
fluorescent lamp ballast test procedure
that would incorporate references to
ANSI C82.2–2002 into appendix Q and
appendix Q1. In examining the ANSI
standard, DOE found that within ANSI
C82.2–2002 there are references other
ANSI standards. In particular, section 2
of ANSI C82.2–2002 states that ‘‘when
American National Standards referred to
in this document [ANSI C82.2–2002] are
superseded by a revision approved by
the American National Standards
Institute, Inc. the revision shall apply.’’
Revisions to these normative standards
could potentially impact compliance
with energy conservation standards by
changing the tested value for energy
efficiency. Therefore, DOE proposes to
specify the particular versions of the
ANSI standards that would be used in
conjunction with ANSI C82.2–2002.
DOE proposes to use ANSI C78.81–
2005, ANSI C78.901–2005, ANSI C82.1–
2004, ANSI C82.11–2002, and ANSI
C82.13–2002 in support of ANSI C82.2–
2002. All other normative references
would be as directly specified in ANSI
C82.2–2002. These specifications would
apply to the ANSI C82.2–2002
references in Appendix Q and to the
ANSI C82.2–2002 references in
Appendix Q1. DOE conducted testing in
development of today’s proposed test
procedure for Appendix Q1 in
accordance with the aforementioned
industry references.
G. Burden To Conduct the Proposed
Test Procedure
EPCA requires that ‘‘[a]ny test
procedures prescribed or amended
under this section shall be reasonably
designed to produce test results which
measure energy efficiency, energy use
* * * or estimated annual operating
cost of a covered product during a
representative average use cycle or
period of use * * * and shall not be
unduly burdensome to conduct.’’ (42
U.S.C. 6293(b)(3)). Today’s proposed
test procedure seeks to calculate the
efficiency of a ballast by computing the
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ratio of ballast output power (simulated
lamp arc power) to ballast input power.
This ratio is then converted to ballast
efficacy factor, the statutorily required
efficiency metric. DOE believes its
proposed method minimizes burden on
manufacturers while still achieving an
effective test procedure.
DOE sought to reduce manufacturer
burden wherever possible. As described
in section III.F.2, DOE chose to test each
ballast type using only one resistor load
bank instead of using a different load for
each ballast factor and number of lamps
associated with a ballast. DOE believes
this choice reduces burden on the
manufacturer. In addition, the proposed
test procedure requires no additional
measurement instrumentation beyond
what ballast manufacturers use for the
existing test procedure and other
general uses. The required measurement
of ballast factor is no different than the
procedure manufacturers already use for
reporting BF in their literature. The use
of resistors for measuring ballast input
power and lamp arc power, however,
does impose a small incremental burden
compared to the existing test procedure.
DOE estimates the initial purchase cost
of resistors for a two-lamp ballast to be
about $1000 to $2000 and does not
believe this additional materials burden
is unreasonable due to the low cost and
the fact that the materials cost can be
amortized over the span of many years
because the resistors maintain integrity
over a long lifespan. The test procedure
imposes a minimal incremental labor
burden of about 30 to 60 minutes for a
two-lamp ballast over the existing test
procedure to measure BE using the
ballast-resistor setup. For these reasons,
even for small ballast manufacturers,
DOE believes the testing burden is not
unduly burdensome. DOE invites
comment on this issue.
H. Impact on Measured Energy
Efficiency
In any rulemaking to amend a test
procedure, DOE must determine ‘‘to
what extent, if any, the proposed test
procedure would alter the measured
energy efficiency * * * of any covered
product as determined under the
existing test procedure.’’ (42 U.S.C.
6293(e)(1)) If DOE determines that the
amended test procedure would alter the
measured efficiency of a covered
product, DOE must amend the
applicable energy conservation standard
accordingly. (42 U.S.C. 6293(e)(2)) This
proposed active mode test procedure
does impact the reported BEF value.
Some products will test with higher or
lower efficiency based on the new test
procedure because of the transfer
equation between the measured
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parameters and the reported BEF value.
DOE is currently amending energy
conservation standards for fluorescent
lamp ballasts in the fluorescent lamp
ballast standards rulemaking. In that
rulemaking, DOE will consider
standards based on the measured
efficiency of the ballast in accordance
with the test procedure proposed in this
active mode test procedure rulemaking
consistent with 42 U.S.C. 6293(e)(2).
DOE will use test data that it collects in
the course of both this test procedure
rulemaking and the fluorescent lamp
ballast standards rulemaking when
setting energy conservation standards
for fluorescent lamp ballasts.
I. Certification and Enforcement
Ballast manufacturers are currently
not required to submit compliance
statements and certification reports. In
this rulemaking, DOE proposes to
require fluorescent lamp ballast
manufacturers to follow the certification
and enforcement requirements
summarized in subpart F of 10 CFR part
430.
DOE regulations at 10 CFR
430.62(a)(4) describe the format and
content of a certification report for
consumer products. DOE proposes to
include fluorescent lamp ballasts in the
list of products for which certification
reports are required (along with specific
energy consumption metrics). The
revised submission of data section will
indicate that ballast manufacturers
should report ballast efficacy factor and
power factor in certification reports. The
definition of ‘‘basic model’’ can be found
at 10 CFR 430.2; the fluorescent lamp
ballast test procedure can be found in 10
CFR part 430, subpart B, Appendix Q,
and the sampling plan can be found at
10 CFR 430.24(q). Manufacturers would
be required to follow all other
provisions of subpart F of 10 CFR part
430 for certification and enforcement
applicable to all covered ballasts.
DOE proposes that certification
statements and compliance reports be
submitted in accordance with the
existing energy conservation standards
one year after publication of this
rulemaking (publication approximately
June 30, 2011). In addition, DOE
proposes that certification statements
and compliance reports be submitted in
accordance with the revised energy
conservation standards and possible
expansion of scope of coverage one year
after these standards become effective
(effective date of standards
approximately June 30, 2014).
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IV. Procedural Issues and Regulatory
Review
A. Executive Order 12866
Today’s proposed rule has been
determined to not be a ‘‘significant
regulatory action’’ under Executive
Order 12866, ‘‘Regulatory Planning and
Review,’’ 58 FR 51735 (Oct. 4, 1993).
Accordingly, this action was not subject
to review under that Executive Order by
the Office of Information and Regulatory
Affairs (OIRA) of the Office of
Management and Budget (OMB).
B. National Environmental Policy Act
In this proposed rule, DOE proposes
test procedure amendments that it
expects will be used to develop and
implement future energy conservation
standards for ballasts. DOE has
determined that this rule falls into a
class of actions that are categorically
excluded from review under the
National Environmental Policy Act of
1969 (42 U.S.C. 4321 et seq.) and DOE’s
implementing regulations at 10 CFR part
1021. Specifically, this proposed rule
would amend the existing test
procedures without affecting the
amount, quality or distribution of
energy usage, and, therefore, would not
result in any environmental impacts.
Thus, this rulemaking is covered by
Categorical Exclusion A5 under 10 CFR
part 1021, subpart D, which applies to
any rulemaking that interprets or
amends an existing rule without
changing the environmental effect of
that rule. Accordingly, neither an
environmental assessment nor an
environmental impact statement is
required.
C. Regulatory Flexibility Act
The Regulatory Flexibility Act (5
U.S.C. 601 et seq.) requires preparation
of an initial regulatory flexibility
analysis for any rule that by law must
be proposed for public comment, unless
the agency certifies that the rule, if
promulgated, will not have a significant
economic impact on a substantial
number of small entities. As required by
Executive Order 13272, ‘‘Proper
Consideration of Small Entities in
Agency Rulemaking,’’ 67 FR 53461
(August 16, 2002), DOE published
procedures and policies on February 19,
2003, to ensure that the potential
impacts of its rules on small entities are
properly considered during the DOE
rulemaking process. 68 FR 7990. DOE
has made its procedures and policies
available on the Office of the General
Counsel’s Web site: https://
www.gc.doe.gov.
The Small Business Administration
(SBA) has set size thresholds for
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manufacturers of fluorescent lamp
ballasts that define those entities
classified as ‘‘small businesses’’ for the
purposes of the RFA. DOE used the
SBA’s small business size standards to
determine whether any small
manufacturers of fluorescent lamp
ballasts would be subject to the
requirements of the rule. 65 FR 30836,
30850 (May 15, 2000), as amended at 65
FR 53533, 53545 (September 5, 2000)
and codified at 13 CFR part 121. The
size standards are listed by North
American Industry Classification
System (NAICS) code and industry
description and are available at https://
www.sba.gov/idc/groups/public/
documents/sba_homepage/
serv_sstd_tablepdf.pdf. Fluorescent
lamp ballast manufacturing is classified
under NAICS 335311, Power,
Distribution, & Specialty Transformer
Manufacturing. The SBA sets a
threshold of 750 employees or less for
an entity to be considered as a small
business for this category.
To better assess the potential impacts
of the proposed standards for
fluorescent lamp ballasts on small
entities, DOE conducted a more focused
inquiry of the companies that could be
small manufacturers of fluorescent lamp
ballasts. During its market survey, DOE
used all available public information to
identify potential small manufacturers.
DOE’s research involved several
industry trade association membership
directories, product databases,
individual company Web sites, and
marketing research tools (e.g., Dunn and
Bradstreet reports) to create a list of
every company that manufactures or
sells fluorescent lamp ballasts covered
by this rulemaking. DOE reviewed all
publicly-available data and contacted
select companies on its list, as
necessary, to determine whether they
met the SBA’s definition of a small
business manufacturer of covered
fluorescent lamp ballasts. DOE screened
out companies that did not offer
fluorescent lamp ballasts covered by
this rulemaking, did not meet the
definition of a ‘‘small business,’’ or are
foreign owned and operated. Ultimately,
DOE identified approximately 15
fluorescent lamp ballast manufacturers
that produce covered fluorescent lamp
ballasts and can potentially be
considered small businesses.
The proposed rule includes revisions
to appendix Q and appendix Q1, as well
as certification reporting requirements.
The revisions to appendix Q update an
industry reference and do not change
the test method or increase testing
burden. The only difference between the
two test procedures relates to the
interference of testing instrumentation.
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Specifically, the input power
measurement of ANSI C82.2–2002
reduces the interference of
instrumentation on the input power
measurement as compared to ANSI
C82.2–1984. The vast majority of
companies and testing facilities,
however, already employ modern
instrumentation that does not
significantly interfere with input power
measurements. Thus, updating this
industry reference would not impose
additional financial burden in terms of
labor or materials. The proposed test
procedure in appendix Q1 imposes a
minimal incremental burden compared
to the existing test procedure and
industry practices. For a 2-lamp ballast,
the new procedure requires a small
increase in the labor burden of 30 to 60
minutes and a relatively small increase
in materials costs ($1000 to $2000 initial
purchase price). Finally, DOE estimates
that the proposed certification reporting
requirements would average 30 hours
per response.
To analyze the testing burden impacts
described above on small business
manufacturers, DOE identified small
business manufacturers of fluorescent
lamp ballasts included in the
preliminary scope of coverage
considered in the fluorescent lamp
ballast standards rulemaking as
described above. DOE sought to
examine publically available financial
data for these companies to compare
revenue and profit to the anticipated
testing burden associated with this
proposed test procedure. DOE
determined that all the identified small
business manufacturers were privately
owned, and as a result, financial data
was not publically available. Instead,
DOE estimated testing burden for a
small business with 0.1 percent market
share of covered fluorescent lamp
ballasts and revenue of approximately
one million dollars. DOE assumed that
this small manufacturer would sell
approximately 30 basic models of a
single ballast type. Based on the
assumptions stated in the previous
paragraphs, DOE estimated that the
annual testing costs for this small
business would be about $10,000,
constituting 1 percent of annual
revenue. Including the 30 hours per
response for certification reporting, DOE
believes this to be a small percentage of
revenue and not a significant impact.
On the basis of the foregoing, DOE
tentatively concludes and certifies that
this proposed rule would not have a
significant impact on a substantial
number of small entities. Accordingly,
DOE has not prepared a regulatory
flexibility analysis for this rulemaking.
DOE will provide its certification and
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supporting statement of factual basis to
the Chief Counsel for Advocacy of the
Small Business Administration for
review under 5 U.S.C. 605(b).
D. Paperwork Reduction Act
This rule contains a collection-ofinformation requirement subject to the
Paperwork Reduction Act (PRA) which
has been approved by OMB under
control number 1910–1400. Public
reporting burden for compliance
reporting for energy and water
conservation standards is estimated to
average 30 hours per response,
including the time for reviewing
instructions, searching existing data
sources, gathering and maintaining the
data needed, and completing and
reviewing the collection of information.
Send comments regarding this burden
estimate, or any other aspect of this data
collection, including suggestions for
reducing the burden, to DOE (see
ADDRESSES) and by e-mail to
Christine_J._Kymn@omb.eop.gov.
Notwithstanding any other provision
of the law, no person is required to
respond to, nor shall any person be
subject to a penalty for failure to comply
with, a collection of information subject
to the requirements of the PRA, unless
that collection of information displays a
currently valid OMB Control Number.
E. Unfunded Mandates Reform Act of
1995
Title II of the Unfunded Mandates
Reform Act of 1995 (UMRA) (Pub. L.
104–4) requires each Federal agency to
assess the effects of Federal regulatory
actions on State, local, and Tribal
governments and the private sector. For
proposed regulatory actions likely to
result in a rule that may cause
expenditures by State, local, and Tribal
governments, in the aggregate, or by the
private sector of $100 million or more
in any one year (adjusted annually for
inflation), section 202 of UMRA requires
a Federal agency to publish estimates of
the resulting costs, benefits, and other
effects on the national economy. (2
U.S.C. 1532(a), (b)) UMRA also requires
Federal agencies to develop an effective
process to permit timely input by
elected officers of State, local, and
Tribal governments on a proposed
‘‘significant intergovernmental
mandate.’’ In addition, UMRA requires
an agency plan for giving notice and
opportunity for timely input to small
governments that may be affected before
establishing a requirement that might
significantly or uniquely affect them. On
March 18, 1997, DOE published a
statement of policy on its process for
intergovernmental consultation under
UMRA. 62 FR 12820. (This policy is
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also available at https://www.gc.doe.gov).
Today’s proposed rule contains neither
an intergovernmental mandate, nor a
mandate that may result in the
expenditure of $100 million or more in
any year, so these requirements do not
apply.
