Energy Conservation Program: Test Procedures for Fluorescent Lamp Ballasts, 71570-71596 [2010-28793]
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Federal Register / Vol. 75, No. 226 / Wednesday, November 24, 2010 / Proposed Rules
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appropriate number and frequency of
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Dated: November 18, 2010.
David R. Shipman,
Acting Administrator, Agricultural Marketing
Service.
[FR Doc. 2010–29551 Filed 11–23–10; 8:45 am]
BILLING CODE 3410–02–P
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: Supplemental notice of
proposed rulemaking.
AGENCY:
The U.S. Department of
Energy (DOE) proposes to revise 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
SUMMARY:
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goal of reducing measurement variation.
Furthermore, this proposed test
procedure would measure a new metric,
ballast luminous efficiency (BLE),
which more directly assesses the
electrical losses in a ballast compared to
the existing ballast efficacy factor (BEF)
metric. Rather than testing a ballast with
a resistive load as proposed in the
March 24, 2010 notice of proposed
rulemaking (NOPR), the BLE test
procedure would measure the
performance of a ballast while operating
a fluorescent lamp.
DATES: DOE will accept comments, data,
and information regarding this
supplemental notice of proposed
rulemaking (SNOPR) no later than
December 27, 2010. See section V,
‘‘Public Participation,’’ of this SNOPR
for details.
ADDRESSES: Any comments submitted
must identify the Fluorescent Lamp
Ballast Active Mode Test Procedure
SNOPR, 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-TP0016@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.
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Federal Register / Vol. 75, No. 226 / Wednesday, November 24, 2010 / Proposed Rules
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.
Elizabeth 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:
Elizabeth.Kohl@hq.doe.gov.
For additional information on how to
submit or review public comments,
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:
FOR FURTHER INFORMATION CONTACT:
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Table of Contents
I. Authority and Background
II. Summary of the Supplemental Notice of
Proposed Rulemaking
III. Discussion
A. Existing Test Procedure
B. Metric
C. Test Procedures Considered
1. Resistor-based Ballast Efficiency
Correlated to BEF
2. Lamp-based Ballast Efficiency Correlated
to BEF
3. Improved Light-Output-Based Test
Procedure
4. Relative System Efficacy
5. Dimming Ballast Test Procedure
D. Test Procedure Proposal
1. Test Conditions
2. Test Setup
3. Test Method
4. Calculations
5. Updates to Existing Test Procedure
6. Normative References for ANSI C82.2–
2002
E. Burden To Conduct the Proposed Test
Procedure
F. Impact on Measured Energy Efficiency
G. Scope of Applicability
H. 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
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V. Public Participation
A. Submission of Comments
B. Issues on Which DOE Seeks Comment
1. Impact of Ballast Output on Lamp
Efficacy
2. Ballast Factor Calculation
3. Impact of Reference Lamp Measured
Power Variation on Ballast Factor
4. NVLAP Accreditation
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) 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 EPCA, the overall program
consists essentially of the following
parts: Testing, labeling, certification and
enforcement, and Federal energy
conservation standards. The testing
requirements consist of test procedures
that manufacturers of covered products
must use as the basis for certifying to
DOE that their products comply with
energy conservation standards and for
representing 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.
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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.
The Energy Independence and
Security Act of 2007 also amended
EPCA to require DOE to review test
procedures for all covered products at
least once every seven years. DOE must
either amend the test procedures or
publish notice in the Federal Register of
any determination not to amend a test
procedure. (42 U.S.C. 6293(b)(1)(A)) To
fulfill this periodic review requirement,
DOE invites comment on all aspects of
the existing test procedures for
fluorescent lamp ballasts 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. 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 relevant to
this test procedure rulemaking. On
March 24, 2010, DOE published a notice
of public meeting and availability of the
preliminary technical support document
1 American
National Standards Institute.
National Standards for Fluorescent
Lamp Ballasts—Methods of Measurement.’’
Approved October 21, 1983.
2 ‘‘American
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(TSD) for the fluorescent lamp ballast
standards rulemaking. 75 FR 14319.
DOE also published a test procedure
notice of proposed rulemaking NOPR on
March 24, 2010. 75 FR 14288. On April
26, 2010, DOE held a joint public
meeting to discuss the test procedure
proposals in the NOPR and the
preliminary TSD for the fluorescent
lamp ballast standards rulemaking
(hereafter ‘‘NOPR public meeting’’). All
comments on the fluorescent lamp
ballast test procedure rulemaking are
discussed in section III of this proposed
rulemaking.
As mentioned in the NOPR, 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. (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. This
supplemental notice of proposed
rulemaking does not propose any
changes to the measurement of standby
and off mode energy consumption for
fluorescent lamp ballasts.
II. Summary of the Supplemental
Notice of Proposed Rulemaking
In this supplemental notice of
proposed rulemaking (SNOPR), DOE
proposes to modify the current
procedures for fluorescent lamp ballasts
to reduce measurement variation and
reduce testing burden. The proposed
method would eliminate photometric
measurements and propose the use of
electrical measurements of a lamp-andballast system. In addition, this test
procedure measures a new metric,
ballast luminous efficiency (BLE),
which more directly assesses the
electrical losses in a ballast compared to
the existing ballast efficacy factor (BEF)
metric. The SNOPR proposal also
describes a new method for calculating
the ballast factor (BF) of a system. DOE
also outlines the scope of applicability
of the test procedure and proposes a
minor update of the existing test
procedure in appendix Q. The following
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paragraphs summarize these proposed
changes.
In the NOPR, DOE proposed a
resistor-based ballast efficiency
measurement that would then be
correlated to BEF. In response to
comments received citing the
limitations of a resistor-based
measurement, DOE proposes in this
SNOPR to measure ballast input power
and lamp arc power using only
electrical measurements of a lamp-andballast system. Variation in the
measured power of a reference lamp is
minimized by the calculation of ballast
luminous efficiency, where BLE is equal
to total lamp arc power divided by
ballast input power. To account for the
increase in lamp efficacy associated
with high-frequency lamp operation
versus low-frequency, DOE is also
proposing an adjustment to the BLE of
low-frequency systems. DOE is
proposing that low-frequency BLE be
multiplied by 0.9 to account for the
approximately 10% increase in lighting
efficacy associated with high-frequency
lamp operation. DOE also proposes a
method for calculating the ballast factor
(BF) of a ballast by dividing the
measured lamp arc power on the test
ballast by the measured lamp arc power
on a reference ballast. Ballast factor is
under consideration in the fluorescent
lamp ballast standards rulemaking as
criteria for defining product classes. In
cases where reference ballast operating
conditions are unavailable, the SNOPR
provides a reference lamp power
(specific to the ballast type) from an
ANSI standard or from empirical
results. Particular lamp and ballast
pairings are specified for both the BLE
and BF measurements.
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
provisions for the testing of ballasts
identified in the preliminary
determination of scope. If the scope of
coverage changes in later stages of the
fluorescent lamp ballast standards
rulemaking, DOE will add or remove
provisions from the test procedure so
that it is consistent with the final scope
of coverage of standards. See section
III.G for further detail.
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
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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 will describe
the efficiency of a ballast in terms of a
new metric, BLE. 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
BLE generated by the active mode test
procedure proposed in this rulemaking.
As a result, DOE proposes that use of
any revised test procedure, to be
published as Appendix Q1 of 10 CFR
part 430 Subpart B, would be required
concurrent with the compliance date of
any amended fluorescent lamp ballast
standards. DOE is required by a consent
decree to issue any amended fluorescent
lamp ballast standards by June 30, 2011.
As described in the NOPR, 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 use of any amended
test procedure to be published at
Appendix Q1 is required, manufacturers
should continue testing these ballasts
using the existing test procedure to
determine compliance with existing
standards. In the NOPR, DOE proposed
to make minor updates to the existing
test procedure, published at Appendix
Q to Subpart B of part 430. The SNOPR
does not affect this proposal. DOE
would update the reference to ANSI
C82.2–1984 in the existing test
procedure (appendix Q) to ANSI C82.2–
2002.3 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 use of the
amendments to Appendix Q be required
upon the effective date of any test
procedure final rule, 30 days after
publication. In addition, the test
procedures for any ballasts that operate
in standby mode are also located in
Appendix Q.
III. Discussion
A. Existing Test Procedure
The existing ballast test procedure (in
Appendix Q to subpart B of 10 CFR part
3 ‘‘American National Standards for Lamp
Ballasts—Method of Measurement of Fluorescent
Lamp Ballasts,’’ approved June 6, 2002.
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Federal Register / Vol. 75, No. 226 / Wednesday, November 24, 2010 / Proposed Rules
430) determines the energy efficiency of
a fluorescent lamp ballast based on light
output measurements and ballast input
power. The metric used is called ballast
efficacy factor. 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 4 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
system by the photocell output of the
reference ballast system yields relative
light output or ballast factor. 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 and multiplying by 100. A ballast
that produces more light than another
ballast with the same input power will
have a larger BEF.
The National Electrical Manufacturers
Association (NEMA) commented that
BEF measurements would vary by plus
or minus five percent and that this
variation is unacceptable when trying to
differentiate between products that vary
in efficiency by three to five percent.