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F. Treasury and General Government
Appropriations Act, 1999
Section 654 of the Treasury and
General Government Appropriations
Act, 1999 (Pub. L. 105–277) requires
Federal agencies to issue a Family
Policymaking Assessment for any
proposed rule that may affect family
well-being. Today’s proposed rule
would not have any impact on the
autonomy or integrity of the family as
an institution. Accordingly, DOE has
concluded that it is unnecessary to
prepare a Family Policymaking
Assessment.
G. Executive Order 13132
Executive Order 13132, ‘‘Federalism,’’
64 FR 43255 (August 4, 1999) imposes
certain requirements on agencies
formulating and implementing policies
or regulations that preempt State law or
that have Federalism implications. The
Executive Order requires agencies to
examine the constitutional and statutory
authority supporting any action that
would limit the policymaking discretion
of the States and to carefully assess the
necessity for such actions. The
Executive Order also requires agencies
to have an accountable process to
ensure meaningful and timely input by
State and local officials in the
development of regulatory policies that
have Federalism implications. On
March 14, 2000, DOE published a
statement of policy describing the
intergovernmental consultation process
it will follow in the development of
such regulations. 65 FR 13735. DOE has
examined this proposed rule and has
determined that it would not have a
substantial direct effect on the States, on
the relationship between the national
government and the States, or on the
distribution of power and
responsibilities among the various
levels of government. EPCA governs and
prescribes Federal preemption of State
regulations as to energy conservation for
the products that are the subject of
today’s proposed rule. States can
petition DOE for exemption from such
preemption to the extent, and based on
criteria, set forth in EPCA. (42 U.S.C.
6297(d)) No further action is required by
Executive Order 13132.
H. Executive Order 12988
With respect to the review of existing
regulations and the promulgation of
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new regulations, section 3(a) of
Executive Order 12988, ‘‘Civil Justice
Reform,’’ 61 FR 4729 (Feb. 7, 1996),
imposes on Federal agencies the general
duty to adhere to the following
requirements: (1) Eliminate drafting
errors and ambiguity; (2) write
regulations to minimize litigation; (3)
provide a clear legal standard for
affected conduct rather than a general
standard; and (4) promote simplification
and burden reduction. Section 3(b) of
Executive Order 12988 specifically
requires that Executive agencies make
every reasonable effort to ensure that the
regulation: (1) Clearly specifies the
preemptive effect, if any; (2) clearly
specifies any effect on existing Federal
law or regulation; (3) provides a clear
legal standard for affected conduct
while promoting simplification and
burden reduction; (4) specifies the
retroactive effect, if any; (5) adequately
defines key terms; and (6) addresses
other important issues affecting clarity
and general draftsmanship under any
guidelines issued by the Attorney
General. Section 3(c) of Executive Order
12988 requires Executive agencies to
review regulations in light of applicable
standards in sections 3(a) and 3(b) to
determine whether they are met or it is
unreasonable to meet one or more of
them. DOE has completed the required
review and determined that, to the
extent permitted by law, the proposed
rule meets the relevant standards of
Executive Order 12988.
I. Treasury and General Government
Appropriations Act, 2001
Section 515 of the Treasury and
General Government Appropriations
Act, 2001 (Pub. L. 106–554; 44 U.S.C.
3516 note) provides for agencies to
review most disseminations of
information to the public under
guidelines established by each agency
pursuant to general guidelines issued by
OMB. OMB’s guidelines were published
at 67 FR 8452 (Feb. 22, 2002), and
DOE’s guidelines were published at 67
FR 62446 (Oct. 7, 2002). DOE has
reviewed today’s proposed rule under
the OMB and DOE guidelines and has
concluded that it is consistent with
applicable policies in those guidelines.
J. Executive Order 13211
Executive Order 13211, ‘‘Actions
Concerning Regulations That
Significantly Affect Energy Supply,
Distribution, or Use,’’ 66 FR 28355 (May
22, 2001), requires Federal agencies to
prepare and submit to OMB, a
Statement of Energy Effects for any
proposed significant energy action. A
‘‘significant energy action’’ is defined as
any action by an agency that
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14311
promulgated or is expected to lead to
promulgation of a final rule, and that:
(1) Is a significant regulatory action
under Executive Order 12866, or any
successor order; and (2) is likely to have
a significant adverse effect on the
supply, distribution, or use of energy; or
(3) is designated by the Administrator of
OIRA as a significant energy action. For
any proposed significant energy action,
the agency must give a detailed
statement of any adverse effects on
energy supply, distribution, or use
should the proposal be implemented,
and of reasonable alternatives to the
action and their expected benefits on
energy supply, distribution, and use.
Today’s regulatory action to amend the
test procedure for measuring the energy
efficiency of fluorescent lamp ballasts is
not a significant regulatory action under
Executive Order 12866. Moreover, it
would not have a significant adverse
effect on the supply, distribution, or use
of energy, nor has it been designated as
a significant energy action by the
Administrator of OIRA. Therefore, it is
not a significant energy action, and,
accordingly, DOE has not prepared a
Statement of Energy Effects.
K. Executive Order 12630
Pursuant to Executive Order 12630,
‘‘Governmental Actions and Interference
with Constitutionally Protected Property
Rights,’’ 53 FR 8859 (March 15, 1988),
DOE has determined that this rule
would not result in any takings that
might require compensation under the
Fifth Amendment to the United States
Constitution.
L. Section 32 of the Federal Energy
Administration Act of 1974
Under section 301 of the Department
of Energy Organization Act (Pub. L. 95–
91; 42 U.S.C. 7101), DOE must comply
with section 32 of the Federal Energy
Administration Act of 1974, as amended
by the Federal Energy Administration
Authorization Act of 1977. (15 U.S.C.
788; FEAA) Section 32 essentially
provides in relevant part that, where a
proposed rule authorizes or requires use
of commercial standards, the notice of
proposed rulemaking must inform the
public of the use and background of
such standards. In addition, section
32(c) requires DOE to consult with the
Attorney General and the Chairman of
the Federal Trade Commission (FTC)
concerning the impact of the
commercial or industry standards on
competition. The proposed rule
incorporates testing methods contained
in the following commercial standards:
ANSI C82.2–2002, Method of
Measurement of Fluorescent Lamp
Ballasts. While today’s proposed test
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procedure is not exclusively based on
ANSI C82.2–2002, one component of
the test procedure, namely measurement
of ballast factor, adopts a measurement
technique from ANSI C82.2–2002
without amendment. The Department
has evaluated these standards and is
unable to conclude whether they fully
comply with the requirements of section
32(b) of the FEAA, (i.e., that they were
developed in a manner that fully
provides for public participation,
comment, and review). DOE will
consult with the Attorney General and
the Chairman of the FTC concerning the
impact of these test procedures on
competition, prior to prescribing a final
rule.
V. Public Participation
A. Attendance at Public Meeting
The time, date and location of the
public meeting are listed in the DATES
and ADDRESSES sections at the beginning
of this NOPR. To attend the public
meeting, please notify Ms. Brenda
Edwards at (202) 586–2945. As
explained in the ADDRESSES section,
foreign nationals visiting DOE
headquarters are subject to advance
security screening procedures.
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B. Procedure for Submitting Requests To
Speak
Any person who has an interest in the
topics addressed in this notice, or who
is a representative of a group or class of
persons that has an interest in these
issues, may request an opportunity to
make an oral presentation at the public
meeting. Such persons may handdeliver requests to speak to the address
shown in the ADDRESSES section at the
beginning of this notice between 9 a.m.
and 4 p.m., Monday through Friday,
except Federal holidays. Requests may
also be sent by mail or e-mail to: Ms.
Brenda Edwards, U.S. Department of
Energy, Building Technologies Program,
Mailstop EE–2J, 1000 Independence
Avenue, SW., Washington, DC 20585–
0121, or Brenda.Edwards@ee.doe.gov.
Persons who wish to speak should
include in their request a computer
diskette or CD in WordPerfect, Microsoft
Word, PDF, or text (ASCII) file format
that briefly describes the nature of their
interest in this rulemaking and the
topics they wish to discuss. Such
persons should also provide a daytime
telephone number where they can be
reached.
DOE requests that those persons who
are scheduled to speak submit a copy of
their statements at least one week prior
to the public meeting. DOE may permit
any person who cannot supply an
advance copy of this statement to
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participate, if that person has made
alternative arrangements with the
Building Technologies Program in
advance. When necessary, the request to
give an oral presentation should ask for
such alternative arrangements.
C. Conduct of Public Meeting
DOE will designate a DOE official to
preside at the public meeting and may
also employ a professional facilitator to
aid discussion. The public meeting will
be conducted in an informal, conference
style. The meeting will not be a judicial
or evidentiary public hearing, but DOE
will conduct it in accordance with
section 336 of EPCA (42 U.S.C. 6306).
There shall not be discussion of
proprietary information, costs or prices,
market share, or other commercial
matters regulated by U.S. anti-trust
laws.
DOE reserves the right to schedule the
order of presentations and to establish
the procedures governing the conduct of
the public meeting. A court reporter will
record the proceedings and prepare a
transcript.
At the public meeting, DOE will
present summaries of comments
received before the public meeting,
allow time for presentations by
participants, and encourage all
interested parties to share their views on
issues affecting this rulemaking. Each
participant may present a prepared
general statement (within time limits
determined by DOE) before the
discussion of specific topics. Other
participants may comment briefly on
any general statements. At the end of
the prepared statements on each specific
topic, participants may clarify their
statements briefly and comment on
statements made by others. Participants
should be prepared to answer questions
from DOE and other participants. DOE
representatives may also ask questions
about other matters relevant to this
rulemaking. The official conducting the
public meeting will accept additional
comments or questions from those
attending, as time permits. The
presiding official will announce any
further procedural rules or modification
of procedures needed for the proper
conduct of the public meeting.
DOE will make the entire record of
this proposed rulemaking, including the
transcript from the public meeting,
available for inspection at the U.S.
Department of Energy, 6th Floor, 950
L’Enfant Plaza, SW., Washington, DC
20024, (202) 586–2945, between 9 a.m.
and 4 p.m., Monday through Friday,
except Federal holidays. The official
transcript will also be posted on the
Web page at
https://www1.eere.energy.gov/buildings/
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appliance_standards/residential/
fluorescent_lamp_ballasts.html.
D. Submission of Comments
DOE will accept comments, data, and
information regarding the proposed rule
no later than the date provided at the
beginning of this notice. Comments,
data, and information submitted to
DOE’s e-mail address for this
rulemaking should be provided in
WordPerfect, Microsoft Word, PDF, or
text (ASCII) file format. Stakeholders
should avoid the use of special
characters or any form of encryption,
and wherever possible, comments
should include the electronic signature
of the author. Comments, data, and
information submitted to DOE via mail
or hand delivery/courier should include
one signed paper original. No
telefacsimiles (faxes) will be accepted.
According to 10 CFR 1004.11, any
person submitting information that he
or she believes to be confidential and
exempt by law from public disclosure
should submit two copies: one copy of
the document including all the
information believed to be confidential,
and one copy of the document with the
information believed to be confidential
deleted. DOE will make its own
determination as to the confidential
status of the information and treat it
according to its determination.
Factors of interest to DOE when
evaluating requests to treat submitted
information as confidential include: (1)
A description of the items; (2) whether
and why such items are customarily
treated as confidential within the
industry; (3) whether the information is
generally known by or available from
other sources; (4) whether the
information has previously been made
available to others without obligation
concerning its confidentiality; (5) an
explanation of the competitive injury to
the submitting person which would
result from public disclosure; (6) a date
upon which such information might
lose its confidential nature due to the
passage of time; and (7) why disclosure
of the information would be contrary to
the public interest.
E. Issues on Which DOE Seeks Comment
Although comments are welcome on
all aspects of this rulemaking, DOE is
particularly interested in receiving
comments and views of interested
parties concerning the following issues:
1. All Aspects of the Existing Test
Procedure for Active Mode Energy
Consumption
DOE invites comment on all aspects
of the existing test procedure for
fluorescent lamp ballasts for active
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mode energy consumption that appear
at 10 CFR part 430, subpart B, appendix
Q (‘‘Uniform Test Method for Measuring
the Energy Consumption of Fluorescent
Lamp Ballasts’’).
2. Appropriate Usage of ANSI Standards
DOE seeks comment on the
appropriate use of ANSI C82.2–2002,
ANSI C82.11 Consolidated-2002, and
ANSI C82.1–2004. See section III.E.3 for
further detail.
3. Method of Measurement for Dimming
Ballasts
DOE seeks comment on potential
methods of measurement to determine
the efficiency of dimming ballasts if
DOE decides to include them in the
scope of energy conservation standards.
See section III.F.2 for further detail.
4. Resistor-Based Ballast Efficiency Test
Method
DOE seeks comment on the
effectiveness of the proposed resistorbased BE test method and its expected
improvement in measurement variation.
See section III.E.1 for further details.
5. Alternative Approaches To Amending
the Test Procedure
DOE seeks comment from interested
parties who do not support the
proposed resistor-based ballast
efficiency method on the lamp-based BE
method and the light-output-based and
RSE test procedures (see sections III.E.2,
III.E.3, and III.E.4 for further detail), or
any other procedure they believe is
appropriate.
6. Ballasts That Do Not Operate
Resistors
DOE seeks comment on why some
ballasts do not operate when connected
to a resistor load bank and DOE’s
proposal to measure BEF directly (as a
light output measurement) for these
ballasts. DOE invites comment on other
approaches to test these ballasts. See
section III.F.8 for further detail.
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7. Ballast Factor Variation Due to
Variations in Measured Lamp Power
DOE recognizes that in order to
correlate measured BE to BEF using
DOE’s proposed test procedure, the BF
of the test ballast must be determined.
DOE seeks comment on DOE’s approach
to use light output-based measurement
to determine ballast factor and the
resulting variation in ballast factor due
to lamp manufacturing variations. DOE
also requests comment on impact of this
variation in BF on the calculated BEF
(according to the proposed test
procedure). See section III.F.3 for
further detail.
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8. Ballast Factor Binning
DOE seeks comment on the effect of
DOE’s approach of using a single
resistor value for measuring ballasts of
all ballast factors (for a particular
ballast) and correlating measured BE to
correlated BEF using transfer equations
specific to ballast factor bins. See
section III.F.5 for further detail.
paragraphs the words ‘‘and Appendix
Q1 of subpart B’’.
b. Redesignating paragraphs (c)(11) as
(c)(12); (c)(12) as (c)(15); and (c)(13) as
(c)(16).
c. Adding new paragraphs (c)(11),
(c)(13) and (c)(14).
These revisions and additions read as
follows:
9. Transfer Equations
DOE seeks comment on the transfer
equations developed to convert BE to
BEF. See section III.F.5 for further
detail.
§ 430.3 Materials incorporated by
reference.
10. Scaling Transfer Equations
DOE seeks comment on the transfer
equation scaling techniques (across
number of lamps operated by a ballast,
starting method, ballast factor, and total
rated lamp power) used for product
classes in which there was insufficient
correlation in the test data to establish
a slope. See section III.F.6 for further
detail.
11. Burden on Manufacturers and
Testing Facilities
DOE seeks comment on its assessment
of the anticipated burden imposed by
the proposed test method. See section
III.G for further detail.
VI. Approval of the Office of the
Secretary
The Secretary of Energy has approved
publication of this proposed rule.
List of Subjects in 10 CFR Part 430
Administrative practice and
procedure, Confidential business
information, Energy conservation,
Household appliances, Imports,
Incorporation by reference,
Intergovernmental relations, Small
businesses.
Issued in Washington, DC on February 12,
2010.
Cathy Zoi,
Assistant Secretary, Energy Efficiency and
Renewable Energy.
For the reasons stated in the
preamble, DOE is proposing to amend
Part 430 of Chapter II of Title 10, Code
of Federal Regulations as set forth
below:
PART 430–ENERGY CONSERVATION
PROGRAM FOR CONSUMER
PRODUCTS
1. The authority citation for Part 430
continues to read as follows:
Authority: 42 U.S.C. 6291–6309; 28 U.S.C.
2461 note.
2. Section 430.3 is amended by:
a. Amending paragraphs (c)(5), (c)(7)
and (c)(11) by adding at the end of the
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*
*
*
*
*
(c) * * *
(11) ANSI C82.1–2004, Revision of
ANSI C82.1–1997 (‘‘ANSI C82.1’’),
American National Standard for Lamp
Ballast—Line-Frequency Fluorescent
Lamp Ballast, approved November 19,
2004; IBR approved for Appendix Q of
subpart B and Appendix Q1 of subpart
B.
*
*
*
*
*
(13) ANSI C82.11–2002, Revision of
ANSI C82.11–1993 (‘‘ANSI C82.11’’),
American National Standard for Lamp
Ballasts—High-frequency Fluorescent
Lamp Ballasts, approved January 17,
2002; IBR approved for Appendix Q of
subpart B and Appendix Q1 of subpart
B.
(14) ANSI C82.13–2002 (‘‘ANSI
C82.13’’), American National Standard
for Lamp Ballasts—Definitions for
Fluorescent Lamps and Ballasts,
approved July 23, 2002; IBR approved
for Appendix Q of subpart B and
Appendix Q1 of subpart B.
*
*
*
*
*
3. Section 430.23 is amended by
revising paragraph (q) to read as follows:
§ 430.23 Test procedures for the
measurement of energy and water
consumption.
*
*
*
*
*
(q) Fluorescent Lamp Ballasts. (1) The
Estimated Annual Energy Consumption
(EAEC) for fluorescent lamp ballasts,
expressed in kilowatt-hours per year,
shall be the product of:
(i) The input power in kilowatts as
determined in accordance with section
3.1.3.1 of appendix Q to this subpart
before the compliance date of the
amended standards for fluorescent lamp
ballasts or section 7.1.2.2 of appendix
Q1 to this subpart beginning on the
compliance date of the amended
standards for fluorescent lamp ballasts;
and
(ii) The representative average use
cycle of 1,000 hours per year, the
resulting product then being rounded
off to the nearest kilowatt-hour per year.
(2) Ballast Efficacy Factor (BEF) shall
be as determined in section 4.2 of
appendix Q of this subpart before the
compliance date of the amended
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standards for fluorescent lamp ballasts
or section 8.3 of appendix Q1 to this
subpart beginning on the compliance
date of the amended standards for
fluorescent lamp ballasts.
(3) The Estimated Annual Operating
Cost (EAOC) for fluorescent lamp
ballasts, expressed in dollars per year,
shall be the product of:
(i) The representative average unit
energy cost of electricity in dollars per
kilowatt-hour as provided by the
Secretary,
(ii) The representative average use
cycle of 1,000 hours per year, and
(iii) The input power in kilowatts as
determined in accordance with section
3.1.3.1 of appendix Q to this subpart
before the compliance date of the
amended standards for fluorescent lamp
ballasts or section 7.1.2.2 of appendix
Q1 to this subpart beginning on the
compliance date of the amended
standards for fluorescent lamp ballasts,
the resulting product then being
rounded off to the nearest dollar per
year.
(4) Standby power consumption of
certain fluorescent lamp ballasts shall
be measured in accordance with section
3.2 of appendix Q to this subpart.
*
*
*
*
*
4. Appendix Q to Subpart B of Part
430 is amended by:
a. Adding introductory text.
b. Revising sections 1.15, 1.16, and
1.17.
c. Removing section 2.1, redesignating
section 2.2 as section 2, and revising
redesignated section 2.
d. Redesignating sections 3.1, 3.2, 3.3,
3.3.1, 3.3.2, 3.3.3, 3.4, 3.4.1, and 3.4.2 as
sections 3.1.1, 3.1.2, 3.1.3, 3.1.3.1,
3.1.3.2, 3.1.3.3, 3.1.4, 3.1.4.1, and
3.1.4.2, respectively.
e. Revising redesignated sections
3.1.1, 3.1.2, 3.1.3.1, 3.1.3.2, 3.1.3.3,
3.1.4.1, and 3.1.4.2.
f. Redesignating sections 3.5, 3.5.1,
3.5.2, 3.5.3, 3.5.3.1, 3.5.3.2, 3.5.3.3, and
3.5.3.4 as sections 3.2, 3.2.2, 3.2.3, 3.2.4,
3.2.4.1, 3.2.4.2, 3.2.4.3, and 3.2.4.4,
respectively.
g. Adding sections 3.1 and 3.2.1.
h. Revising section 4.
Appendix Q is effective until the
compliance date of the amended standards
for fluorescent lamp ballasts. After this date,
all fluorescent lamp ballasts shall be tested
using the provisions of Appendix Q1 except
where Appendix Q1 specifies use Appendix
Q for testing certain ballasts that do not
operate resistors.
*
*
*
*
*
*
*
1. Definitions
*
*
*
1.15 Power Factor means the power input
divided by the product of ballast input
voltage and input current of a fluorescent
lamp ballast, as measured under test
conditions specified in ANSI C82.2–2002
(incorporated by reference; see § 430.3).
1.16 Power input means the power
consumption in watts of a ballast an
fluorescent lamp or lamps, as determined in
accordance with the test procedures specified
in ANSI C82.2–2002 (incorporated by
reference; see § 430.3).
1.17 Relative light output means the light
output delivered through the use of a ballast
divided by the light output of a reference
ballast, expressed as a percent, as determined
in accordance with the test procedures
specified in ANSI C82.2–2002 (incorporated
by reference; see § 430.3).
*
*
*
*
*
2. Test Conditions
The measurement of standby mode power
need not be performed to determine
compliance with energy conservation
standards for fluorescent lamp ballasts at this
time. The above statement will be removed
as part of a rulemaking to amend the energy
conservation standards for fluorescent lamp
ballasts to account for standby mode energy
consumption, and the following shall apply
on the compliance date for such
requirements. The test conditions for testing
fluorescent lamp ballasts shall be done in
accordance with ANSI C82.2–2002
(incorporated by reference; see § 430.3). Any
subsequent amendment to this standard by
the standard setting organization will not
affect the DOE test procedures unless and
until amended by DOE. The test conditions
for measuring active mode energy
consumption are described in sections 4, 5,
and 6 of ANSI C82.2–2002. The test
conditions for measuring standby power are
described in sections 5, 7, and 8 of ANSI
C82.2–2002. Fluorescent lamp ballasts that
are capable of connections to control devices
shall be tested with all commercially
available compatible control devices
connected in all possible configurations. For
each configuration, a separate measurement
of standby power shall be made in
accordance with section 4 of the test
procedure.
3. * * *
3.1 Active Mode Energy Efficiency
Measurement
3.1.1 The test method for testing the
active mode energy efficiency of fluorescent
lamp ballasts shall be done in accordance
with ANSI C82.2–2002 (incorporated by
reference; see § 430.3). Where ANSI C82.2–
2002 references ANSI C82.1–1997, the
operator shall use ANSI C82.1 (incorporated
by reference; see § 430.3) for testing lowfrequency ballasts and ANSI C82.11
(incorporated by reference; see § 430.3) for
high-frequency ballasts.
3.1.2 Instrumentation. The
instrumentation shall be as specified by
sections 5, 7, 8, and 15 of ANSI C82.2–2002
(incorporated by reference; see § 430.3).
3.1.3 * * *
3.1.3.1 Input Power. Measure the input
power (watts) to the ballast in accordance
with ANSI C82.2–2002 (incorporated by
reference; see § 430.3), section 4.
3.1.3.2 Input Voltage. Measure the input
voltage (volts) (RMS) to the ballast in
accordance with ANSI C82.2–2002
(incorporated by reference; see § 430.3),
section 3.2.1 and section 4.
3.1.3.3 Input Current. Measure the input
current (amps) (RMS) to the ballast in
accordance with ANSI C82.2–2002
(incorporated by reference; see § 430.3),
section 3.2.1 and section 4.
3.1.4 * * *
3.1.4.1 Measure the light output of the
reference lamp with the reference ballast in
accordance with ANSI C82.2–2002
(incorporated by reference; see § 430.3),
section 12.
3.1.4.2 Measure the light output of the
reference lamp with the test ballast in
accordance with ANSI C82.2–2002
(incorporated by reference; see § 430.3),
section 12.
3.2. * * *
3.2.1 The test for measuring standby
mode energy consumption of fluorescent
lamp ballasts shall be done in accordance
with ANSI C82.2–2002 (incorporated by
reference; see § 430.3).
*
*
*
*
*
4. Calculations
4.1
Calculate Relative Light Output
Photocell output of lamp on test ballast
× 100 = relative light output
Photocell output of lamp on ref. ballast
f
Where:
Photocell output of lamp on test ballast is
determined in accordance with section
3.1.4.2, expressed in watts, and
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determined in accordance with section
3.1.4.1, expressed in watts.
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4.2 Determine the Ballast Efficacy Factor
(BEF) Using the Following Equations
(a) Single lamp ballast.
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These revisions and additions read as
follows:
Appendix Q to Subpart B of Part 430—
Uniform Test Method for Measuring the
Energy Consumption of Fluorescent
Lamp Ballasts
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Federal Register / Vol. 75, No. 56 / Wednesday, March 24, 2010 / Proposed Rules
BEF =
for testing low-frequency ballasts and shall
use ANSI C82.11 (incorporated by reference;
see § 430.3) for high-frequency ballasts.
relative light output
input power
(b) Multiple lamp ballast.
3. Definitions
average relative light output
BEF =
input power
Where:
Input power is determined in accordance
with section 3.1.3.1,
Relative light output as defined in section
4.1, and
Average relative light output is the relative
light output, as defined in section 4.1, for
all lamps, divided by the total number of
lamps.
4.3
Determine Ballast Power Factor (PF)
PF =
Input power
Input voltage × input current
Where:
Input power is as defined in section 3.1.3.1,
Input voltage is determined in accordance
with section 3.1.3.2, expressed in volts,
and
Input current is determined in accordance
with section 3.1.3.3, expressed in amps.
5. Appendix Q1 is added to Subpart
B of Part 430 to read as follows:
Appendix Q1 to Subpart B of Part 430—
Uniform Test Method for Measuring the
Energy Consumption of Fluorescent
Lamp Ballasts
Appendix Q1 is effective on the
compliance date of the amended standards
for fluorescent lamp ballasts. Prior to this
date, all fluorescent lamp ballasts shall be
tested using the provisions of Appendix Q.
1. If the operator determines that a ballast
does not operate a resistor load bank, then
the operator should use the test procedure
described in Appendix Q to Subpart B of Part
430. To determine that a ballast does not
operate a resistor load bank, the input power,
voltage, or current to the ballast should equal
zero when tested in accordance with this
Appendix Q1 to Subpart B of Part 430.
2. Where ANSI C82.2–2002 (incorporated
by reference; see § 430.3) references ANSI
C82.1–1997, the operator shall use ANSI
C82.1 (incorporated by reference; see § 430.3)
3.1. Commercial ballast is a fluorescent
lamp ballast that is not a residential ballast
as defined in Section 3.8 and meets technical
standards for non-consumer RF lighting
devices as specified in subpart C of 47 CFR
part 18.
3.2. Electrode heating refers to power
delivered to the lamp by the ballast for the
purpose of raising the temperature of the
lamp electrode or filament. ANSI standards
generally refer to this process as cathode
heating.
3.3. High-frequency ballast is as defined in
ANSI C82.13 (incorporated by reference; see
§ 430.3).
3.4. Instant-start is the starting method
used instant-start systems as defined in ANSI
C82.13 (incorporated by reference; see
§ 430.3).
3.5. Low-frequency ballast is a fluorescent
lamp ballast that operates at a supply
frequency of 50 to 60 Hz and operates the
lamp at the same frequency as the supply.
3.6. Programmed-start is the starting
method used in programmed start systems as
defined in ANSI C82.13 (incorporated by
reference; see § 430.3).
3.7. Rapid-start is the starting method used
in rapid-start type systems as defined in
ANSI C82.13 (incorporated by reference; see
§ 430.3).
3.8. Residential ballast is a fluorescent
lamp ballast designed and labeled for use in
residential applications. Residential ballasts
must meet the technical standards for
consumer RF lighting devices as specified in
subpart C of 47 CFR part 18.
3.9. Resistor load bank means a network of
resistors used to model the load placed on a
fluorescent lamp ballast by a fluorescent
lamp.
3.10. RMS is the root mean square of a
varying quantity.
4. Instruments
4.1. All instruments shall be as specified
by ANSI C82.2–2002 (incorporated by
reference; see § 430.3).
4.2. Power Analyzer. In addition to the
specifications in ANSI C82.2–2002
(incorporated by reference; see § 430.3), the
power analyzer shall have a maximum 100
pF capacitance to ground and frequency
response between 40 Hz and 1 MHz.
4.3. Current Probe. In addition to the
specifications in ANSI C82.2–2002
(incorporated by reference; see § 430.3), the
current probe shall be galvanically isolated
and have frequency response between 40 Hz
and 20 MHz.