(NEMA, No. 15 at p. 13) For BEF, the
variation in measured power of the
reference lamps (rated power ± 2.5%)
plus the variation in the photometric
measurement system itself leads to the
plus or minus 5% variation. Given the
variation observed in BEF measurement,
NEMA also does not believe a
thousandths place digit in a BEF
measurement discussed in the proposed
rule has any statistical validity. In
contrast, NEMA noted that for the
ballast efficiency (BE) measurement
proposed in the NOPR, the power
analyzer equipment introduces plus or
minus 1.5% variation into the
measurement and the current transducer
and wiring capacitances contribute 1%
for a total of plus or minus 2.5%
variation (NEMA, Public Meeting
Transcript, No. 12 at p. 15–16, 22–25).
4 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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DOE agrees that photometric based BEF
measurements are more variable than
electrical measurement based BE
measurements. In this test procedure
SNOPR, DOE is proposing a
methodology that uses electrical
measurements of a lamp and ballast
system to measure BLE. The BLE metric
includes a modification to the BE metric
discussed in the NOPR to account for
changes in lamp efficacy as a result of
differences in lamp operating frequency.
B. Metric
In the NOPR, DOE proposed a
resistor-based ballast efficiency
measurement that would then be
correlated to BEF, for consistency with
the standards set forth at 42 U.S.C.
6295(g)(5) and (8). At the NOPR public
meeting, the Appliance Standards
Awareness Project (ASAP) and
Earthjustice commented that they did
not believe DOE was required to
regulate ballasts using the BEF metric.
(ASAP, Public Meeting Transcript, No.
12 at p. 98–99 5; Earthjustice, Public
Meeting Transcript, No. 12 at p. 100)
In response to these comments, DOE
is proposing a new metric to describe
the efficiency of a ballast called ballast
luminous efficiency (BLE). EPCA does
not require DOE to set standards for
fluorescent lamp ballasts using the BEF
metric and grants DOE the authority to
use test procedures for measuring
energy efficiency that it determines are
appropriate. (42 U.S.C. 6291, 6295(g),
and 6293(b)(5)) The BLE metric and test
procedure are based on the NEMA
lamp-based ballast efficiency (BE) test
procedure considered in the test
procedure NOPR. Similar to the
procedure considered in the NOPR, the
BLE test procedure measures ballast
input power and lamp arc power of a
lamp-and-ballast system. The only
difference between the BE procedure
considered in the NOPR and the
proposed BLE test procedure is the
proposed adjustment to the BLE of lowfrequency systems to account for the
increase in lamp efficacy associated
with high-frequency lamp operation
versus low-frequency. Specifically, DOE
is proposing that low-frequency BLE be
multiplied by 0.9 to account for the
approximately 10% increase in lighting
efficacy associated with high-frequency
lamp operation. DOE also proposes a
5 A notation in the form ‘‘ASAP, Public Meeting
Transcript, No. 12 at p. 98–99’’ 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 April 26, 2010; (2) in document number 12 in
the docket of this rulemaking; and (3) appearing on
pages 98 through 99 of the transcript.
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method for calculating the ballast factor
(BF) of a system by dividing the
measured lamp arc power on the test
ballast by the measured lamp arc power
on a reference ballast. In cases where
reference ballast operating conditions
are unavailable, the SNOPR provides a
reference lamp power (specific to the
ballast type and operating frequency)
from an ANSI standard or from
empirical results. The ballast factor
measurement is described in more detail
in section III.D.4. Particular lamp and
ballast pairings are specified for both
the BLE and BF measurements.
DOE is proposing the BLE test
procedure because it reduces
measurement variation and testing
burden compared to the existing test
procedure. In contrast to BEF and RSE,
the BLE metric can be used to compare
the efficiency across many different
types of ballasts. DOE also believes the
use of a lamp-and-ballast system allows
the ballast to operate at its natural
operating point and will more
accurately assess ballast performance
than when the ballast test load is a
resistor. Furthermore, a resistive load
can only model the effective resistance
of a lamp operated at a particular ballast
factor, requiring multiple ballast factor
specific resistors to be specified and
increasing the testing cost to
manufacturers. DOE also believes that
the use of electrical measurements and
the calculation of BLE reduce the
impact of lamp manufacturing variation
on the efficiency descriptor compared to
the existing test procedure.
C. Test Procedures Considered
In the NOPR, DOE proposed a
resistor-based ballast efficiency
measurement correlated to BEF. DOE
also provided descriptions of alternative
test procedures it considered in the
course of developing its proposal.
Interested parties commented on the
proposed methodology and the three
alternative methods considered. The
following sections discuss DOE’s
responses to interested party comments.
1. Resistor-Based Ballast Efficiency
Correlated to BEF
In the NOPR, DOE proposed a test
procedure to measure a resistor-based
BE, which would then be correlated to
BEF. This procedure used precision
resistive loads to simulate the effective
resistance of a fluorescent lamp as the
ballast load. In response, DOE received
many comments suggesting performance
measurements of a lamp-and-ballast
system will provide more realistic data
than a resistor and ballast system while
still reducing measurement variation
compared to the existing method. These
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comments are discussed in additional
detail in section III.C.2. Discussed in the
following paragraphs are comments
DOE received on the proposed transfer
equations, the ballasts selected for
testing, and ballasts that do not operate
resistors.
NEMA commented that it supports
the BE method but prefers the ballast to
be paired with reference lamps rather
than precision resistors. NEMA and
Osram Sylvania (OSI) commented that
the ballast needs to be paired with a
resistor matched to the ballast factor of
the ballast for it to operate at its design
point. A test procedure that requires
multiple ballast factor specific resistors
would be very expensive considering
each resistive load bank costs 1000 to
2000 dollars and is only available on a
custom order basis. (NEMA, No. 15 at p.
5, 11; NEMA, Public Meeting
Transcript, No. 12 at p. 21–22, 38–39,
105; OSI, Public Meeting Transcript, No.
12 at p. 80)
DOE agrees that specifying multiple
ballast-factor specific resistors would be
burdensome and that the actual
performance of a ballast is better
measured while it is operating the
natural lamp load. In this SNOPR, DOE
proposes a procedure which is
applicable to all ballasts and uses lamp
loads in the measurement of ballast
luminous efficiency.
DOE also received several comments
in response to its proposed transfer
equations between BE and BEF. The
Northwest Energy Efficiency Alliance
and the Northwest Power Conservation
Council (NEEA and NPCC) commented
that the transfer equations between BE
and BEF may be error prone and may
not attribute the correct BEF to a ballast.
(NEEA & NPCC, Public Meeting
Transcript, No. 12 at p. 86–87, 89, 167–
168; NEEA & NPCC, No. 16 at p. 4–5)
NEMA commented that a lighting
designer might prefer BE to be
correlated to BEF in order to compare
lighting efficacy. NEMA also added that
it does not believe small errors in the
transfer equation to be an issue, because
lighting designers do not require as high
a level of accuracy when specifying a
system. (NEMA, No. 15 at p. 9) Philips
commented that the approach with the
transfer equations is essentially to
average the BEF values at a particular
BE value and to plot a line through
these points. Philips noted that the
average BEF helps to account for the
wide variation in BEF values. (Philips,
Public Meeting Transcript, No. 12 at p.
87–91) Philips also indicated general
agreement with the transfer equations
for the ballasts that operate four foot
medium bipin lamps. (Philips, Public
Meeting Transcript, No. 12 at p. 94–95)
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OSI commented that the test data used
to develop the transfer equations could
bias the results if the BEF or BE values
happened to test on the high or low end
of the expected distribution of data.
(OSI, Public Meeting Transcript, No. 12
at p. 166–167) NEMA commented that
a percentage shift in the transfer
equation between BE and BEF based on
ballast factor would not necessarily be
the same for all ballast types. In
addition, NEMA commented that
instant start ballasts should generally be
more efficient than programmed start
ballasts and the transfer equations
should be consistent with this
difference. (NEMA, Public Meeting
Transcript, No. 12 at p. 21, 25–26) DOE
appreciates the comments on the
transfer equations. Because DOE is
proposing a test procedure for BLE
without correlation to another metric,
however, DOE does not need to develop
transfer equations or scaling
relationships between equations.
In response to the test data presented
in the fluorescent lamp ballast standards
rulemaking, NEEA and NPCC
commented that they understood DOE
tested only normal BF ballasts and used
scaling relationships to derive the BE
and BEF for the high and low BF
ballasts. (NEEA & NPCC, No. 32 at p. 4)
DOE did test ballasts of all ballast
factors, including low and high BF
models. However, DOE tested low and
high BF models using a resistor load
that corresponded to a lamp driven by
a normal BF ballast in an effort to
reduce the inventory of resistors
required for testing and reduce
measurement burden. Because the
ballast operates differently when
attached to a resistor that does not
properly match the ballasts’ impedance,
DOE developed separate transfer
equations to correlate BE to BEF for
different bins of BF (high, normal, and
low 6). In this SNOPR, however, DOE is
proposing a test procedure based on a
lamp-and-ballast system that does not
employ resistive loads.
In its testing for development of the
resistor-based BE test method for the
NOPR, DOE observed that some ballasts
did not operate resistors. NEMA
commented that its round robin testing
for its own investigation of the resistorbased BE test procedure showed that
some ballasts do not start or operate
correctly with resistor loads. NEMA
commented that in some cases, the
ballast senses the resistor is a non-lamp
load and will shut down or fail to start
entirely. Some labs overcome this issue
6 High ballast factor: BF ≥ 1.10; Normal ballast
factor: 0.78 > BF > 1.10; Low ballast factor: BF ≤
0.78.
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by starting the ballast without this
resistive load connected and then
introducing the resistor after a short
time (as short as 500 milliseconds). This
setup can require program controllers
which add parasitic capacitance and
inductance. (NEMA, No. 15 at p. 5, 8)
NEMA and General Electric (GE) also
commented that the issue of some
ballasts not operating resistors can be
resolved by changing the procedure to
involve lamp loads rather than resistors.
NEMA noted that ballasts are designed
to operate lamps, not resistors, and that
using a lamp load will ensure a ballast
starts and operates properly. (NEMA,
Public Meeting Transcript, No. 12 at p.
39, 96–97; GE, Public Meeting
Transcript, No. 12 at p. 97–98; NEMA,
No. 15 at p. 6) Finally, the CA Utilities
commented that they did not support
the use of different test procedures for
ballasts that do and do not operate
resistors. (CA Utilities, No. 13 at p. 2–
3) DOE agrees that a change of test
procedure to involve lamp loads rather
than resistive loads will resolve the
issue of some ballasts not operating
resistors properly and will provide a
procedure applicable to all ballasts.
2. Lamp-Based Ballast Efficiency
Correlated to BEF
In the NOPR, DOE considered a lampbased BE measurement that would then
be correlated to BEF using transfer
equations. DOE defined this lamp-based
BE as lamp arc power divided by ballast
input power such that cathode heating
power was included in the input but not
in the output. This procedure is based
largely on the BE test procedure
described in the NEMA Alternative Test
Procedure Handout, available at https://
www1.eere.energy.gov/buildings/
appliance_standards/residential/pdfs/
fl_ballast_tp_nema.pdf. In this SNOPR,
DOE is proposing a variation of lampbased BE called ballast luminous
efficiency (BLE). BLE is equal to lamp
arc power divided by input power and
then multiplied by an adjustment factor
based on high- or low-frequency lamp
operation. This adjustment factor
accounts for the decreased lighting
efficacy of low-frequency lamp
operation. DOE references the BLE
procedure in the responses to comments
that follow on the lamp-based BE
procedure, and provides more detail on
the BLE procedure in section III.D. As
discussed in the following paragraphs,
DOE received comments suggesting a
ballast should be tested with a lamp
load (not a resistor), as well as
comments on the potential drawbacks
and benefits of the BE metric compared
to BEF, a new method for the
measurement of ballast factor, and the
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validity of the lamp-based BE procedure
for ballasts other than instant- and
programmed-start ballasts with full
cathode cutout.
DOE received several comments
suggesting that BE is better measured
with a lamp-and-ballast system rather
than a resistor and ballast system.
NEMA commented in the NOPR public
meeting that it supports the adoption of
the lamp-based BE test procedure.
NEMA commented that the lamp-based
BE procedure is simple, repeatable
(testing variation of ±2.5 percent), and
can be used to generate a stand-alone BE
value or combined with a transfer
equation to calculate BEF. NEMA also
indicated that the procedure provides a
clear description of ballast performance
while minimizing the effects of
reference lamps on the ballast and lamp
system. (NEMA, No. 15 at p. 2, 7, 14;
NEMA, Public Meeting Transcript, No.
12 at p. 20–21, 165–166; NEMA, Public
Meeting Transcript, No. 12 at p. 38)
NEMA commented that the ballast
should operate a reference lamp when
lamp arc power and ballast input power
are measured. (NEMA, No. 15 at p. 14)
Finally, OSI commented that ballast
design laboratories are familiar with
electrical efficiency testing, and
typically make these measurements
rather than photometric measurements
when designing ballasts. (OSI, Public
Meeting Transcript, No. 12 at p. 60).
NEEA and NPCC commented that
they prefer the usage of fluorescent
lamps as the load for a ballast when
testing for ballast efficiency compared to
the usage of resistive loads. (NEEA &
NPCC, No. 16 at p. 5; NEEA & NPCC,
No. 32 at p. 4 7) NEMA and GE also
recommended that lamps be utilized as
the load for testing the BE of a ballast.
They also noted that lamps respond to
the current supplied by a ballast, are
readily available and inexpensive to
procure, and provide a natural operating
load for the ballast. (NEMA, Public
Meeting Transcript, No. 12 at p. 22, GE,
Public Meeting Transcript, No. 12 at p.
103; NEMA, No. 15 at p. 6–7) Philips
agreed that the ballast should operate a
lamp for the measurement of BE.
(Philips, Public Meeting Transcript, No.
12 at p. 39) NEMA also commented that
by correctly matching the lamp
impedance to the ballast, the maximum
power transfer from the ballast to the
lamp occurs and the ballast operates at
its design point and design efficiency.
(NEMA, No. 15 at p. 6) Reference lamps
are standardized and well characterized
7 This written comment was submitted to the
docket of the fluorescent lamp ballast standards
rulemaking [Docket No. EERE–2007–BT–STD–0016;
RIN 1904–AB50].
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and can be procured from any lamp
manufacturer. (NEMA, No. 15 at p. 6)
Philips and GE commented that the
lamp load should be a reference lamp to
keep the ballast near its designed
operating point. The reference lamp
provides a common electrical operating
point. (Philips, Public Meeting
Transcript, No. 12 at p. 64; GE, Public
Meeting Transcript, No. 12 at p. 63, 80)
The CA Utilities agreed, commenting
that if DOE adopts a BE based test
procedure, it should use reference
lamps as the ballast load. (CA Utilities,
No. 13 at p. 2)
DOE agrees that electrical
measurements of ballast performance
are more realistic while the ballast is
operating a lamp load compared to a
purely resistive load. Though a resistive
load provides a constant and repeatable
operating point, a precision resistor is
more expensive than a lamp, does not
change impedance in response to
ballasts of different ballast factor, and
does not always provide the proper
operating point for the ballast. DOE also
understands that electrical
measurements are commonly used in
ballast design labs to ascertain
performance. In this SNOPR, DOE is
proposing ballast performance
measurements based on a reference
lamp-and-ballast system as the new test
procedure for fluorescent lamp ballasts
based on the NEMA Test Procedure
Handout and comments from Philips
and GE.
Philips and GE also commented that
BE would be a more appropriate metric
than BEF, because BE is a metric that
allows for the comparison of all ballast
systems, including different numbers of
lamps or lamp type, using a common
basis for the metric. (Philips, Public
Meeting Transcript, No. 12 at p. 71; GE,
Public Meeting Transcript, No. 12 at p.
74) GE also commented that BE is a
useful metric for original equipment
manufacturers when deciding which
products to combine into their lighting
systems. (GE, Public Meeting Transcript,
No. 12 at p. 74–75) NEEA and NPCC
commented, however, that a lighting
designer may be more interested in
meeting a lumen per unit area
requirement than achieving a one or two
percent difference in ballast efficiency.
(NEEA & NPCC, Public Meeting
Transcript, No. 12 at p. 73) NEEA and
NPCC commented that ballasts are not
useful except as part of a lighting
system, suggesting that for a lighting
product, lighting output per unit power
input is the metric that matters. Because
ballasts of increased electrical efficiency
do not always produce the same amount
of light, NEEA and NPCC gave first
preference to an improved light-output-
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71575
based test procedure, followed by a
lamp-based BE metric without
correlation to BEF, and finally the
resistor-based BE test procedure with
multiple ballast-factor specific resistors
specified for each lamp. NEEA and
NPCC also commented that lamp
operating frequency has a large impact
on light output. (NEEA & NPCC, No. 16
at p. 2, 5) In its written comments,
NEMA stated that BEF could be
calculated from BE using the reference
arc power listed in ANSI C78.81–2010.
NEMA also noted that its method of
correlating BE to BEF would allow
manufacturers to express the
performance of the ballast in terms of
BEF to engineers and lighting
consultants while still using an
electrical measurement for indicating
compliance with energy conservation
standards. (NEMA, No. 15 at p. 9)
The CA Utilities commented that the
existing test procedure is more
appropriate than the lamp-based BE
measurement because it measures the
two most important parameters to
ballast consumers: Input power and
light output. The CA Utilities
commented that ballasts with the same
BE may produce more or less light from
the same lamp depending on the
frequency at which they operate the
lamp. Furthermore, the CA Utilities
commented that for high-frequency
ballasts, variations in frequency, crest
factor, and wave shape can affect lamp
efficacy. However, if DOE proposes a BE
test procedure, the CA Utilities
commented that they encourage DOE to
keep the standards in terms of BE and
not correlate to BEF. (CA Utilities, No.
13 at p. 1–3)
DOE believes BLE is the best metric
for assessing the performance of a
ballast. BLE provides for wide
comparability among all types of
ballasts and can distinguish between the
efficacy of high- and low-frequency
lamp operation. For ballast customers
who prefer the BEF metric, DOE agrees
that manufacturers could provide a BEF
value calculated from the BLE
measurement using the technique
suggested by NEMA. As explained in
the paragraphs that follow, DOE
proposes a modification to the
measurement of BE (resulting in the BLE
metric) in this SNOPR to address the
concerns of the CA Utilities and NEEA
and NPCC on the impact of lamp
operating frequency on light output.
More detail on the BLE metric proposed
in this SNOPR is provided in section
III.D.