5. Test Setup
5.1. The ballast shall be connected to a
main power source and to the resistor load
bank according to the manufacturer’s wiring
instructions. Where the wiring diagram
indicates connecting the ballast lead to a
lamp, the lead should be connected to a
resistor load bank.
5.1.1. Figures 1 and 2 illustrate the resistor
load bank used to model one fluorescent
lamp. The four resistors labeled as R1/2E
represent the electrodes, and Rarc represents
the lamp arc.
5.1.2. Wire lengths between the ballast and
resistor load bank shall be the length
provided by the ballast manufacturer.
5.2. A ballast shall be tested using one
resistor load bank to simulate one lamp. A
ballast shall be connected to the number of
resistor load banks equal to the maximum
number of lamps a ballast is designed to
operate.
5.3. A ballast designed to operate a lamp
at high-frequency (as defined in section 3.3)
shall use a resistor with resistance that
simulates high-frequency operation. A ballast
designed to operate a lamp a low-frequency
(as defined in section 3.5) shall use a resistor
with resistance that simulates low-frequency
operation.
5.4. A ballast shall be tested with a resistor
load bank with the resistances indicated in
Table A.
5.5. Power Analyzer
5.5.1. The power analyzer shall have n+1
channels where n is the number of lamps a
ballast operates.
5.5.2. Output Voltage. Leads from the
power analyzer should attach to each resistor
load bank according to Figure 1 for rapidand programmed-start ballasts and Figure 2
for instant-start ballasts.
5.5.3. Output Current. A current probe
shall be positioned on each resistor load bank
according to Figure 1 for rapid- and
programmed-start ballasts and Figure 2 for
instant-start ballasts.
TABLE A—SIMULATED LAMP RESISTOR VALUES
32
34
T8 MBP .......
T12 MBP .....
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Lamp arc
(Rarc)
5.75
4.8
439
151
Electrode
(R1/2E)
5.75
4.8
Lamp arc
(Rarc)
760
204
EP24MR10.008
Ballasts that operate one, two, three, four, five, or six
straight-shaped lamps (commonly referred to as 4-foot medium bipin lamps) with medium bipin bases, a nominal
overall length of 48 inches, a rated wattage of 25W or
more, and an input voltage at or between 120V and 277V.
Electrode
(R1/2E)
EP24MR10.009
Lamp diameter and base
High-frequency operation resistance
(Ohms)
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Ballast type
VerDate Nov<24>2008
Low-frequency operation
resistance (Ohms)
Nominal
lamp wattage
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TABLE A—SIMULATED LAMP RESISTOR VALUES—Continued
Low-frequency operation
resistance (Ohms)
High-frequency operation resistance
(Ohms)
Nominal
lamp wattage
Ballast type
Ballasts that operate one, two, three, four, five, or six Ushaped lamps (commonly referred to as 2-foot U-shaped
lamps) with medium bipin bases, a nominal overall length
between 22 and 25 inches, a rated wattage of 25W or
more, and an input voltage at or between 120V and 277V.
Ballasts that operate one or two rapid-start lamps (commonly
referred to as 8-foot high output lamps) with recessed double contact bases, a nominal overall length of 96 inches
and an input voltage at or between 120V and 277V.
Ballasts that operate one or two instant-start lamps (commonly referred to as 8-foot slimline lamps) with single pin
bases, a nominal overall length of 96 inches, a rated wattage of 52W or more, and an input voltage at or between
120V and 277V.
Ballasts that operate one or two straight-shaped lamps (commonly referred to as 4-foot miniature bipin standard output
lamps) with miniature bipin bases, a nominal length between 45 and 48 inches, a rated wattage of 26W or more,
and an input voltage at or between 120V and 277V.
Ballasts that operate one, two, three, or four straight-shaped
lamps (commonly referred to as 4-foot miniature bipin high
output lamps) with miniature bipin bases, a nominal length
between 45 and 48 inches, a rated wattage of 49W or
more, and an input voltage at or between 120V and 277V.
Ballasts that operate one, two, three, or four straight-shaped
lamps (commonly referred to as 4-foot medium bipin
lamps) with medium bipin bases, a nominal overall length
of 48 inches, a rated wattage of 25W or more, an input
voltage at or between 120V and 277V, a power factor of
less than 0.90, and that are designed and labeled for use
in residential applications.
Ballasts that operate one, two, three, four, five, or six rapidstart lamps (commonly referred to as 8-foot high output
lamps) with recessed double contact bases, a nominal
overall length of 96 inches, an input voltage at or between
120V and 277V, and that operate at ambient temperatures
of 20 °F or less and are used in outdoor signs.
Lamp diameter and base
32
34
T8 MBP .......
T12 MBP .....
5.75
4.8
439
151
5.75
4.8
760
204
86
95
T8 HO RDC
T12 HO RDC
N/A
1.6
N/A
131
4.75
1.6
538
204
59
60
T8 slimline
SP.
T12 slimline
SP.
N/A*
N/A*
876
313
N/A*
N/A*
1256
431
28
T5 Mini-BP ..
N/A
N/A
20
950
54
T5 Mini-BP ..
N/A
N/A
4
255
32
34
T8 MBP .......
T12 MBP .....
5.75
4.8
439
151
5.75
4.8
760
204
86
110
T8 HO RDC
T12 HO RDC
N/A
1.6
N/A
166
4.75
1.6
538
275
Electrode
(R1/2E)
Lamp arc
(Rarc)
Electrode
(R1/2E)
mstockstill on DSKH9S0YB1PROD with PROPOSALS2
MBP, Mini-BP, RDC, and SP represent medium bipin, miniature bipin, recessed double contact, and single pin, respectively.
* The resistor load bank representing 8-foot slimline single pin (SP) lamps does not have electrode resistors.
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Federal Register / Vol. 75, No. 56 / Wednesday, March 24, 2010 / Proposed Rules
6.1. The test conditions for testing
fluorescent lamp ballasts shall be done in
accordance with ANSI C82.2–2002
(incorporated by reference; see § 430.3). DOE
further specifies that the following revisions
of the normative references indicated in
ANSI C82.2–2002) should be used in place of
the references directly specified in ANSI
C82.2–2002: ANSI C78.81 (incorporated by
reference; see § 430.3), ANSI C78.901
(incorporated by reference; see § 430.3), ANSI
C82.1 (incorporated by reference; see
§ 430.3), ANSI C82.3 (incorporated by
reference; see § 430.3), ANSI C82.11
(incorporated by reference; see § 430.3), and
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Jkt 220001
ANSI C82.13 (incorporated by reference; see
§ 430.3). All other normative references shall
be as specified in ANSI C82.2–2002.
6.2. Temperature Stabilization. Ballasts
shall be thermally conditioned for at least 4
hours at room temperature (25 ± 2 °C), with
normal room or lab ventilation.
6.3. Input Voltage. The directions in ANSI
C82.2–2002 (incorporated by reference; see
§ 430.3) section 4.1 should be ignored with
the following directions for input voltage
used instead. For commercial ballasts
capable of operating at multiple voltages, the
ballast shall be tested 277V ± 0.1%. For
ballasts designed and labeled for residential
applications and capable or operating at
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multiple voltages, the ballast shall be tested
at 120V ± 0.1%.
6.4. Duty Cycle. The duty cycle shall be no
more than 50%. For every operational
minute, the resistor load bank shall be rested
at zero power for at least one minute.
7. Test Method
7.1. Ballast Efficiency
7.1.1. The ballast shall be connected to the
appropriate resistor load bank and to
measurement instrumentation as indicated
by the Test Setup in section 5.
7.1.2. The ballast shall be operated for one
minute followed by an instantaneous data
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6. Test Conditions
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Federal Register / Vol. 75, No. 56 / Wednesday, March 24, 2010 / Proposed Rules
capture of the parameters described in
sections 7.1.2.1 through 7.1.2.4.
7.1.2.1. Output Power. The power analyzer
shall calculate output power by capturing
voltage across each lamp arc resistor using
the setup described in 5.5.2 and current to
the lamp according to the setup described in
5.5.3 and summing the power for each lamp.
7.1.2.2. Input Power. Measure the input
power (watts) to the ballast in accordance
with ANSI C82.2–2002 (incorporated by
reference; see § 430.3), section 7.
7.1.2.3. Input Voltage. Measure the input
voltage (volts) (RMS) to the ballast in
accordance with ANSI C82.2–2002
(incorporated by reference; see § 430.3),
section 3.2.1 and section 4.
7.1.2.4. Input Current. Measure the input
current (amps) (RMS) to the ballast in
accordance with ANSI C82.2–2002
(incorporated by reference; see § 430.3),
section 3.2.1 and section 4.
7.2. Ballast Factor
7.2.1. ANSI C82.2–2002 (incorporated by
reference; see § 430.3) shall be further
specified for the purpose of measuring ballast
factor by the following:
7.2.1.1. The reference lamp shall be
operated at the specified input voltage to the
reference circuit.
7.2.1.2. Electrode heating shall be used in
the reference circuit for all ballasts that
operate bipin (MBP, mini-BP) or recessed
double contact (RDC) lamps as indicated in
Table A. Electrode heating shall not be used
in the reference circuit for single pin lamps.
7.2.1.3. Light output measurements shall
be used for all ballasts, including instant-start
ballasts. Power measurements shall not be
used.
Ballast Factor =
Where:
Photocell output of lamp on test ballast is
determined in accordance with section
7.2.2, expressed in watts, and
7.2.2. Measure the light output of the
reference lamp with the reference ballast in
accordance with ANSI C82.2–2002
(incorporated by reference; see § 430.3),
section 12, using section 7.2.1 to further
specify ANSI C82.2–2002. The reference
lamp shall have the nominal wattage
corresponding to the test ballast as indicated
in Table A.
7.2.3. Measure the light output of the
reference lamp with the test ballast in
accordance with ANSI C82.2–2002
(incorporated by reference; see § 430.3),
section 12, using section 7.2.1 to further
specify ANSI C82.2–2002 The reference lamp
shall have the nominal wattage
corresponding to the test ballast as indicated
in Table A.
8. Calculations
8.1. Calculate Ballast Factor (BF)
Photocell output of lamp on test ballast
×100
Photocell output of lamp on reference ballast
Photocell output of lamp on reference ballast
is determined in accordance with section
7.2.3, expressed in watts.
8.2. Calculate Ballast Efficiency (BE)
8.3. Calculate Ballast Efficacy Factor (BEF).
Multiply BE by the Appropriate Conversion
Factor in Table B. BEF = Conversion Factor
× BE
TABLE B—CONVERSION FACTOR, BE TO BEF
Number of lamps
Starting method*
Ballast and lamp type
Ballast factor**
One
Four-Foot MBP,
Shaped.
and
Two-Foot
U–
Two
Three
Four
Five
Six
IS and RS (not PS) ......
High ..............................
Normal ..........................
Low ...............................
3.233
3.378
3.430
1.624
1.697
1.723
1.081
1.129
1.147
0.812
0.849
0.862
0.650
0.679
0.690
0.542
0.566
0.575
PS .................................
High ..............................
Normal ..........................
Low ...............................
3.204
3.348
3.400
1.610
1.682
1.708
1.071
1.119
1.137
0.808
0.844
0.857
0.644
0.673
0.684
0.537
0.561
0.570
Four-Foot T5, MiniBP SO ......................
All .................................
High ..............................
Normal ..........................
Low ...............................
2.910
3.041
3.088
1.584
1.655
1.680
..........
..........
..........
..........
..........
..........
..........
..........
..........
..........
..........
..........
Four-Foot T5, MiniBP HO ......................
All .................................
All .................................
1.703
0.927
0.649
0.504
..........
..........
Eight-Foot SP Slimline ...........................
All .................................
High ..............................
Normal ..........................
Low ...............................
1.653
1.727
1.754
0.841
0.878
0.892
..........
..........
..........
..........
..........
..........
..........
..........
..........
..........
..........
..........
Eight-Foot RDC HO ...............................
IS and RS (not PS) ......
All .................................
1.128
0.614
..........
..........
..........
..........
PS .................................
All .................................
1.138
0.619
..........
..........
..........
..........
IS and RS (not PS) ......
All .................................
3.357
1.686
1.122
0.853
..........
..........
PS .................................
All .................................
3.328
1.671
1.113
0.846
..........
..........
All .................................
All .................................
0.888
0.483
0.338
0.263
0.216
0.184
Sign Ballast ............................................
*IS
= Instant-start; RS = Rapid-start; PS = Programmed-start
ballast factor: BF ≥ 1.10; Normal ballast factor: 0.78 > BF >1.10; Low ballast factor: BF ≤ 0.78.
**High
8.4. Calculate Power Factor (PF)
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Residential Ballast, Four-Foot MBP, and
Two-Foot U–Shaped.
Federal Register / Vol. 75, No. 56 / Wednesday, March 24, 2010 / Proposed Rules
Where:
Input power is determined in accordance
with section 7.1.2.2,
Input voltage is determined in accordance
with section 7.1.2.2, and
Input current is determined in accordance
with section 7.1.2.3.
procedure and energy conservation
standards final rulemaking.
*
*
*
*
*
[FR Doc. 2010–6374 Filed 3–23–10; 8:45 am]
BILLING CODE 6450–01–P
6. Section 430.62 is amended by
revising paragraph (a)(1), and adding
new paragraphs (a)(4)(xxv) and (a)(6) to
read as follows:
mstockstill on DSKH9S0YB1PROD with PROPOSALS2
§ 430.62
Submission of data.
(a)(1) Except as provided in paragraph
(a)(2) and (a)(6) of this section, each
manufacturer or private labeler before
distributing in commerce any basic
model of a covered product subject to
the applicable energy conservation
standard or water conservation standard
(in the case of faucets, showerheads,
water closets, and urinals) set forth in
subpart C of this part shall certify by
means of a compliance statement and a
certification report that each basic
model(s) meets the applicable energy
conservation standard or water
conservation standard (in the case of
faucets, showerheads, water closets, and
urinals) as prescribed in section 325 of
the Act. The compliance statement,
signed by the company official
submitting the statement, and the
certification report(s) shall be sent by
certified mail to: Department of Energy,
Office of Energy Efficiency and
Renewable Energy, Office of Codes and
Standards, Forrestal Building, 1000
Independence Avenue, SW.,
Washington, DC 20585–0121.
*
*
*
*
*
(4) * * *
(xxv) Fluorescent Lamp Ballasts, the
ballast efficacy factor (BEF) and the
ballast power factor (PF).