To account for the change in lighting
efficacy as a result of lamp operating
frequency, DOE has developed a
modification to the metric measured in
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constant.8 DOE believes it is reasonable
to assume a fixed adjustment factor for
all high-frequency ballasts, as most
high-frequency ballasts operate at
greater than 20 kHz. DOE believes the
impact of lamp current crest factor
(LCCF) and waveform to have a minimal
impact on efficacy compared to the
difference between low and high
frequency operation. Lamp current crest
factor is limited by ANSI standards and
does not affect lamp efficacy
significantly. DOE also believes the
difference in waveform has a minimal
impact on lamp efficacy because the
limitations on lamp current crest factor
and power factor constrain the variety of
waveforms present in the market. DOE
seeks comment and data on the impact
of LCCF and waveform on lamp efficacy
and on its decision to adjust BLE for
low-frequency ballasts by a factor of 0.9.
DOE received comment that the term
ballast efficiency already has an
accepted meaning in industry. NEMA
commented that ballast efficiency can
be defined as a purely electrical
measurement that documents the true
efficiency of a ballast by dividing total
ballast output power by ballast input
power. NEMA commented that ballast
efficiency by itself does not account for
the reduced system efficiency associated
with ballasts that employ cathode
heating and suggested measuring a
metric defined as lamp arc power
divided by ballast input power. (NEMA,
No. 15 at p. 15; Philips, Public Meeting
Transcript, No. 12 at p. 71–72) Philips
commented that while cathode heating
does increase lamp column efficacy, it
does not offset the added energy
required to heat the lamp electrodes.
(Philips, Public Meeting Transcript, No.
12 at p. 44–46) In the NOPR, DOE
defined ballast efficiency as lamp arc
power divided by ballast input power,
but in the SNOPR, DOE is proposing the
metric ballast luminous efficiency
(BLE), which is defined as lamp arc
power divided by ballast input power
multiplied by an adjustment factor for
low-frequency operation. The
alternative nomenclature BLE also
indicates that the metric is slightly
different than a true ballast efficiency
measurement. DOE believes the BLE
procedure accurately accounts for the
diminished system efficacy associated
with lamp cathode heating by only
including lamp arc power (not cathode
heating) in the ballast output
measurement.
GE and NEMA commented that the
impact of lamp to lamp variation is
minimized with the lamp-based BE test
procedure because variations in lamp
measured power will impact ballast
input power and ballast output power in
such a way that the ratio of ballast
efficiency is mostly unaffected. (GE,
Public Meeting Transcript, No. 12 at p.
62–63; NEMA, No. 15 at p. 6) DOE
agrees that the metric of lamp arc power
divided by ballast input power is mostly
unaffected by lamp to lamp variation.
Because variations in lamp power affect
both the numerator and denominator,
the calculation of BE (as defined in the
NOPR) or BLE (as defined in this
SNOPR) minimizes the impact. This is
in contrast to the existing light-output
based test procedure where variations in
lamp measured power have significant
impact on ballast input power but not
relative light output.
NEMA commented that the lampbased BE measurement would be
preferable to the resistor-based BE
measurement proposed in the NOPR
because it would allow for measurement
of ballast performance at steady state.
The resistor-based BE method involves
measurement of ballast performance
within one minute of energizing the
ballast, and the resistor then needs to
rest for one minute so that an increase
in temperature would not impact its
resistance. NEMA commented that
unlike resistors, lamps do not have a
duty cycle requirement necessitating
them to be run for long periods of time
without deviation from the desired
operating point. (NEMA, No. 15 at p. 6)
GE commented that the lamp-based BE
test procedure measures ballast
performance at steady-state, in contrast
to the resistor-based test procedure
proposed in the NOPR. NEMA and GE
8 Rea, Mark S., ed. The IESNA Lighting
Handbook: Reference & Application, 9th Edition.
2000. The Illuminating Engineering Society of
America: New York, New York.
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the NEMA Alternative Test Procedure
Handout that DOE calls BLE. Under this
metric, the lamp arc power for ballasts
that operate lamps at low frequency will
be multiplied by 0.9. This adjustment
factor compensates for the reduced lamp
efficacy that results from low-frequency
operation. Figure III.1 shows lamp
efficacy increases with increased
operating frequency up to about 20 kHz,
after which, lamp efficacy is close to
Federal Register / Vol. 75, No. 226 / Wednesday, November 24, 2010 / Proposed Rules
commented that certain ballast
components such as magnetics and
diodes operate at higher efficiency once
they have reached a steady state
temperature. Testing at steady state
therefore captures the in-practice
performance of a ballast. (GE, Public
Meeting Transcript, No. 12 at p. 82–83;
NEMA, No. 15 at p. 6) Philips agreed
that measurement of the ballast
performance is more realistic at steady
state than within one minute of
energizing. (Philips, Public Meeting
Transcript, No. 12 at p. 163)
DOE agrees that the lamp-based BE
test procedure is simpler and more
representative of ballast performance
than the resistor-based method. Because
a lamp does not have a short duty cycle,
the lamp-and-ballast system can be
operated for a long enough time to reach
steady state and the ballast
measurement can be representative of
typical operation. In this SNOPR, DOE
is proposing a BLE test procedure in
which, like the BE method, the
performance of a ballast is measured at
steady state while operating a lamp
load.
The lamp-based BE test procedure
would define particular lamp and
ballasts pairings for testing ballast
performance. In its written comments,
NEMA recommended that instant-start
ballasts and programmed-rapid-start
ballasts with cathode cut-out should be
tested with a full wattage load. (NEMA,
No. 15 at p. 6–7) In this SNOPR, DOE
is proposing to pair ballasts with the
most common wattage lamp for testing
purposes (see section III.D.2 for
additional detail). In the case of instantstart ballasts and programmed-rapidstart ballasts (with or without full
cathode cut-out), DOE is proposing that
these ballasts operate full-wattage lamps
which are also the most common
wattage in these groupings. Some
ballasts, such as rapid start T12 ballasts,
are paired with reduced wattage or
energy saver lamps as this will be the
most common pairing. The proposal for
lamp-and-ballast pairing in this SNOPR
is the same as discussed in the test
procedure NOPR.
GE also commented on the transfer
equations for BE to BEF, stating that
fitting a line of best fit to tested BEF and
BE data would be a reasonable method
of developing a transfer equation
between the two metrics. (GE, Public
Meeting Transcript, No. 12 at p. 64–65)
GE commented that separate empirically
derived transfer equations would likely
be needed for ballasts that either employ
or do not employ cathode heating. (GE,
Public Meeting Transcript, No. 12 at p.
65–66) At the NOPR public meeting,
Philips commented that it developed
correlations between BE and BEF for
instant start ballasts and ballasts with
cathode cutout when using the lampbased BE test procedure. (Philips, Public
Meeting Transcript, No. 12 at p. 36)
NEMA commented that separate transfer
equations for ballasts of different ballast
factor would be unnecessary with a
lamp-based BE test procedure. (NEMA,
No. 15 at p. 6) The CA Utilities
commented that they did not agree with
using the same transfer equations for
converting BE to BEF for high and low
frequency ballasts because of the change
in lamp efficacy. A high- and lowfrequency ballast with the same BE
would not have the same BEF. (CA
Utilities, No. 13 at p. 2) In its written
comments, NEMA stated that BEF could
be calculated from BE using the
reference arc power listed in ANSI
C78.81–2010 9. NEMA suggested
multiplying BE by 100, dividing by
number of lamps, and dividing by the
ANSI reference lamp arc power. Philips
commented that this technique is based
on the assumption that light output is
directly proportional to arc power for all
ballast types over the ballast factor range
from 0.75 to 1.15. NEMA provided test
data that supports this claim. NEMA
also commented that the calculation
favors ballasts with less cathode
heating, which is consistent with the
goal of promoting energy efficient
systems. (NEMA, No. 29 at p. 3; NEMA,
No. 15 at p. 15–16; Philips, Public
Meeting Transcript, No. 12 at p. 51–53)
In the SNOPR, DOE is proposing to
measure BLE directly without
correlation to another metric. To convert
71577
the existing standards from BEF to BLE,
however, DOE used the NEMA
suggested calculation (rather than
empirical correlations) to convert the
existing BEF energy conservation
standards to BLE standards. DOE used
different conversion equations to assign
the associated BLE for high- or lowfrequency ballasts, in agreement with
the CA Utilities’ comment.
To convert from BEF to BLE, DOE
multiplied the BEF values by the
corresponding reference lamp arc power
listed in Table III.2 and the number of
lamps operated by the ballast. As
described in section III.D.4, these
reference arc powers originate from
ANSI C78.81–2010 or IEC 60081 Ed 5.0,
the results of empirical analysis
performed by DOE, or scaling from a
similar lamp type (as described in the
next paragraph). For example, for
ballasts that operate two F34T12 lamps,
DOE multiplied 1.35 (BEF) by two
(number of lamps) and 29.81 (highfrequency reference lamp arc power
based on empirical testing) which
resulted in a BLE of 80.5%. To convert
the same BEF to a low-frequency
equivalent BLE, DOE multiplied 1.35 by
two (number of lamps), 32 (lowfrequency reference lamp arc power),
and 0.9 (lamp operating frequency
adjustment factor) which resulted in a
BLE of 77.8%. Table III.1 lists the
existing standards and their
corresponding values in BLE using the
methodology described in this
paragraph.
DOE did not have high-frequency
ANSI reference specifications or
empirical data for F40T12 or F96T12
lamps. To estimate high-frequency lamp
arc powers for the F40T12 lamp, DOE
scaled the low-frequency ANSI-based
F40T12 reference power using the ratio
of high-frequency to low-frequency
reference powers for the F34T12 lamp.
For the F96T12 lamp, DOE used the
same methodology using the ratio of
high- to low-frequency reference power
for the F96T12/ES lamp to scale the
low-frequency ANSI-based F96T12
reference power to high-frequency.
TABLE III.1—EXISTING BEF STANDARDS AND CORRESPONDING BLE CONVERSION
Ballast
input
voltage
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Ballasts that operate:
One
Two
Two
Two
One
F40T12 lamp ..............................................................................................
F40T12 lamps ............................................................................................
F96T12 lamps ............................................................................................
F96T12HO lamps .......................................................................................
F34T12 lamp ..............................................................................................
9 American National Standard for Electric
Lamps—Double-Capped Fluorescent Lamps—
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120/277
120/277
120/277
120/277
120/277
Total
nominal
lamp watts
Ballast
efficacy
factor
40
80
150
220
34
2.29
1.17
0.63
0.39
2.61
Dimensional and Electrical Characteristics,
Approved January 14, 2010.
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BLE Lowfrequency
BLE Highfrequency
80.4
82.1
85.1
74.4
75.2
83.2
85.0
89.7
78.0
77.8
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TABLE III.1—EXISTING BEF STANDARDS AND CORRESPONDING BLE CONVERSION—Continued
Ballast
input
voltage
Ballasts that operate:
jdjones on DSK8KYBLC1PROD with PROPOSALS-1
Two F34T12 lamps ............................................................................................
Two F96T12/ES lamps ......................................................................................
Two F96T12/HO/ES lamps ................................................................................
While DOE is proposing the BLE
metric in this SNOPR, DOE also
proposes a method for calculating
ballast factor of a ballast by dividing the
measured lamp arc power on the test
ballast by the measured lamp arc power
on a reference ballast. In some cases,
when reference ballast operating
conditions are unavailable, the SNOPR
provides a reference lamp power from
an ANSI standard or from empirical
results. As described in the preliminary
analysis of the fluorescent lamp ballast
standards rulemaking, DOE is
considering categorizing ballasts into
different groups (product classes) based
on ballast factor. These product classes
could then be subject to different energy
conservation standards. DOE could use
the ballast factor measurement in this
test procedure to assign a ballast to a
particular product class. See section
III.D.4 for additional detail on the
ballast factor calculation.
In commenting on the lamp-based BE
procedure, which is similar to the
suggested lamp-based BE test procedure
outlined in the NEMA Alternative Test
Procedure Handout, Philips indicated
that the NEMA procedure was only
valid for instant-start ballasts and
programmed-start ballasts with full
cathode cutout. Philips stated that
NEMA had not completed enough due
diligence for ballasts with cathode
heating to make a proposal. Philips
indicated that the existing light output
based procedure could be used for
ballasts without cathode heating.
Philips also commented that DOE could
make the assumption in the test
procedure to include cathode heating as
ballast losses and account for this
difference in the energy conservation
standard. (Philips, Public Meeting
Transcript, No. 12 at p. 36, 38, 47, 65,
71–72) Then, in written comments,
NEMA provided supplemental
information suggesting a modification to
the test setup to support ballasts that
employ cathode heating. NEMA
indicated that two 1,000 ohm resistors
should be placed in parallel with both
sets of lamp pins, generating a midpoint
from which to measure the lamp
discharge voltage. NEMA also noted that
the resistors are of high enough
impedance not to affect the lamp
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Total
nominal
lamp watts
120/277
120/277
120/277
operating characteristics and low
enough impedance not to affect the
measurement system. (NEMA, No. 15 at
p. 7) In response to the original NEMA
proposal that was applicable only to
ballasts without cathode heating, NEEA
and NPCC commented that they do not
support a test procedure that is only
applicable to certain ballasts. (NEEA &
NPCC, No. 16 at p. 3–4) NEEA and
NPCC commented that the existing test
procedure for BEF applies equally well
to all ballast types, which is not the case
for the lamp-based BE alternative, the
NOPR resistor-based BE proposal, or the
procedure as outlined in the NEMA
Alternative Test Procedure Handout. GE
commented that the use of more than
one test procedure for ballasts subject to
the same energy conservation standard
was not desirable. (GE, Public Meeting
Transcript, No. 12 at p. 97–98)
DOE agrees that the test procedure for
fluorescent lamp ballasts should be
applicable to all ballasts subject to the
same standards. DOE believes that the
test setup with resistors in parallel with
the lamp pins would allow for
repeatable BE measurements, as well as
BLE measurements, for rapid- and
programmed-start ballast regardless of
the level of cathode heating. Rather than
require the ballast to be tested to
determine the level of cathode heating,
DOE would use the voltage divider for
all rapid- and programmed-start ballasts.
The voltage divider would provide a
position in the circuit to measure the
lamp arc voltage assuming the arc
begins near the center of the ballast.
This is in contrast to a setup without the
divider when lamp arc voltage would
vary depending on the position of the
hotspot on each electrode. As a result,
DOE believes that NEMA’s suggested
test setup augments the BE procedure,
and the proposed BLE procedure, such
that both procedures are applicable to
all ballasts.
3. Improved Light-Output-Based Test
Procedure
In the NOPR, DOE considered
improving the existing light-output
based test procedure to reduce
measurement variation. The
measurement variation in the existing
procedure can be attributed to operating
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Ballast
efficacy
factor
68
120
190
1.35
0.77
0.42
BLE Lowfrequency
BLE Highfrequency
77.8
83.9
68.0
80.5
88.4
71.3
conditions, variation in measured power
of reference lamps, inconsistent output
power measurements in determining
ballast factor, and ambient temperature.
DOE invited comment on the clarified
methodologies and tighter tolerances for
temperature and reference lamp
measured power.
The CA Utilities commented that they
supported the improvements to the
existing test procedure presented in the
NOPR to reduce measurement variation,
including tightening reference lamp
tolerance, requiring uniform operating
conditions, taking measurements at
constant voltage (consistent with the
general service fluorescent lamps test
procedure listed in 10 CFR part 430
appendix R to subpart B), using only
one approach for calculating BF, and
testing universal voltage commercial
ballasts at 277V and residential
universal voltage ballasts at 120V. (CA
Utilities, No. 13 at p. 2) NEEA and
NPCC also supported the improvements
to the existing test procedure with the
exception of the ambient temperature
specification, which they believed
would be extraordinarily costly. NEEA
and NPCC preferred the improved lightoutput-based method to all other test
procedure proposals. (NEEA & NPCC,
No. 16 at p. 1–3) NEEA and NPCC also
commented that DOE should test the
proposed changes with a large sample
size so that statistics such as standard
deviation can be computed. NEEA and
NPCC commented that this data is
needed to judge the existing test
procedure against the proposed
amendment and alternatives. (NEEA &
NPCC, No. 16 at p. 3) General Electric
(GE), Philips, and NEMA agreed that
controlling a photometric laboratory to
25 °C ± 0.5 °C is a significant
undertaking and would require
upgrades of the air conditioning and air
handling controls and could require
some specialized equipment. (GE,
Public Meeting Transcript, No. 12 at p.
59, 105; Philips, Public Meeting
Transcript, No. 12 at p. 60–61; NEMA,
No. 15 at p. 7) Philips and NEMA also
commented that decreasing the
tolerance on reference lamps would
significantly increase the burden in
identifying reference lamps compared to
the already difficult process of meeting
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the current specification. (Philips,
Public Meeting Transcript, No. 12 at p.
60–61; NEMA, No. 15 at p. 7–8) NEEA
and NPCC disagreed with NEMA on the
issue of reference lamp variation,
commenting that while the process of
identifying reference lamps is tedious,
they did not see any reason why this
technique introduced unmanageable
variation into the test process. (NEEA &
NPCC, No. 16 at p. 2) GE commented
that the BEF metric is based heavily on
the input power to the ballast. However,
a vast majority of the input power is
dependent on the lamp, and the ballast
manufacturer has no control over this
lamp power. As a result, input power
and BEF will vary in response to the
measured power of the lamp, potentially
making high performance ballasts look
less efficient. Furthermore, the BEF test
procedure, as defined, contains some
latitude that permits variation between
test laboratories. (GE, Public Meeting
Transcript, No. 12 at p. 35–36)
DOE agrees that a tighter tolerance on
ambient temperature would be more
burdensome to manufacturers, though it
would decrease measurement variation.