*
*
*
*
*
(6) Each manufacturer or private
labeler of a basic model of a covered
fluorescent lamp ballast shall file a
compliance statement and a certification
report to DOE using the test procedure
described in Appendix Q to Subpart B
of Part 430 within 1 year of publication
of the fluorescent lamp ballast test
procedure and energy conservation
standard final rulemaking. Furthermore,
each manufacturer or private labeler of
a basic model of a covered fluorescent
lamp ballast shall file a compliance
statement and a certification report to
DOE using the test procedure described
in Appendix Q1 to Subpart B of Part 430
before within 4 years of publication of
the fluorescent lamp ballast test
VerDate Nov<24>2008
18:00 Mar 23, 2010
Jkt 220001
Input Power
Input Voltage × Input Current
DEPARTMENT OF ENERGY
10 CFR Part 430
[Docket No. EERE–2007–BT–STD–0016]
RIN 1904–AB50
Energy Conservation Standards for
Fluorescent Lamp Ballasts: Public
Meeting and Availability of the
Preliminary Technical Support
Document
AGENCY: Office of Energy Efficiency and
Renewable Energy, Department of
Energy.
ACTION: Notice of public meeting and
availability of preliminary technical
support document.
SUMMARY: The U.S. Department of
Energy (DOE) will hold a public meeting
to discuss and receive comments on: the
product classes that DOE plans to
analyze for purposes of establishing
energy conservation standards for
fluorescent lamp ballasts; the analytical
framework, models, and tools that DOE
is using to evaluate standards for these
products; the results of preliminary
analyses DOE performed for these
products; and potential energy
conservation standard levels derived
from these analyses that DOE could
consider for these products. DOE
encourages written comments on these
subjects. To inform interested parties
and facilitate this process, DOE has
prepared an agenda, a preliminary
technical support document (TSD), and
briefing materials, which are available at
https://www1.eere.energy.gov/buildings/
appliance_standards/residential/
fluorescent_lamp_ballasts.html.
DATES: DOE will hold a public meeting
on Monday, April 26, 2010, beginning at
9 a.m. in Washington, DC. The agenda
for the public meeting will first cover
the concurrent test procedure
rulemaking for fluorescent lamp ballasts
(see proposal in today’s Federal
Register), and then this energy
conservation standards rulemaking for
the same products. Any person
requesting to speak at the public
meeting should submit such a request,
along with an electronic copy of the
PO 00000
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statement to be given at the public
meeting, before 4 p.m., Monday, April
12, 2010. Written comments are
welcome, especially following the
public meeting, and should be
submitted by May 10, 2010.
ADDRESSES: The public meeting will be
held at the U.S. Department of Energy,
Forrestal Building, Room 8E–089, 1000
Independence Avenue, SW.,
Washington, DC 20585–0121. Please
note that foreign nationals participating
in the public meeting are subject to
advance security screening procedures.
If a foreign national wishes to
participate in the public meeting, please
inform DOE of this fact as soon as
possible by contacting Ms. Brenda
Edwards at (202) 586–2945 so that the
necessary procedures can be completed.
Interested persons may submit
comments, identified by docket number
EERE–2007–BT–STD–0016, by any of
the following methods:
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
• E-mail:
ballasts.rulemaking@ee.doe.gov. Include
EERE–2007–BT–STD–0016 and/or RIN
1904–AB50 in the subject line of the
message.
• Postal Mail: Ms. Brenda Edwards,
U.S. Department of Energy, Building
Technologies Program, Mailstop EE–2J,
Public Meeting for Fluorescent Lamp
Ballasts, EERE–2007–BT–STD–0016,
1000 Independence Avenue, SW.,
Washington, DC 20585–0121.
Telephone (202) 586–2945. Please
submit one signed paper original.
• Hand Delivery/Courier: Ms. Brenda
Edwards, U.S. Department of Energy,
Building Technologies Program, Sixth
Floor, 950 L’Enfant Plaza, SW.,
Washington, DC 20024. Telephone (202)
586–2945. Please submit one signed
paper original.
Instructions: All submissions received
must include the agency name and
docket number.
Docket: For access to the docket to
read background documents or a copy of
the transcript of the public meeting or
comments received, go to the U.S.
Department of Energy, Sixth Floor, 950
L’Enfant Plaza, SW., Washington, DC
20024, (202) 586–2945, between 9 a.m.
and 4 p.m., Monday through Friday,
except Federal holidays. Please call Ms.
Brenda Edwards at (202) 586–2945 for
additional information regarding
visiting the Resource Room.
E:\FR\FM\24MRP2.SGM
24MRP2
EP24MR10.011
Power Factor =
14319
Agencies
[Federal Register Volume 75, Number 56 (Wednesday, March 24, 2010)]
[Proposed Rules]
[Pages 14288-14319]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-6374]
[[Page 14287]]
-----------------------------------------------------------------------
Part III
Department of Energy
-----------------------------------------------------------------------
10 CFR Part 430
Energy Conservation Program: Test Procedures and Standards for
Fluorescent Lamp Ballasts; Public Meeting and Availability of the
Preliminary Technical Support Document; Proposed Rules
Federal Register / Vol. 75, No. 56 / Wednesday, March 24, 2010 /
Proposed Rules
[[Page 14288]]
-----------------------------------------------------------------------
DEPARTMENT OF ENERGY
10 CFR Part 430
[Docket No. EERE-2009-BT-TP-0016]
RIN 1904-AB99
Energy Conservation Program: Test Procedures for Fluorescent Lamp
Ballasts
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of proposed rulemaking and public meeting.
-----------------------------------------------------------------------
SUMMARY: The U.S. Department of Energy (DOE) proposes major revisions
to its test procedures for fluorescent lamp ballasts established under
the Energy Policy and Conservation Act. The proposed test method would
eliminate the use of photometric measurements in favor of purely
electrical measurements with the goal of reducing measurement
variation. DOE proposes a set of transfer functions to convert the
measured ballast electrical efficiency to a ballast efficacy factor
value. These revisions, however, do not concern the measurement of
energy consumption of ballasts in the standby and off modes, which DOE
addressed in another rulemaking. DOE also announces a public meeting to
receive comment on the issues presented in this notice.
DATES: DOE will hold a public meeting on Monday, April 26, 2010,
beginning at 9 a.m. in Washington, DC. The agenda for the public
meeting will first cover this test procedure rulemaking for fluorescent
lamp ballasts, and then the concurrent energy conservation standards
rulemaking (see proposal in today's Federal Register) for the same
products. Any person requesting to speak at the public meeting should
submit such a request, along with an electronic copy of the statement
to be given at the public meeting, before 4 p.m., Monday, April 12,
2010.
DOE will accept comments, data, and information regarding this
notice of proposed rulemaking (NOPR) before or after the public
meeting, but no later than June 7, 2010. See section V, ``Public
Participation,'' of this NOPR for details.
ADDRESSES: The public meeting will be held at the U.S. Department of
Energy, Forrestal Building, Room 8E-089, 1000 Independence Avenue, SW.,
Washington, DC 20585-0121. To attend the public meeting, please notify
Ms. Brenda Edwards at (202) 586-2945. Please note that foreign
nationals participating in the public meeting are subject to advance
security screening procedures. If a foreign national wishes to
participate in the workshop, please inform DOE of this fact as soon as
possible by contacting Ms. Brenda Edwards at (202) 586-2945 so that the
necessary procedures can be completed.
Any comments submitted must identify the Fluorescent Lamp Ballast
Active Mode Test Procedures NOPR, and provide the docket number EERE-
2009-BT-TP-0016 and/or Regulation Identifier Number (RIN) 1904-AB99.
Comments may be submitted using any of the following methods:
Federal eRulemaking Portal: https://www.regulations.gov. Follow the
instructions for submitting comments.
E-mail: FLB-2009-TP-0016@ee.doe.gov. Include the docket number
EERE-2009-BT-TP-0016 and/or RIN 1904-AB99 in the subject line of the
message.
Postal Mail: Ms. Brenda Edwards, U.S. Department of Energy,
Building Technologies Program, Mailstop EE-2J, 1000 Independence
Avenue, SW., Washington, DC, 20585-0121. Please submit one signed paper
original.
Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of
Energy, Building Technologies Program, 6th Floor, 950 L'Enfant Plaza,
SW., Washington, DC 20024. Telephone: (202) 586-2945. Please submit one
signed paper original.
For detailed instructions on submitting comments and additional
information on the rulemaking process, see section V, ``Public
Participation,'' of this document.
Docket: For access to the docket to read background documents or
comments received, visit the U.S. Department of Energy, 6th Floor, 950
L'Enfant Plaza, SW., Washington, DC 20024, (202) 586-2945, between 9
a.m. and 4 p.m., Monday through Friday, except Federal holidays. Please
call Ms. Brenda Edwards at (202) 586-2945 for additional information
regarding visiting the Resource Room.
FOR FURTHER INFORMATION CONTACT: Ms. Linda Graves, 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) 586-1851. E-mail:
Linda.Graves@ee.doe.gov. In the Office of General Counsel, contact Ms.
Betsy Kohl, U.S. Department of Energy, Office of the General Counsel,
GC-71, 1000 Independence Avenue, SW., Washington, DC 20585. Telephone:
(202) 586-7796. E-mail: Betsy.Kohl@hq.doe.gov.
For additional information on how to submit or review public
comments and on how to participate in the public meeting, contact Ms.
Brenda Edwards, 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)
586-2945. E-mail: Brenda.Edwards@ee.doe.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Authority and Background
II. Summary of the Proposal
III. Discussion
A. Scope of Applicability
1. Ballasts Covered
2. Effective Date
B. Existing Test Procedure
C. Drawbacks of Existing BEF Test Procedure
D. Efficiency Metric for Fluorescent Lamp Ballasts
E. Test Procedure Improvement Options
1. Resistor-Based Ballast Efficiency Correlated to Ballast
Efficacy Factor
2. Lamp-Based Ballast Efficiency Correlated to Ballast Efficacy
Factor
3. Improvements to Existing Test Procedure
4. Relative System Efficacy
F. Proposed Test Procedure
1. Test Conditions
2. Test Setup
3. Test Method
4. Calculations
5. Transfer Equations--General Method
6. Transfer Equations--Testing, Analysis, and Results
7. Resistor Value Determination
8. Non-Operational Ballasts When Connected to a Resistor
9. Existing Test Procedure Update
10. References to ANSI C82.2-2002
G. Burden to Conduct the Proposed Test Procedure
H. Impact on Measured Energy Efficiency
I. Certification and Enforcement
IV. Procedural Issues and Regulatory Review
A. Executive Order 12866
B. National Environmental Policy Act
C. Regulatory Flexibility Act
D. Paperwork Reduction Act
E. Unfunded Mandates Reform Act of 1995
F. Treasury and General Government Appropriations Act, 1999
G. Executive Order 13132
H. Executive Order 12988
I. Treasury and General Government Appropriations Act, 2001
J. Executive Order 13211
K. Executive Order 12630
L. Section 32 of the Federal Energy Administration Act of 1974
V. Public Participation
A. Attendance at Public Meeting
B. Procedure for Submitting Requests to Speak
C. Conduct of Public Meeting
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
1. All Aspects of the Existing Test Procedure for Active Mode
Energy Consumption
[[Page 14289]]
2. Appropriate Usage of ANSI Standards
3. Method of Measurement for Dimming Ballasts
4. Resistor-based Ballast Efficiency Test Method
5. Alternative Approaches to Amending the Test Procedure
6. Ballasts that do not Operate Resistors
7. Ballast Factor Variation Due to Variations in Measured Lamp
Power
8. Ballast Factor Binning
9. Transfer Equations
10. Scaling Transfer Equations
11. Burden on Manufacturers and Testing Facilities
VI. Approval of the Office of the Secretary
I. Authority and Background
Title III of the Energy Policy and Conservation Act (42 U.S.C. 6291
et seq.; EPCA or the Act) sets forth a variety of provisions designed
to improve energy efficiency. Part A of Title III (42 U.S.C. 6291-6309)
establishes the ``Energy Conservation Program for Consumer Products
Other Than Automobiles,'' which covers consumer products and certain
commercial products (all of which are referred to below as ``covered
products''), including fluorescent lamp ballasts (ballasts). (42 U.S.C.
6291(1)(2) and 6292(a)(13))
Under the Act, the overall program consists essentially of the
following parts: testing, labeling, and Federal energy conservation
standards. The testing requirements consist of test procedures,
prescribed under EPCA, that manufacturers of covered products must use
as the basis for certifying to the DOE that their products comply with
energy conservation standards adopted under EPCA and for
representations as to the efficiency of their products. Also, these
test procedures must be used whenever testing is required in an
enforcement action to determine whether covered products comply with
EPCA standards.
Section 323 of EPCA (42 U.S.C. 6293) sets forth generally
applicable criteria and procedures for DOE's adoption and amendment of
test procedures. It states, for example, that ``[a]ny test procedures
prescribed or amended under this section shall be reasonably designed
to produce test results which measure energy efficiency, energy use,* *
* or estimated annual operating cost of a covered product during a
representative average use cycle or period of use, as determined by the
Secretary [of Energy], and shall not be unduly burdensome to conduct.''
(42 U.S.C. 6293(b)(3)) In addition, if DOE determines that a test
procedure amendment is warranted, it must publish proposed test
procedures and offer the public an opportunity to present oral and
written comments on them. (42 U.S.C. 6293(b)(2)) Finally, in any
rulemaking to amend a test procedure, DOE must determine ``to what
extent, if any, the proposed test procedure would alter the measured
energy efficiency * * * of any covered product as determined under the
existing test procedure.'' (42 U.S.C. 6293(e)(1)) If DOE determines
that the amended test procedure would alter the measured efficiency of
a covered product, DOE must amend the applicable energy conservation
standard accordingly. (42 U.S.C. 6293(e)(2))
As to fluorescent lamp ballasts specifically, DOE must ``prescribe
test procedures that are in accord with ANSI \1\ standard C82.2-1984
\2\ or other test procedures determined appropriate by the Secretary.''
(42 U.S.C. 6293(b)(5)) DOE's existing test procedures for ballasts,
adopted pursuant to these and the above-described provisions, appear at
10 CFR Part 430, Subpart B, Appendix Q.
---------------------------------------------------------------------------
\1\ American National Standards Institute.
\2\ ``American National Standards for Fluorescent Lamp
Ballasts--Methods of Measurement.'' Approved October 21, 1983.