DOE also believes that tightening the
tolerance on reference lamp measured
power would increase the burden for
lamp identification because fewer lamps
would meet the more stringent
specification. While DOE agrees with
NEEA and NPCC that the process of
identifying reference lamps can be
accurately carried out at any test
laboratory, because a reference lamp can
vary in measured power up to plus or
minus 2.5% of the rated lamp power
(existing requirements) or up to 1% in
the improved light output based test
procedure, the permitted variation in
measured power introduces variation
into the BEF metric. The same ballast
paired with reference lamps of different
measured power will measure different
ballast input power, impacting the value
of BEF. All other procedural
improvements and clarifications
including requiring uniform operating
conditions, taking measurements at
constant voltage, using only one
approach for calculating BF, and testing
universal voltage commercial ballasts at
277V and residential universal voltage
ballasts and cold-temperature sign
ballasts at 120V would reduce testing
variation without appreciably increasing
testing burden. DOE does not plan to
investigate the improved light output
based test procedure through testing
because it believes BLE to be a better
metric and test procedure. DOE believes
its proposal of BLE is less burdensome
than an improved light-output based
method, potentially reduces
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measurement variation to a greater
extent, and generates a straightforward
descriptor of electrical losses. The BLE
measurement and calculation also
minimize the impact of lamp measured
power variation. Therefore, DOE
believes there is minimal benefit to
requiring a tighter tolerance on
reference lamp power variation in the
context of the proposed test procedure.
Because discrepancies may exist in
BEF test data from different sources,
NEEA and NPCC suggested that any
changes to the existing test procedure
should place ballasts both above and
below the mean values, not
systematically generate tested
performance above the mean. (NEEA &
NPCC, No. 16 at p. 6) GE commented
that the discrepancies in data could
signify a compliance problem and that
manufacturers should notify DOE of
observed instances of non-compliance.
GE also indicated that manufacturers
may shop around at different
laboratories to find an improvement in
ratings. (GE, Public Meeting Transcript,
No. 12 at p. 35, 172–173) Philips
commented that variation in test data
between different sources should be
expected given the variation in the
underlying measurement technique.
(Philips, Public Meeting Transcript, No.
12 at p. 162–164, 173–174)
DOE understands that the existing test
procedure has some latitude in its
definition in that several slightly
different setups (lamp operating
conditions, reference lamps) and
conditions are permitted. Even the
improved light-output-based procedure
with its procedural clarifications still
allows a ballast to be tested with
reference lamps of slightly different
measured power. These light-outputbased procedures and the BEF metric
could allow for a systematic bias as GE
indicated at the NOPR public meeting.
DOE believes that the proposal in
today’s SNOPR of BLE limits the impact
of reference lamp measured power on
the efficiency descriptor for fluorescent
lamp ballasts and provides a clearly
defined procedure that limits
procedural variations from test facility
to test facility. The BLE metric is more
robust to changes in reference lamp
measured power because variations in
lamp power generally have a
proportional effect on both the input
power and lamp arc power
measurements (numerator and
denominator, respectively).
Philips commented that BEF can only
be used to compare ballasts of similar
light output. For example, T5 standard
output and T8 ballasts cannot be
compared using BEF because of their
different system lumen outputs.
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(Philips, Public Meeting Transcript, No.
12 at p. 50, 70–71) DOE agrees that BEF
cannot be used to compare ballasts that
are part of systems with different light
output. The measurement of ballast
luminous efficiency proposed in this
SNOPR can be used to compare ballasts
that are part of systems with different
light output.
4. Relative System Efficacy
In the NOPR, DOE considered a test
procedure to measure the relative
system efficacy of fluorescent lamp
ballasts. RSE is intended to normalize
the existing metric of BEF to rated lamp
efficacy to make it more comparable
across different lamp-and-ballast
systems. DOE received comment from
some interested parties regarding
potential problems and benefits
resulting from the use of RSE.
The CA Utilities supported the
normalization of BEF to RSE to allow
better comparison between ballasts that
operate different numbers of lamps. The
CA Utilities recommended measuring
BE, converting to BEF, and finally
converting to RSE or measuring BEF
directly using light output based
measurements. The CA Utilities also
commented that RSE is more useful
than BEF for designing and
implementing rebate programs. (CA
Utilities, No. 13 at p. 3; CA Utilities,
Public Meeting Transcript, No. 12 at p.
41, 53–54, 67–68) Lutron and NEMA
commented that if RSE is based on
photometric measurements, then RSE
will suffer from the same variation as
the existing test procedure. (Lutron,
Public Meeting Transcript, No. 12 at p.
51, 54; NEMA, No. 15 at p. 14) Philips
commented that though RSE may allow
for greater comparability of losses
among the product classes considered in
the preliminary analysis, these different
categories of ballasts may need to be
subject to different standards. As the
ballast operates increased wattage loads,
efficiency generally increases. As a
result, RSE would not automatically
reduce the number of product classes.
(Philips, Public Meeting Transcript, No.
34 at p. 54–55) NEEA and NPCC
disagreed with the use of RSE,
commenting that the utility of RSE may
be minimal to the lighting designer. The
lighting designer is interested in room
cavity ratio, fixture efficiency, fixture
spacing, and other factors for meeting a
lumen per unit area requirement and
not for a one or two percent efficiency
difference in the ballast. (NEEA &
NPCC, Public Meeting Transcript, No.
12 at p. 72–73) Philips and NEMA
commented that a lighting designer
might prefer BEF to RSE because BEF
can be used directly to convert to
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system lumen output while RSE must
first be converted to BEF. (Philips,
Public Meeting Transcript, No. 12 at p.
73; NEMA, No. 15 at p. 13) The CA
Utilities commented that a more
understandable efficiency metric will
help lighting designers with less
expertise make better decisions when
specifying the ballasts for their lighting
systems. (CA Utilities, Public Meeting
Transcript, No. 12 at p. 76)
Philips and NEMA commented that
while RSE does give a set of numbers
that are easier to understand and can be
compared for ballasts operating the
same lamp type, test data cannot be
compared for different lamp types.
(Philips, Public Meeting Transcript, No.
12 at p. 54; NEMA, No. 15 at p. 8, 14)
NEMA also commented that another
problem with RSE is that the four foot
MBP lamp is referenced at 60 Hz.
Therefore, the rated wattage of 32.5
watts (W) only corresponds to a lowfrequency ballast operating at ballast
factor of one. A high-frequency ballast
operating at ballast factor of one will
require less than 32.5 W. Because RSE
is defined as BEF divided by one
hundred and multiplied by the total
rated lamp power of the system, RSE
normalizes low- and high-frequency
four foot MBP T8 systems with the same
factor. (NEMA, Public Meeting
Transcript, No. 12 at p. 55) Philips
commented that because of the
difference in the rated lamp power used
to normalize the values, comparison of
four foot T8 high-frequency ballasts to
four foot T5 high-frequency ballasts is
inappropriate. (Philips, Public Meeting
Transcript, No. 12 at p. 68–69, 101)
Though RSE could be modified such
that BEF is normalized with a rated
power at the appropriate frequency,
DOE believes that BLE has many
advantages to RSE. The BLE metric is
measured directly with electrical
measurements and can be used to
compare the efficiency of ballasts that
operate different numbers of lamps and
different types of lamps. The
straightforward definition of BLE and its
wide range of comparability should help
inexperienced lighting designers select
more efficient ballasts for their lighting
systems to the same or greater extent
than the use of RSE.
5. Dimming Ballast Test Procedure
In the NOPR, DOE requested
comment on potential test procedures
for dimming ballasts in the event they
were added to the scope of coverage in
the fluorescent lamp ballast standards
rulemaking. Philips commented that
testing a dimming ballast at full light
output may be misleading because a
dimming ballast may have a different
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efficiency at reduced light levels than at
full light output. Furthermore, a
practicable method of characterizing the
overall efficiency of a dimming ballast
had not yet been identified. (Philips,
Public Meeting Transcript, No. 12 at p.
122–124) NEMA also commented in
response to the energy conservation
standard that it has not conducted
sufficient analysis to determine the
appropriate light level at which to test
dimming ballasts and that testing at
multiple light levels would be
burdensome. (NEMA, No. 29 at p. 2 10)
In written comments in response to the
test procedure NOPR, NEMA indicated
that testing a dimming ballast at full
light output was acceptable so long as
energy conservation standards were
adjusted appropriately—similar to
standards for programmed start versus
instant start ballasts. (NEMA, No. 15 at
p. 4–5) Because DOE is not currently
considering dimming ballasts in the
scope of coverage in the energy
conservation standard, DOE is also not
developing a test procedure for these
ballasts. If the scope of coverage later
includes dimming ballasts, DOE would
consider NEMA’s comment in
development of a dimming ballast test
procedure.
D. Test Procedure Proposal
DOE is proposing a test procedure for
the measurement of ballast luminous
efficiency (BLE) using electrical
measurements of a lamp-and-ballast
system. This proposal is based on a test
procedure developed by NEMA and
considered in the NOPR to measure
lamp-based BE and correlate the result
to BEF. The proposal includes a
calculation of ballast factor without
photometric measurements and a
repeatable method of measuring lamp
arc power for systems with cathode
heating. The proposed method also
includes a modification to the
calculation of the BE efficiency metric
to incorporate an element of system
efficacy.
In sections 1 through 4 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 would
contain the new test procedure for the
measurement of BLE that would be used
for demonstrating compliance with any
future amended standards. DOE
proposes that use of the test procedure
would be required upon the effective
date of any amended energy
10 This written comment was submitted to the
docket of the fluorescent lamp ballast standards
rulemaking [Docket No. EERE–2007–BT–STD–0016;
RIN 1904–AB50).
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conservation standards for fluorescent
lamp ballasts. In section 5, DOE
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 would
retain the existing BEF test procedure
for compliance with existing standards.
In section 6, DOE discusses proposed
amendments regarding references to
ANSI C82.2–2002.
1. Test Conditions
The test conditions required in the
SNOPR are unchanged from the NOPR
proposal. DOE proposes that testing be
conducted at 25 degrees Celsius ± 2.0
degrees and in a draft-free environment
according to ANSI C78.375–1997 11.
These conditions provide for mostly
uniform electrical operating
characteristics for the lamp-and-ballast
system. 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 particular revisions
to the normative references associated
with ANSI C82.2–2002 (see section
III.D.6 for additional detail). 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
and commercial cold-temperature
outdoor sign ballasts. Therefore, DOE
proposes that all universal voltage
commercial ballasts be tested at 277 V
and that universal voltage residential
and commercial cold-temperature
outdoor sign ballasts be tested at 120 V.
2. Test Setup
For the BLE measurements, DOE
proposes in this SNOPR that the
fluorescent lamp (ballast load) be
mounted in a standard strip fixture with
lamps facing upward to minimize selfheating according to ANSI C82.1–
11 ‘‘American National Standard for Fluorescent
Lamps—Guide for Electrical Measurements,’’
approved September 25, 1997.
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71581
solid conductor wire. All wires in the
fixture would be kept loose and not
bundled or taped to the fixture metal,
representing common wiring setups in
practice. The ballast under test may be
connected to the fixture through a
terminal strip mounted on the side of
the fixture or may be directly connected.
The ballast would be wired to the lamps
in the fixture according to the
manufacturer’s wiring instructions.
As previously proposed in the NOPR,
instrumentation for current, voltage, and
power measurements would be selected
in accordance with ANSI C78.375–
1997 14 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 would further specify
instrument performance within the
guidelines of the ANSI C78.375–1997
and ANSI C82.2–2002. Specifically,
lamp arc current would be measured
using a galvanically isolated current
probe/monitor with frequency response
between 40 Hertz (Hz) and 20 MHz. In
addition, lamp arc voltage and input
voltage would be measured directly by
a power analyzer with a maximum 100
picofarad (pF) capacitance to ground
and with frequency response between
40 Hz and 1 MHz. Coaxial cables would
not be used due to the excessive
capacitance associated with this wiring.
The input current may be measured
either with the internal shunt of a power
analyzer or with an external current
transducer specifically calibrated with
the power analyzer.
For the lamp arc current
measurement, the galvanically isolated
current probe must be calibrated with
the power analyzer. Furthermore, the
current transducer ratio must be set in
the analyzer to match the transducer to
the analyzer. The output from noninvasive current transducers is usually a
low voltage signal, so the actual current
to voltage ratio to the power analyzer
must consider the losses in addition to
the transducer ratio. Therefore, the full
current to voltage ratio (transducer ratio)
includes the voltage divider effect
between the transducer and the power
analyzer input. Assuming both the
power analyzer and non-invasive
current transducer are properly
calibrated, the actual current to voltage
ratio to use to fully correct the
measurement is as described in equation
1.
Iin = Current through the current transducer
Vout = Voltage out of the transducer
Rin = Power analyzer impedance
Rs = Current transducer output impedance
and depicted in Figure III.2, rapid- and
programmed-start ballast test setups
would include two 1000 ohm resistors
placed in parallel with both sets of lamp
pins. This voltage divider provides a
midpoint from which to measure the
lamp arc voltage, minimizing the impact
of cathode heating. Instant-start ballasts
would not employ a voltage divider, but
would require a jumper wire or an
adapter to connect to lamps with two
pins per electrode.
13 ‘‘American National Standard for Lamp
Ballasts—Definitions—for Fluorescent Lamps and
Ballasts,’’ approved July 23, 2002.
14 ‘‘American National Standard for Fluorescent
Lamps—Guide for Electrical Measurements,’’
approved September 25, 1997.
jdjones on DSK8KYBLC1PROD with PROPOSALS-1
The test setup would be different
depending on the ballast starting
method. As discussed in section III.C.2
12 ‘‘American National Standards for Lamp
Ballast—Line Frequency Fluorescent Lamp Ballast,’’
approved November 19, 2004.
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2004 12 and C78.81–2010. The
fluorescent lamp should be seasoned for
at least twelve hours and be tested to be
electrically stable and meet reference
lamp conditions as defined in ANSI
C82.13–2005.13 The ballast can be
placed on the test bench and the fixture
should be electrically connected to the
ballast case and to earth ground. The
ballast wire lengths would be as
specified in the manufacturer’s catalog
and not bundled or coiled to minimize
capacitive and inductive effects. If the
wire lengths supplied by the
manufacturer are of insufficient length
to reach both ends of lamp, additional
wire may be added. The minimal
additional wire length necessary would
be added, and the additional wire
would be the same wire gauge as the
wire supplied with the ballast. If no
wiring is provided with the ballast, DOE
proposes 18 American wire gauge
(AWG) or thicker wire should be used.
The wires would be separated from each
other and ground to prevent parasitic
capacitance for all wires used in the
apparatus, including those wires from
the ballast to the lamps and from the
lamps to the measuring devices. The test
fixture would be wired with 18 AWG
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programmed- and rapid-start ballasts
with full cathode cutout, and Figure
III.4 and Figure III.5 show the placement
for instant-start ballasts.
EP24NO10.378</GPH>
The power analyzer should have at least
one channel per lamp plus one
additional channel for the ballast input
power measurement. Figure III.3 shows
the instrumentation placement for the
lamp arc power measurement for
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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. 226 / Wednesday, November 24, 2010 / Proposed Rules
As discussed in the NOPR, DOE
proposes that the ballasts be tested with
the most common wattage lamp
operated by the ballast. 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. To test every lampand-ballast combination would impose
a significant burden on manufacturers.
Thus, to mitigate the testing burden on
manufacturers, the proposed test
procedure would require only one lampand-ballast combination to be tested in
each product class. Therefore, DOE
proposes a test procedure based on the
71583
ballast operating the most common
lamp wattage, resulting in a ballast
luminous efficiency that represents the
way the product is primarily used in the
market. Table III.2 indicates the nominal
lamp wattage that would be paired with
a ballast for testing.
TABLE III.2—BALLAST AND LAMP PAIRINGS
Nominal
lamp
wattage
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Lowfrequency
Highfrequency
32
34
T8 MBP ........
T12 MBP ......
30.8
32
29
*29.81
32
34
T8 MBP ........
T12 MBP ......
30.8
32
29
*29.81
86
95
T8 HO RDC
T12 HO RDC
N/A
90
86
*84.88
59
60
T8 slimline
SP.
T12 slimline
SP.
60.1
60.5
57
*56.91
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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 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.
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.
Reference lamp arc
power
EP24NO10.379</GPH>
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Ballast type
Lamp
diameter
and base
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Federal Register / Vol. 75, No. 226 / Wednesday, November 24, 2010 / Proposed Rules
TABLE III.2—BALLAST AND LAMP PAIRINGS—Continued
Nominal
lamp
wattage
Ballast type
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 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 °F or less and are used in outdoor signs.
Lamp
diameter
and base
Reference lamp arc
power
Lowfrequency
Highfrequency
28
T5 SO MiniBP.
N/A
27.8
54
T5 HO MiniBP.
N/A
53.8
32
34
T8 MBP ........
T12 MBP ......
30.8
32
29
*29.81
86
110
T8 HO RDC
T12 HO RDC
N/A
106
86
*100.03
MBP, Mini-BP, RDC, and SP represent medium bipin, miniature bipin, recessed double contact, and single pin, respectively.
* Empirically derived.
would be selected and the test would be
repeated.
After the system has stabilized, DOE
proposes that the measured input
parameters be voltage (RMS 15), current
(RMS), power, and power factor
measured in accordance with ANSI
C82.2–2002. The measured output
parameters would include lamp arc
voltage, current, and power. Lamp arc
current and voltage measurements
would be taken at the specified
locations according to the test setup.
Frequency of the output waveform
delivered to the lamp by the ballast
should also be measured.
3. Test Method
Once the lamp-and-ballast system is
connected and attached to the
measurement instrumentation, DOE
proposes that the ballast operate a
fluorescent lamp for a minimum of
fifteen minutes to a maximum of one
hour until stability is reached. DOE
notes that the NEMA Test Procedure
Handout indicated stability should be
determined in accordance with ANSI
C78.375–1997. DOE found the
specifications in this standard to be
unclear. To further specify the
determination of stabilization, DOE
proposes that measurements of lamp arc
voltage, lamp arc current, lamp arc
power be taken every one second during
the stabilization period. Once the
percent difference between the
minimum and maximum values for
voltage, current, and power do not
exceed one percent over a four minute
moving window, the system would be
considered stable. Allowing the lamp
and ballast system to reach its steady
state operating point will provide a
more accurate assessment of ballast
performance in the field. If the system
does not stabilize, a new ballast sample
The symbol b is equal to 0.9 for lowfrequency ballasts and is equal to 1.0 for
high-frequency ballasts.
DOE is also proposing a method of
calculating ballast factor to potentially
be used in the fluorescent lamp ballast
standards rulemaking to assign a ballast
to a particular product class. The
method specifies dividing the measured
lamp arc power on the test ballast by the
measured lamp arc power on a reference
ballast. The reference lamp arc power
will be the measured power determined
during reference lamp identification in
accordance with ANSI C78.375–2010,
ANSI C78.81–2010, and ANSI C82.3–
2002. Reference lamp measured power
can change over time which could
impact the BF calculation. Increasing
the frequency of the reference lamp
measurement could lead to increased
ballast factor calculation accuracy with
slightly increased testing burden. DOE
proposes that the reference lamp arc
15 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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4. Calculations
As described in Equation 2 below,
ballast luminous efficiency is equal to
total lamp arc power, divided by ballast
input power, multiplied by 100, and
then multiplied by 0.9 for ballasts that
operate lamps at low-frequency.