---------------------------------------------------------------------------
This test procedure rulemaking will fulfill the periodic review
requirement prescribed by the Energy Independence and Security Act of
2007. ``At least once every 7 years, the Secretary shall review test
procedures for all covered products and--amend test procedures with
respect to any covered product * * * or publish notice in the Federal
Register of any determination not to amend a test procedure.'' (42
U.S.C. 6293(b)(1)(A) DOE invites comment on all aspects of the existing
test procedures for fluorescent lamp ballasts for active mode energy
consumption that appear at Title 10 of the CFR Part 430, Subpart B,
Appendix Q (``Uniform Test Method for Measuring the Energy Consumption
of Fluorescent Lamp Ballasts'').
In a separate rulemaking proceeding, DOE is considering amending
energy conservation standards for fluorescent lamp ballasts (docket
number EERE-2007-BT-STD- 0016; hereinafter referred to as the
``fluorescent lamp ballast standards rulemaking''). DOE initiated that
rulemaking by publishing a Federal Register (FR) notice announcing a
public meeting and availability of the framework document (``Energy
Efficiency Program for Consumer Products: Public Meeting and
Availability of the Framework Document for Fluorescent Lamp
Ballasts,'') on January 22, 2008. 73 FR 3653. DOE has completed the
preliminary analyses for the energy conservation standard rulemaking
and published in today's Federal Register a notice announcing a public
meeting and availability of the preliminary technical support document.
On February 6, 2008, DOE held a public meeting in Washington, DC,
to discuss the framework document for the fluorescent lamp ballast
energy conservation standards rulemaking (hereinafter referred to as
the ``2008 public meeting''). At that meeting, attendees also discussed
potential revisions to the test procedure for active mode energy
consumption. All comments on the fluorescent lamp ballast standards
rulemaking regarding the measurement of active mode energy consumption
are discussed in section III of this proposed rulemaking.
DOE has also completed a standby mode and off mode test procedure.
The Energy Independence and Security Act of 2007 (Pub. L. 110-140)
amended EPCA to require that, for each covered product for which DOE's
current test procedures do not fully account for standby mode and off
mode energy consumption, DOE amend the test procedures to include
standby mode and off mode energy consumption into the overall energy
efficiency, energy consumption, or other energy descriptor for that
product. If an integrated test procedure is technically infeasible, DOE
must prescribe a separate standby mode and off mode energy use test
procedure, if technically feasible. (EPCA section 325(gg)(2)(A); 42
U.S.C. 6295(gg)(2)(A)) DOE published a final rule addressing standby
mode and off mode energy consumption for fluorescent lamp ballasts in
the Federal Register on October 22, 2009. 74 FR 54445.
II. Summary of the Proposal
In this notice of proposed rulemaking (NOPR), DOE proposes to
modify the current test procedures for fluorescent lamp ballasts to
revise the scope of applicability of this test procedure for
consistency with the ongoing fluorescent lamp ballast standards
rulemaking, improve measurement variability, and update the referenced
standards. DOE also proposes provisions for manufacturers to submit
compliance statements and certification reports for fluorescent lamp
ballasts. The following paragraphs summarize these proposed changes.
In the preliminary technical support document for the fluorescent
lamp ballast standards rulemaking, DOE makes a preliminary
determination of the scope of coverage. Today's proposed test procedure
includes specific procedures for ballasts identified in the preliminary
determination of scope. If the scope of coverage changes in the
fluorescent lamp ballast standards
[[Page 14290]]
rulemaking, DOE will add or remove provisions from the test procedure
so that it is consistent with the final scope of coverage of standards.
The preliminary determination of scope includes ballasts that operate
multiple numbers of lamps (one through six), all values of ballast
factor, and many different lamp classes including 4-foot medium bipin
T8 and T12 lamps, 4-foot T5 miniature bipin lamps, 8-foot single pin
slimline T8 and T12 lamps, and 8-foot recessed double contact high
output T8 and T12 lamps. See section III.A.1 for further detail.
In addition to matching the scope of coverage for the active mode
test procedure to the scope of coverage being considered in the
fluorescent lamp ballast standards rulemaking, the proposed amendments
seek to reduce the measurement variation inherent in the existing test
procedure. The existing test procedure exhibits variation in
measurements of a similar magnitude to the spread in efficiency within
many fluorescent lamp ballast product classes analyzed in the
preliminary determination. The test measurement variation can be
attributed to reference lamp variation, lamp operation conditions, and
ballast wiring. DOE believes a test procedure with reduced variation
will allow for more precise standard setting and certification,
compliance, and enforcement testing.
DOE's proposed test method greatly reduces the impact of reference
lamps on measurement variation. The method calculates a ballast input
power and output power using only electrical measurements and resistors
that simulate the load placed on a ballast by a fluorescent lamp at a
given operating condition. Because a resistor can be manufactured with
much smaller performance tolerances than a fluorescent lamp, the
resistor introduces much less variation to the operating
characteristics of the ballast. This revised test method delivers
increased precision, thereby allowing for greater resolution. The
procedure proposed in this rulemaking measures ballast input power and
ballast output power and then calculates ballast electrical efficiency
(output power divided by input power). The ballast electrical
efficiency is then converted to ballast efficacy factor (BEF) using a
transfer equation to maintain the reported metric for energy efficiency
as BEF for consistency with use of BEF in 42 U.S.C. 6295(g)(5) and
(g)(8). DOE developed the transfer equation by measuring several
ballasts within a product class for ballast efficiency (BE) using the
proposed BE test procedure and for BEF using the existing test
procedure, and then calculating a line of best fit for the combined
data. This proposed method is hereafter referred to as the resistor-
based ballast efficiency test procedure.
Prior to selecting the proposed test method, DOE also considered
three other methods as potential improvements in the revised test
procedure: (1) The lamp-based ballast efficiency (correlated to BEF)
method, (2) the existing BEF method with revisions to reduce variation;
and (3) the relative system efficacy (RSE) method. DOE's initial
assessment of the lamp-based ballast efficiency method, which uses a
lamp as a load, rather than a resistor, indicated that, similar to the
resistor-based ballast efficiency method, there could be significant
improvements by eliminating light output-based measurements. However,
adopting that method would result in a test procedure that was still
susceptible to lamp-to-lamp variability. DOE explored the existing
light-output-based test procedure and found improvements could be made
without making fundamental changes. DOE believes that tightening
tolerances on certain specifications and clarifying loosely-defined
directions can reduce measurement variation relative to the existing
test procedure for fluorescent ballasts, but to a lesser extent than
the proposed resistor-based BE test procedure. DOE found the RSE method
to exhibit larger variation than the proposed resistor-based BE test
procedure because it uses the same measurement techniques as the
existing test procedure.
In any rulemaking to amend a test procedure, DOE must determine
``to what extent, if any, the proposed test procedure would alter the
measured energy efficiency * * * of any covered product as determined
under the existing test procedure.'' (42 U.S.C. 6293(e)(1)) If DOE
determines that the amended test procedure would alter the measured
efficiency of a covered product, DOE must amend the applicable energy
conservation standard accordingly. (42 U.S.C. 6293(e)(2)) The proposed
test procedure would change the measured energy efficiency of some
products relative to the existing test procedure. To ensure that the
standards developed in the ongoing fluorescent lamp ballast standards
rulemaking account for any changes to the test procedure, DOE is
developing the standards based on the measured energy efficiency
generated by the active mode test procedure proposed in this
rulemaking. As a result, DOE proposes an effective date for this
revised test procedure, to be published as Appendix Q1 of 10 CFR part
430 Subpart B, concurrent with the compliance date of the fluorescent
lamp ballast standards rulemaking (approximately June 30, 2014). DOE
plans to publish the final rule establishing the procedures in Appendix
Q1 in the same rule document as the final rule establishing any amended
standards.
DOE notes that ballasts that operate one or two 40 or 34 watt (W)
4-foot T12 medium bipin lamps (F40T12 and F34T12), two 75 W or 60 W 8-
foot T12 single pin slimline lamps (F96T12 and F96T12/ES); and two 110
W and 95 W 8-foot T12 recessed double contact high output lamps
(F96T12HO and F96T12HO/ES) are covered by existing energy conservation
standards. 10 CFR 430.32(m). Until the proposed effective date of the
test procedure to be published at Appendix Q1, these ballasts should
continue to be tested using the existing test procedure to determine
compliance with existing standards. DOE proposes in this NOPR to make
minor updates to the existing test procedure, published at Appendix Q
to Subpart B of part 430. DOE would update the reference to ANSI C82.2-
1984 in the existing test procedure (appendix Q) to ANSI C82.2-2002.
Because DOE does not believe the updated standard will impose increased
testing burden or alter the measured BEF of fluorescent lamp ballasts,
DOE proposes that the amendments to Appendix Q be effective 30 days
after publication of this test procedure final rule. DOE notes that
because use of the test method in Appendix Q1 is not appropriate for
those ballasts that cannot operate a resistor load bank, manufacturers
would continue to test those ballasts using the test method set forth
in Appendix Q. In addition, the test procedures for any ballasts that
operate in standby mode are also located in Appendix Q.
DOE also proposes amending the language in 10 CFR 430.62 to require
fluorescent lamp ballast manufacturers to submit compliance statements
and certification reports. This provision would also be effective 30
days after publication of this test procedure final rule. Ballast
manufacturers would begin to submit these documents to certify
compliance with existing fluorescent lamp ballast energy conservation
standards using the test procedures at Appendix Q one year following
publication of this final rule. Ballast manufacturers would certify
compliance with any amended standards using the test procedures at
Appendix Q1 beginning one year following the compliance date of the
amended standards.
[[Page 14291]]
III. Discussion
A. Scope of Applicability
1. Ballasts Covered
Today's proposed test procedure is applicable to the fluorescent
lamp ballasts covered in the preliminary determination of scope
outlined in the preliminary technical support document for the
fluorescent lamp ballast standards rulemaking. The preliminary
determination of scope is as follows:
(1) Ballasts that operate one, two, three, four, five, or six
straight-shaped lamps (commonly referred to as 4-foot medium bipin
lamps) with medium bipin bases, a nominal overall length of 48
inches, a rated wattage \3\ of 25 watts (W) or more, and an input
voltage at or between 120 volts (V) and 277 V;
---------------------------------------------------------------------------
\3\ The July 14, 2009 final rule establishing amended energy
conservation standard for general service fluorescent lamps and
incandescent reflector lamps (74 FR 34080) adopted a new definition
for ``rated wattage'' that can be found in 10 CFR 430.2. Please see
https://www1.eere.energy.gov/buildings/appliance_standards/residential/incandescent_lamps.html for further information.
---------------------------------------------------------------------------
(2) Ballasts that operate one, two, three, four, five, or six U-
shaped lamps (commonly referred to as 2-foot U-shaped lamps) with
medium bipin bases, a nominal overall length between 22 and 25
inches, a rated wattage of 25 W or more, and an input voltage at or
between 120 V and 277 V;
(3) Ballasts that operate one or two rapid-start lamps (commonly
referred to as 8-foot high output lamps) with recessed double
contact bases, a nominal overall length of 96 inches and an input
voltage at or between 120 V and 277 V;
(4) Ballasts that operate one or two instant-start lamps
(commonly referred to as 8-foot slimline lamps) with single pin
bases, a nominal overall length of 96 inches, a rated wattage of 52
W or more, and an input voltage at or between 120 V and 277 V;
(5) Ballasts that operate one or two straight-shaped lamps
(commonly referred to as 4-foot miniature bipin standard output
lamps) with miniature bipin bases, a nominal length between 45 and
48 inches, a rated wattage of 26 W or more, and an input voltage at
or between 120 V and 277 V;
(6) Ballasts that operate one, two, three, or four straight-
shaped lamps (commonly referred to as 4-foot miniature bipin high
output lamps) with miniature bipin bases, a nominal length between
45 and 48 inches, a rated wattage of 49 W or more, and an input
voltage at or between 120 V and 277 V;
(7) Ballasts that operate one, two, three, or four straight-
shaped lamps (commonly referred to as 4-foot medium bipin lamps)
with medium bipin bases, a nominal overall length of 48 inches, a
rated wattage of 25 W or more, an input voltage at or between 120 V
and 277 V, a power factor of less than 0.90, and designed and
labeled for use in residential applications; and
(8) Ballasts that operate one, two, three, four, five, or six
rapid-start lamps (commonly referred to as 8-foot high output lamps)
with recessed double contact bases, a nominal overall length of 96
inches, an input voltage at or between 120 V and 277 V, and that
operate at ambient temperatures of 20 degrees Fahrenheit ([deg]F) or
less and are used in outdoor signs.
For the proposed test procedure in this rulemaking, DOE would
establish particular test setups and calculations depending on the
product class. When evaluating and establishing energy conservation
standards, DOE divides covered products into product classes by the
type of energy used, capacity, or other performance-related features
that affect efficiency, considering factors such as the utility of the
product to users. (See 42 U.S.C. 6295(q)) The fluorescent lamp ballast
standards rulemaking delineates product classes based on the maximum
number of lamps operated by a ballast, ballast factor, starting method,
lumen package,\4\ lamp base, market sector, and lamp length. Ballasts
contained in the same product class are subject to the same energy
conservation standards.
---------------------------------------------------------------------------
\4\ Lumen package refers to the quantity of light generated by a
lamp and ballast system. For example, 8-foot RDC high output HO
lamps and 4-foot miniature bipin (MiniBP) HO lamps tend to operate
at higher currents than 8-foot single pin (SP) slimline lamps and 4-
foot MiniBP standard output (SO) lamps, respectively. This
difference in operating design increases the quantity of light per
unit of lamp length.
---------------------------------------------------------------------------
At the 2008 Framework public meeting for the fluorescent lamp
ballast standards rulemaking, the Appliance Standards Awareness Project
(ASAP) asked DOE to elaborate on how the schedules for the fluorescent
lamp ballast energy conservation standard and active mode test
procedure rulemakings interact. (ASAP,\5\ Public Meeting Transcript,
No. 9 at p. 29) Because the fluorescent lamp ballast standards
rulemaking is in the preliminary analysis phase of the rulemaking
process, the proposed scope of coverage is still in draft form. To
ensure consistency in the scope of coverage, DOE plans to publish the
final rule for this test procedure rulemaking concurrently with the
ballasts standards rulemaking final rule (scheduled for June 30, 2011).
Concurrent publication affords DOE the opportunity to synchronize its
test procedure with the final scope of coverage for the fluorescent
lamp ballast standards rulemaking. If a ballast type \6\ is removed
from the scope of coverage, DOE will eliminate the pertinent test
procedures from the active mode test procedure in the final rule.
Conversely, in the event additional ballasts are added to the scope of
coverage, DOE will develop test procedures for these ballasts and
update the active mode test procedure in a subsequent rulemaking. For
example, in the preliminary analyses of the fluorescent lamp ballast
standards rulemaking, DOE's preliminary scope of coverage that does not
include ballasts capable of dimming. As DOE invites comment on this in
the fluorescent lamp ballast standards rulemaking, if DOE's final scope
of coverage includes dimming ballasts, DOE will need finalize test
procedures for these ballasts. DOE also invites comment in this test
procedure rulemaking on suggested methods of measuring the efficiency
of dimming-capable ballasts.
---------------------------------------------------------------------------
\5\ A notation in the form ``ASAP, Public Meeting Transcript,
No. 9 at p. 29'' identifies a statement made in a public meeting
that DOE has received and has included in the docket of this
rulemaking. This particular notation refers to a comment: (1)
Submitted during the public meeting on February 6, 2008; (2) in
document number 9 in the docket of this rulemaking; and (3)
appearing on page 29 of the transcript.
\6\ Ballast type refers to a grouping of ballasts that use the
same starting method, and operate lamps of the same diameter, lumen
package, base type, and length. For example, instant-start ballasts
that operate 4-foot medium bipin T8 lamps.
---------------------------------------------------------------------------
2. Effective Date
Because some of the test procedure amendments proposed for Appendix
Q1 will change measured efficiency and therefore affect compliance with
existing standards, DOE proposes an effective date of the revised test
procedure in Appendix Q1 to Subpart B concurrent with the compliance
date of the energy conservation standards prescribed by the fluorescent
lamp ballast standards rulemaking. DOE also plans to publish the final
rule establishing the procedures in Appendix Q1 in the same rule
document as the final rule establishing any amended standards. In the
fluorescent lamp ballast standards rulemaking, DOE is developing
standards that correspond with the active mode test procedure proposed
in this rulemaking. The proposed active mode test procedure would be
used to test ballast efficiency on or after the compliance date of the
fluorescent lamp ballast standards rulemaking (approximately June
2014). Until this compliance date, fluorescent lamp ballasts would
continue to be tested using the existing test procedure in Appendix Q
to determine compliance with existing standards. Because the
modifications to Appendix Q (an update to referenced industry
standards) do not affect the measured efficiency, DOE proposes that
they be effective 30 days after publication of this test procedure
final rule. DOE notes that because use
[[Page 14292]]
of the test method in Appendix Q1 is not appropriate for those ballasts
that cannot operate a resistor load bank, manufacturers would continue
to test those ballasts using the test method set forth in Appendix Q.
In addition, the test procedures for any ballasts that operate in
standby mode are also located in Appendix Q.
Certification and compliance procedures for fluorescent lamp
ballasts are also proposed in this rulemaking. Because these provisions
also do not affect measured efficiency, DOE proposes that they be
effective 30 days after publication of this test procedure final rule.
Accordingly, manufacturers of fluorescent lamp ballasts would be
required to submit compliance statements and certification reports to
certify compliance with existing standards, using the test procedures
at Appendix Q, one year following publication of the test procedure
final rule. Ballast manufacturers would certify compliance with any
amended standards using the test procedures at Appendix Q1 beginning
one year following the compliance date of the amended standards.
B. Existing Test Procedure
The existing ballast test procedure (in Appendix Q to Subpart B of
10 CFR part 430) used to determine the energy efficiency of a
fluorescent lamp ballast is based on light output measurements and
ballast input power. The metric used is called ballast efficacy factor
(BEF). BEF is the relative light output divided by the power input of a
fluorescent lamp ballast, as measured under test conditions specified
in ANSI standard C82.2-1984, or as may be prescribed by the Secretary.
42 U.S.C. 6291(29)(C)
The BEF metric uses light output of the lamp and ballast system
instead of ballast electrical output power in its calculation of the
efficiency of a ballast. To measure relative light output, ANSI C82.2-
1984 directs the user to measure the photocell output \7\ of the test
ballast operating a reference lamp and the light output of a reference
ballast operating the same reference lamp. Dividing photocell output of
the test ballast by the photocell output of the reference ballast
yields relative light output or ballast factor (BF). Concurrent with
measuring relative light output, the user is directed to measure
ballast input power. BEF is then calculated by dividing relative light
output by input power. A ballast that produces more light than another
ballast with the same input power will have a larger BEF.
---------------------------------------------------------------------------
\7\ The photocell output of a light source is measured in units
of watts. Photocell output (watts) is one method of measuring the
light output of a light source. Through the remainder of this
document, DOE refers to the output of a fluorescent lamp as ``light
output,'' even though the existing test procedure indicates
measuring the light with photocell output.
---------------------------------------------------------------------------
C. Drawbacks of Existing BEF Test Procedure
In response to the framework document for the fluorescent lamp
ballast standards rulemaking, DOE received numerous written and verbal
comments from interested parties on the usage of ballast efficacy
factor as the metric for describing the energy consumption of
fluorescent lamp ballasts. The National Electrical Manufacturers
Association (NEMA) commented that in previous rulemakings regarding
efficiency of ballasts, the variation in BEF measurements was less of
an issue because the range of efficiency in the market was much larger.
The spread in the measured energy efficiency between magnetic and
electronic ballasts, for example, was much larger than the measurement
variation inherent to the existing test procedure. However, in the
current market, the spread in efficiency between ballasts has a much
smaller range. (NEMA, Public Meeting Transcript, No. 9 at p. 23, pp.
56-57) NEMA commented that DOE should change the metric away from BEF
because BEF measurements made in accordance with the current
fluorescent lamp ballast test procedure (appendix Q) can be shown to
have a measurement uncertainty on the order of 5 percent. NEMA stated
that when measuring the same ballast at different test laboratories
with different examples of the same reference lamp, the spread in test
results is similar to the range of T8 ballast BEFs observed in the
market today. NEMA reasoned that in order to have meaningful
verification of a standard DOE would need a metric that delineates
between the products on the market. According to NEMA, the ballast
industry would be challenged to come to consensus on a standard when so
much variation existed in the data. (NEMA, Public Meeting Transcript,
No. 9 at p. 23, pp. 35-36, pp. 56-58; NEMA,\8\ No. 11 at p. 2)
---------------------------------------------------------------------------
\8\ A notation in the form ``NEMA, No. 11 at p. 2'' identifies a
written comment that DOE has received and has included in the docket
of this rulemaking or a written docket submission. This particular
notation refers to a comment: (1) Submitted by NEMA; (2) in document
number 11 in the docket of this rulemaking; and appearing on page 2.
---------------------------------------------------------------------------
DOE understands NEMA's concerns regarding the measurement
uncertainty related to the BEF measurement method under the existing
fluorescent lamp ballast test procedure. The measurement uncertainty
would negatively impact DOE's ability to set standards for ballasts, as
it could be difficult to distinguish between typical and high-
efficiency ballasts. DOE agrees with NEMA's description that the range
of efficiencies of ballasts available in the market have in general
decreased and acknowledges the need for a test method or metric that
reduces systematic error and generates more reliable test results.
Reduced variation in test procedure calculations will allow for more
precise standard setting and certification, compliance, and enforcement
testing. DOE is proposing a test procedure that is designed to reduce
systematic error and enhance energy conservation standard-setting
capabilities.
NEMA also stated that lamp manufacturing variations will create
variations in measured BEF values. (NEMA, Public Meeting Transcript,
No. 9 at p. 38; NEMA, No. 11 at p. 6; GE, Public Meeting Transcript,
No. 9 at p. 43) DOE agrees that a number of factors, in particular the
manufacturing variability of lamps, can contribute to producing this
uncertainty. Due to lamp manufacturing variability and in order to
reduce the performance variation among those lamps selected for
testing, industry standards referenced in the test procedure specify a
narrower range of operating conditions for reference lamps. ANSI C82.1-
1977 (referenced by ANSI C82.2-1984) specifies that a reference lamp
must not vary more than 2.5 percent from the lamp parameters given in
the ANSI C78 Series (1972 edition and 1975 supplement) for fluorescent
lamp electrical characteristics. Even this narrowed variation allowed
in the measured lamp power, however, has a significant impact on the
variation in BEF. Changes in measured lamp input power result in
disproportionate changes to the numerator (ballast factor) and the
denominator (input power) in the BEF metric. The percent change in
ballast factor is not as great as the percent change in ballast input
power for a given change in measured lamp input power. Consequently,
the same ballast will generate different values of BEF when tested on
reference lamps with different measured power.
GE commented that in addition to reference lamp manufacturing
variation, BEF can vary depending on the testing facility. (GE, Public
Meeting Transcript, No. 9 at p. 43) DOE agrees that deviations in test
facility environmental conditions can result in dissimilarities in
measured BEF. ANSI C82.2-1984 (incorporated in the existing test
procedure) allows ambient temperature
[[Page 14293]]
to vary 1 degrees Celsius ([deg]C) from 25 [deg]C. Through
testing, DOE has shown ambient temperature to have an effect on BEF
measurements. Specifically, DOE found that changes in ambient
temperature as small as 1 [deg]C resulted in changes in BEF as much as
1.5 percent.
NEMA commented that the BEF measurement requires photometric
measurements of a reference lamp attached to the test ballast; thus,
BEF values cannot be compared across ballasts that operate different
lamp types. A more appropriate metric would not depend on lamp
parameters or requirements. (NEMA, Public Meeting Transcript, No. 9 at
p. 38, pp. 124-125; NEMA, No. 11 at p. 6) NEMA also stated that an
alternative metric that is comparable across all instant-start or
programmed-start ballasts and capable of including lamp types yet to be
developed would be preferable to the existing test procedure using BEF.
(NEMA, Public Meeting Transcript, No. 9 at pp. 76-77, p. 99) NEMA
further commented that some lamps do not have ANSI standards governing
their operating characteristics. Considerable variation in lamp
operating conditions exists among manufacturers for these lamps because
the industry has not reached a formal consensus. (NEMA, Public Meeting
Transcript, No. 9 at pp. 76-77) NEMA suggested that DOE consider an
alternative metric based on measuring ballast input and output
electrical power as discussed in section III.E. (NEMA, Public Meeting
Transcript, No. 9 at p. 32, pp. 37-38)
DOE recognizes that BEF is not comparable across all ballasts. BEF
is measured and calculated using fluorescent lamps that vary in
measured power, thereby impacting ballast input power. As a
consequence, BEF is dependent on lamp type.\9\ DOE plans to organize
the covered ballasts into different product classes based on consumer
utility and energy efficiency differences. Because DOE will consider a
separate energy conservation standard for each of these product
classes, the test procedure must make comparisons in energy efficiency
possible within a product class. However, the existing BEF method does
not allow for such comparisons in all circumstances, as explained in
the following paragraph. DOE recognizes that comparison across product
classes may also be useful for consumers of fluorescent lamp ballasts.
DOE addresses this issue in its discussion of the resistor-based BE
method in section III.E.1.
---------------------------------------------------------------------------
\9\ Lamp type describes a grouping of lamps that have the same
length, lumen package, base type, and diameter.
---------------------------------------------------------------------------
In the ongoing fluorescent lamp ballast standards rulemaking, DOE
has tentatively determined there is no distinct consumer utility
difference between T8 and T12 ballasts. As a result, DOE is considering
grouping T8 and T12 ballasts in the same product class. Due to the
difference in rated powers of the reference lamps, however, measured
BEF values for T8 and T12 ballasts are not comparable. Because DOE
plans to subject certain T8 and T12 ballasts to the same energy
conservation standard (by including these ballasts in the same product
class), DOE agrees that amendments to the existing active mode test
procedure to allow for greater comparability across lamp types is
warranted. Therefore, in this notice DOE proposes to revise the test
procedure such that the reported BEF for a T12 ballast will be
comparable to the reported BEF for a T8 ballast. These proposed
revisions are discussed in further detail in section III.F.5.
DOE also agrees that the revised test procedure and metric should
be able to encompass newly-developed lamps. The industry has not come
to consensus on operating specification standards for some of these
new, reduced-wattage lamps. Without consistent industry standards for
lamps, light-output-based testing of BEF can vary greatly. DOE proposes
to test ballasts while operating one representative load,
characterizing the lamp wattage most commonly operated. The development
and marketing of new, reduced-wattage lamps (with or without ANSI
standards) is not a concern because today's test procedure proposes to
specify a particular lamp and ballast combination for testing. See
section III.F.2 for additional detail on DOE's preliminary decision to
test ballasts while operating a load characteristic of the most common
wattage lamp.
NEMA commented that lamp filament heating introduces variability
into the existing BEF measurement (NEMA, Public Meeting Transcript, No.
9 at p. 39). DOE agrees the existing ballast test procedure is unclear
on whether or not electrode heating should be used in the reference
circuit. Electrode heating is known to increase the efficiency of a
lamp, which means the same amount of input power produces more light.
Consequently, the ballast factor of a test ballast tends to be smaller
if the reference circuit uses electrode heating compared to a reference
circuit without electrode heating. DOE agrees that the current test
procedure inserts some variability into the measurement of BF and
consequently BEF due to the apparent flexibility in the use of
reference circuit heating. In today's proposed test procedure, DOE
addresses this issue by specifying that electrode heating should always
be used in the reference circuit for medium bipin, recessed double
contact, and miniature bipin lamps. Electrode heating should not be
used in the reference circuit for single pin lamps. As discussed in
section III.E.3, DOE believes specifying whether electrode heating
should be used in the reference case limits opportunity for introducing
variation in the test procedure. DOE also understands that the
efficiency change due to electrode heating may vary from lamp to lamp.
DOE believes the variation to be relatively small, though it does not
have quantitative data to characterize this variation among lamps. DOE
invites comment on reasonable techniques to reduce this source of
variation.
NEMA also commented that filament heating should be taken into
account in comparison of ballasts with different starting methods.
(NEMA, Public Meeting Transcript, No. 9 at p. 39) DOE is aware starting
method can impact the measurement of ballast output power. Ballasts
that employ constant electrode heating generate smaller BEF values than
ballasts without constant electrode heating. Because BEF considers the
light output of a ballast, constant cathode heating tends to decrease
BEF because some of the ballast output power is used for purposes other
than light production. From a system viewpoint, however, BEF reflects
the loss in lighting efficiency due to electrode heating. Contrary to
NEMA, DOE does not believe that power dissipated by the lamp electrodes
should be included in the measurement of output power as this power is
not used directly toward the primary function of producing light. DOE
notes that it will consider setting specific standards for ballasts
that employ electrode heating based on any potential consumer utility
differences \10\ in the ongoing fluorescent lamp ballast standards
rulemaking.
---------------------------------------------------------------------------
\10\ In the fluorescent lamp ballast standards rulemaking, DOE
has tentatively determined that while rapid-start ballasts do not
offer distinct utility compared to instant-start ballasts,
programmed-start ballasts do offer distinct utility compared to
instant-start ballasts. DOE found that consumers frequently use
rapid-start ballasts as replacements for instant-start ballasts.
Programmed-start ballasts, however, can increase lamp lifetime for
frequent on/off cycling applications (e.g. for use with occupancy
sensors), providing consumer utility. Therefore, DOE has tentatively
determined to group rapid-start ballasts and instant-start ballast
in the same product class and place programmed-start ballasts in a
separate product class.
---------------------------------------------------------------------------
NEMA also indicated T8 ballasts are particularly impacted by
measurement
[[Page 14294]]
uncertainty because much of the T8 ballast market is high-frequency
electronic and T8 lamps are first operated on a low-frequency (60-
hertz) reference ballast during BEF testing. NEMA asserted that lamps
increase in efficiency when switching from low- to high-frequency
operation, but that all lamps will not gain exactly the same amount of
efficiency. NEMA mentioned it could provide data to show error of
several percent when the same ballast is tested at different labs with
different lamps due to the high-frequency to low-frequency comparison.
(NEMA, Public Meeting Transcript, No. 9 at p. 26, p. 39)
DOE agrees that random error is introduced into the measurement and
calculation of BEF due to variation in lamp efficiency gains when
switching from magnetic to electronic ballasts. In general, when a lamp
is run at high-frequency (electronic ballasts), the lamp requires less
power to produce the same amount of light when compared to a low-
frequency (magnetic) ballast. Electronic ballasts run at high
frequency, so they tend to display higher BEF values than low-frequency
magnetic ballasts. Part of this difference is due to the lamp operating
at a lower rated wattage (increased efficiency), while the remainder is
due to improvements in the electrical efficiency of the ballast. ANSI
does not specify high-frequency reference conditions for 32W F32T8, 60W
F96T12/ES, 95W F96T12HO/ES, and 110W F96T12HO fluorescent lamps.
Another source of variation in the existing test procedure is lamp
and ballast wiring for rapid- and programmed-start ballasts. These
ballasts have two wires connected to the pins on each end of the lamp.
One of the two wires supplies power to the lamp arc, and the second
provides power to the electrode. Depending on which pin the lamp arc
wire is connected to, the current supplied to the lamp arc will
encounter different amounts of resistance. The difference in resistance
is due to the position on the lamp electrode where the current starts
and finishes the lamp arc. When this position (hotspot) is in the
center of the electrode, wiring differences do not change the measured
BEF. However, when the hotspot is closer to one end or the other of the
electrode, the current encounters varied resistances based on the
distance it must travel through the electrode. Because ballast wires
are not identified as delivering energy to the lamp arc or electrode
and the position of the hotspot is unknown, this source of variation
cannot be eliminated.
At the framework document public meeting, DOE received comments
that ballast manufacturers and independent test labs use light output
measurements for calculating ballast factor for both rapid-start and
instant-start ballasts. (GE, Public Meeting Transcript, No. 9 at p. 73;
Philips, Public Meeting Transcript, No. 9 at p. 74) ANSI C82.2-1984
suggests the usage of power measurements for instant-start systems, but
common industry practice has been the usage of light output
measurements for all ballast starting methods. Ballast factor can be
calculated either as a ratio of test and reference circuit light output
or as a ratio of measured lamp power. DOE notes that power measurements
are somewhat impractical to conduct on ballasts that employ electrode
heating because these ballasts use two wires to connect to a lamp
electrode. The presence of additional wires requires more measurements
to determine output power which introduces error into the results. DOE
believes this technique introduces significant error through
capacitance to ground and loading effects on ballasts that use
electrode heating. As discussed in section III.E.3, DOE believes that
one way to reduce this error would be to require light-output
measurements to be used for all ballast types.
D. Efficiency Metric for Fluorescent Lamp Ballasts
A joint comment (hereafter the ``Joint Comment'') submitted by
ASAP, the American Council for an Energy-Efficient Economy (ACEEE), the
Alliance to Save Energy (ASE), the Natural Resources Defense Council
(NRDC), the Northeast Energy Efficiency Partnerships (NEEP), and the
Northwest Power and Conservation Council (NPCC) suggested that DOE
consider a metric other than BEF that permits comparison between
different lamp wattages, ballast types, and numbers of lamps operated
by a ballast. (Joint Comment, No. 12 at p. 1) NEMA also recommended
that DOE consider changing the metric away from BEF and toward an
alternate metric. (NEMA, No. 11 at p. 2, pp. 11-12) NEMA suggested if
DOE cannot change the metric from BEF, it should develop a test
procedure that requires the measurement of some other metric unrelated
to lamp lumen output, such as ballast efficiency \11\ or relative
system efficacy,\12\ and then give correlations to BEF so that BEF can
still be used in standard-setting. The New York State Energy Research
and Development Authority (NYSERDA) also recommended consideration of
RSE as an alternative metric. (NYSERDA, No. 9, pp. 27-28) NEMA asked if
DOE might accept a NEMA- and ANSI-supported method of measuring BE, and
correlating BE measurements with BEF values. (NEMA, Public Meeting
Transcript, No. 9 at p. 32, pp. 37-38)
---------------------------------------------------------------------------
\11\ Ballast efficiency aims to capture the electrical
efficiency of a ballast by eliminating usage of lamps and
photometric measurements in the test method. Ballast efficiency
equals ballast output power divided by ballast input power. See
section III.E.4.
\12\ Relative system efficacy provides a greater range of
comparability among ballast types in comparison to ballast efficacy
factor. RSE is based on the BEF metric and creates minimal
incremental testing burden. See section III.E.4.
---------------------------------------------------------------------------
The energy conservation standard is specified using the metric of
ballast efficacy factor. 42 U.S.C. 6295(g)(5), (g)(8) In this
rulemaking, DOE proposes measuring an alternate metric (ballast
efficiency) and using a set of correlation functions so that BEF values
can be reported.
Acuity Brands Lighting also commented that much of the marketplace
(end-users, lighting designers, architects, and electrical engineers)
do not use the BEF metric and may not have knowledge of it. Acuity
Brands indicated that luminaire manufacturers are the primary users of
BEF values, using them in ballast purchasing decisions for selection of
products compliant with regulations. Acuity Brands also indicated that
a change in metric would not impact the end-user as much it may impact
luminaire manufacturers. (Acuity Brands Lighting, Public Meeting
Transcript, No. 9 at pp. 45-46) DOE understands that the lighting
design process involves metrics other than BEF. Lamp, ballast, and
luminaire combinations may be more or less efficient when analyzed as a
complete system. End-users may make their purchasing decisions from
this system viewpoint. DOE appreciates this comment; however, DOE
proposes the use of transfer equations to convert BE values to BEF for
consistency with use of the BEF metric in 42 U.S.C. 6295(g)(5) and
(g)(8).
The Joint Comment suggested that an alternate metric should account
for all power loads served by the ballast, including lamp arc power,
cathode power, and standby power consumption. (Joint Comment, No. 12 at
p. 1) DOE understands the importance of capturing all power loads
served by a fluorescent lamp ballast. DOE notes that BEF does capture
all power modes listed by the Joint Comment (lamp arc power and cathode
power) except for standby mode consumption. However, DOE does not
believe it is feasible to incorporate standby power into the BEF
metric. The BEF metric relates light
[[Page 14295]]
output (relative to a reference system) to input power. Ballasts that
produce more light using the same input wattage have a larger BEF
value. Standby mode power, however, performs a different function.
Instead of using power for light output, standby mode power is used to
facilitate activation or deactivation of other functions (active mode
functions, i.e., light output) by a remote switch. Because BEF is a
measure of light output divided by input power and not energy
consumption, DOE does not believe it is feasible to incorporate a
measure of standby mode energy use into the BEF metric for active mode
energy consumption. While DOE's preliminary determination of the scope
of coverage in the fluorescent lamp ballasts standards rulemaking does
not include ballasts capable of operating in standby mode, if the scope
of coverage changes to include these ballasts, DOE will set separate
standby mode energy conservation standards. Test procedures for the
measurement of standby mode energy consumption for fluorescent lamp
ballasts can be found in Appendix Q.
E. Test Procedure Improvement Options
Given that alternative methods of testing may result in reduced
measurement variation compared to the existing test procedure for BEF,
DOE considered three new methods for measuring the efficiency of a
ballast and one improved version of the existing method. The first
method is called the resistor-based ballast efficiency method, and
requires first measuring an estimate of ballast electrical efficiency
when operating a resistor load and then converting the estimate to BEF.
The second method, called the lamp-based ballast efficiency method,
involves measuring ballast efficiency using a lamp as the ballast load
and then converting that BE to BEF. The third method makes small
changes to the existing test procedure to improve the precision of BEF
measurement. The fourth method measures relative system efficacy, which
is a variation of ballast efficacy factor that is more comparable
across ballast types. While DOE proposes the first method to be used as
the new test procedure for determination of fluorescent lamp ballast
energy consumption, DOE is still considering all of these options for
improvement of the test procedure and therefore invites comments on all
alternative methods. The following sections discuss the merits and
drawbacks of the four methods.
1. Resistor-Based Ballast Efficiency Correlated to Ballast Efficacy
Factor
NEMA suggested at the framework document public meeting for the
fluorescent lamp ballast standards rulemaking that DOE should consider
using the BE metric. (NEMA, Public Meeting Transcript, No. 9 at p. 32,
pp. 37-38) Following the public meeting, DOE participated in the NEMA
task force on ballast efficiency through June 2009. Through a series of
conference calls and meetings, DOE learned about the resistor-based BE
method and participated in its development for four-foot 32W MBP T8
normal ballast factor ballasts. Using the data gathered and methodology
used in the NEMA task force DOE then continued development of the
proposed test procedure for other lamp types. DOE defined additional
resistor values, conducted extensive testing for both BE and BEF in
many product classes, created transfer equations so that BEF values
could be reported, and specified instrumentation specifications in its
development of the proposed test procedure.
Ballast efficiency equals lamp arc power divided by ballast input
power. Ballast efficiency aims to capture the electrical efficiency of
a ballast by eliminating usage of lamps and photometric measurements.
Instead of using a lamp and measuring light output, the resistor-based
BE method uses resistors (a resistor load bank) to simulate the lamp
and makes an electrical measurement of power through the arc-resistor.
Because a resistor can be manufactured with much smaller performance
tolerances than a fluorescent lamp, the resistor introduces much less
variation into the operating characteristics of the ballast.
NEMA commented that a BE measurement does not require lamp
electrical and photometric measurements and, thus, is both easier to
execute and more accurate. NEMA also stated that BE measurements have
lower measurement variation (on the order of 1 to 2 percent) between
test facilities and do not require ANSI standards for lamps that the
ballast is designed to operate. NEMA believes that the ballast
efficiency metric could be used to compare all ballasts of a given type
(e.g., all instant-start ballasts, all programmed-start ballasts),
regardless of the lamp types that the ballasts support (including lamp
types yet to be developed). (NEMA, Public Meeting Transcript, No. 9 at
pp. 25-27, p. 36, pp. 76-77, pp. 100-101)
DOE agrees that ballast efficiency would likely show less variation
than BEF and would allow for more equitable comparison among ballasts
operating different numbers of lamps or lamp wattages. As discussed in
section III.C, much of the variation inherent in the existing test
procedure is due to variation among reference lamps. The resistor-based
BE method reduces much of the measurement variation due to reference
lamps by using a resistor load bank to simulate the load placed on a
ballast during the measurement of input and output power. Decreased
measurement variation allows for more precise standard setting and
certification, compliance, and enforcement testing. DOE acknowledges
that the BE metric would allow for comparability across large portions
of the ballast market and that such comparability provides benefit to
consumers. DOE proposes conversion to BEF values, however, to measure
energy efficiency in a repeatable manner that provides comparison for
products in the same product class and that is also consistent with the
statutory metric set forth at 42 U.S.C. 6295(g)(5) and (g)(8).
DOE notes that use of ANSI standards would be required for lamps in
today's proposed test method because of the need to define the ballast
factor of a ballast. Ballast factor is a necessary input to the
transfer equations between BE and BEF as discussed in section III.F.5.
Because DOE proposes to test a ballast using only one lamp type,
however, new lamps without ANSI standards will not affect the test
procedure. The test procedure indicates using currently-available and
ANSI-specified lamps for the measurement and calculation of ballast
factor.
While NEMA commented that BE is the best descriptor for instant-
start energy efficiency measurements, NEMA also stated that electrode
heating effects should be taken into account for rapid-start and
programmed-start systems (NEMA, Public Meeting Transcript, No. 9 at pp.
37-39). The use of electrode heating impacts the ratio of ballast input
power to power dissipated in the lamp arc. Unlike instant-start
ballasts, programmed-start and rapid-start ballasts use a portion of
the ballast input power to heat the electrodes. Ion bombardment at the
electrode (known as sputtering) during the voltage pulse deteriorates
the lamp electrode over time. Electrode heating reduces the magnitude
of the voltage pulse required to start a lamp, thereby increasing lamp
lifetime for applications that require frequent on and off switching.
Because the resistor-based BE test method measures only the power
across the lamp arc resistor, measured output power (lamp arc power)
for ballasts such as rapid-start and some
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programmed-start ballasts tends to be smaller than the true total
ballast output power. Instant-start ballasts are less affected by this
issue because these ballasts do not employ electrode heating. From a
lighting efficiency perspective, the BE metric captures the percentage
of input power utilized for lighting in the output stage. DOE believes
accounting for output power in this way is useful because it does
indicate that instant-start ballasts use a greater percentage of input
power in the direct production of light. The fluorescent lamp ballast
standards rulemaking will consider the impact of starting method on
consumer utility and will set energy conservation standards
accordingly.
DOE investigated the possibility of measuring the total output
power of a ballast for the BE metric to include electrode heating and
lamp arc power. To measure the total output power across the entire
resistor load bank, a user needs to measure the electrode and lamp arc
voltage separately. DOE found this measurement to introduce too much
error through capacitance to ground and loading effects on the ballast
during high-frequency operation. Accordingly, DOE has tentatively
concluded that reducing the number of measurements to ensure a more
accurate measurement is the more reasonable approach. Therefore, DOE
proposes measuring the voltage drop across the lamp arc resistor and
the input current to the resistor