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DOE also found that ballasts are
capable of operating fewer than the
maximum number of lamps they are
designed to operate. For example, a
ballast designed to operate four lamps
can also operate two or three lamps.
However, DOE understands that ballasts
are typically paired with the maximum
number of lamps they are designed to
operate. As discussed in the NOPR, DOE
proposes to test fluorescent lamp
ballasts only while operating the
maximum number of lamps for which
they are designed to operate. DOE
believes this proposal both reduces
testing burden and assesses the
performance of the ballast in its primary
and most common configuration.
Federal Register / Vol. 75, No. 226 / Wednesday, November 24, 2010 / Proposed Rules
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power should be measured once every
24 hours for ballast factor calculation.
DOE invites comment on the frequency
at which the reference lamp power
should be measured on the reference
ballast.
Some lamp types do not have
reference ballast operating conditions
defined for both high- and lowfrequency operation. In these cases,
DOE has provided reference ballast
lamp arc powers based on lamp
operating conditions in ANSI C78.81–
2010 or IEC 60081 Ed 5.0, or as derived
by DOE. DOE empirically derived highfrequency F34T12, F96T12/ES,
F96T12HO/ES, and F96T12HO lamp arc
wattage by measuring lamp current and
voltage when the lamp emanated the
equivalent lumen output to the lowfrequency light output at ANSI reference
conditions.
As discussed in section III.C.2, NEMA
provided evidence in its written
comments that light output is directly
proportional to lamp arc power for the
ballast factor range of 0.75 to 1.15.
Outside this range, the relationship
starts to become nonlinear, but DOE
believes the assumption of a linear
relationship to still be reasonable for the
purpose of assigning ballast factor for
classification purposes. DOE notes that
the method of measuring ballast factor
using fixed reference ballast lamp arc
powers may be more susceptible to
reference lamp measured power
variation than a method that measures
lamp arc power on both the test and
reference ballast. This is because a
measured value (tested lamp arc power)
is being compared to a constant value
(reference lamp arc power from ANSI
C78.81–2010 or IEC 60081 Ed. 5.0)
rather than to another measured value
using the same lamp. This variation will
not impact the measured BLE value, but
could affect the standard to which the
ballast is subject. DOE invites comment
on the impact of variation in the
proposed ballast factor calculation for
certain lamp and ballast systems at
certain operating frequencies.
5. Updates to Existing Test Procedure
DOE is not changing the proposed
updates to the existing test procedure
from the NOPR in this SNOPR. DOE
would update the references to ANSI
standards for the existing light-outputbased test procedure. NEMA
commented that DOE should use the
latest versions of ANSI C82.2, C82.11,
and C82.1 at the time of finalized
rulemaking. (NEMA, No. 15 at p. 4,
Philips, Public Meeting Transcript, No.
12 at p. 36–37) DOE would use the most
recent versions of these standards,
namely ANSI C82.2–2002, ANSI
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C82.11–2002,16 and ANSI C82.1–2004.
The amendments to the existing test
procedure in Appendix Q to Subpart B
of 10 CFR part 430 would be effective
30 days after publication of any test
procedure final rule.
6. Normative References for ANSI
C82.2–2002
DOE is not changing its proposals
regarding the specification of normative
references to be used with ANSI C82.2–
2002 from the NOPR in this SNOPR.
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 to
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 would 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–
2010, 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.
E. 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 measures the
performance of a ballast by computing
the ratio of lamp arc power to ballast
input power and adjusting for lamp
operating frequency. The proposal is
16 ‘‘American National Standards for Lamp
Ballasts—High Frequency Lamp Ballasts—
Supplements,’’ approved January 17, 2002.
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less burdensome than the existing
procedure largely because of the
simplicity of electrical measurements
compared to photometric
measurements. In addition, the lamp
loads proposed in the SNOPR are less
expensive than precision resistor loads
proposed in the NOPR and are already
a common item used in test facilities.
The assessment of testing burden is
discussed in more detail with reference
to small businesses in section IV.C.
To further ensure that the test
procedure proposed in this SNOPR is
not unduly burdensome to conduct,
DOE is not proposing any changes to the
minimum sample size (four) for
generating a reported value or to the
reported value itself. Currently, to
demonstrate compliance with energy
conservation standards, manufacturers
must first test four examples of the basic
model. The reported value of BLE is
then equal to either the lower 99%
confidence interval limit divided by
0.99 or the mean of the four values,
whichever is smaller. DOE received
comment from NEMA supporting the
reported value as currently defined in
10 CFR 430.24. (NEMA, No. 15 at p. 3)
NEEA and NPCC also supported DOE
using a statistically valid method of
reporting efficiency of a ballast. (NEEA
& NPCC, Public Meeting Transcript, No.
12 at p. 175–176) In addition, Philips,
GE, and OSI commented that an
increase in the minimum number of
samples to ten or twenty samples from
70 categories of ballasts would be
burdensome as each test takes two to
three hours. (Philips, Public Meeting
Transcript, No. 12 at p. 177–178; OSI,
Public Meeting Transcript, No. 12 at p.
178; GE, Public Meeting Transcript, No.
12 at p. 178)
F. 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
would change the metric used to
describe in the energy efficiency of a
ballast. DOE is currently amending
energy conservation standards for
fluorescent lamp ballasts in the
fluorescent lamp ballast standards
rulemaking. In that rulemaking, DOE is
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Federal Register / Vol. 75, No. 226 / Wednesday, November 24, 2010 / Proposed Rules
considering 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. The BLE test procedure
proposal will not affect compliance with
existing energy conservation standards,
because DOE proposes that
manufacturers not be required to use the
new test procedure until the date
manufacturers are required to comply
with amended standards.
G. Scope of Applicability
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. DOE is
considering regulating certain ballasts
that operate F32T8, F34T12, F28T5SO,
F54T5HO, F96T8/ES, F96T12/ES,
F96T8HO, F96T12HO/ES, and
F96T12HO lamps. These ballasts can
operate between one and six lamps and
are used in commercial, residential, and
cold-temperature outdoor sign
applications. For the proposed test
procedure in this rulemaking, DOE
would establish particular test setups
and calculations depending on type of
ballast, as described in more detail in
section III.D. For example, DOE would
specify certain fluorescent lamps and
numbers of these lamps to be paired
with certain ballasts for determining
ballast performance.
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H. Certification and Enforcement
As discussed in the NOPR, DOE
regulations do not currently specify the
energy efficiency measurement to be
certified for fluorescent lamp ballasts.
10 CFR 430.62(a)(4). Earthjustice
commented that this omission
undermines effective enforcement and
negates the value of energy conservation
standards. NEEA and NPCC and the CA
utilities support DOE specifying the
energy efficiency measurement to be
certified for fluorescent lamp ballasts.
(NEEA & NPCC, No. 32 17 at p. 10;
Earthjustice, No. 14 at p. 1; CA Utilities,
No. 13 at p. 3) Earthjustice also
commented that DOE could publish a
17 This written comment was submitted in
response to the fluorescent lamp ballast energy
conservation standard preliminary analysis. 75 FR
14319.
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separate final rule to specify the energy
efficiency measurement to be certified
for fluorescent lamp ballasts on an
accelerated timeframe in advance of the
full test procedure final rule.
Earthjustice further indicated that if
manufacturers do not need to retest
units to ensure compliance with
existing standards using the test
procedure in appendix Q, there would
be no justification for permitting a
period of one year to submit data.
(Earthjustice, No. 14 at p. 1) DOE
appreciates these comments and has
responded to them in the notice of
proposed rulemaking for certification,
compliance, and enforcement for
consumer products and commercial and
industrial equipment. 75 FR 56796.
In the context of increasing
compliance with energy conservation
standards, Philips commented that
compliance and enforcement could be
improved by requiring the ballasts to be
tested at labs that meet certain
specifications such as having an audit
program and meeting International
Organization for Standardization (ISO)
criteria. Philips requested that DOE
make its criteria consistent with the
California Energy Commission (CEC)
criteria so that the same data set can be
used for certifying products with both
organizations. Philips also noted that it
has come to NEMA’s attention that some
offshore ballast suppliers with private
labeling may not be complying with
energy efficiency regulations. (Philips,
Public Meeting Transcript, No. 12 at p.
32–34) NEMA commented that they
believe a clear and concise test
procedure may encourage voluntary
compliance with energy conservation
standards. (NEMA, No. 15 at p. 7)
Furthermore, NEMA commented that a
change from the existing test procedure
to the test procedure proposed by
NEMA may yield increased compliance
by simplifying the methodology.
(NEMA, No. 15 at p. 2, 12)
DOE agrees that requiring certification
and compliance data to be generated in
a certified facility could increase the
integrity of the data. DOE also agrees
with NEMA that a clear and concise test
procedure may also foster voluntary
compliance. In this test procedure
SNOPR, DOE proposes the measurement
of BLE using electrical measurements of
a lamp and ballast system. DOE believes
this test procedure to be clearer and less
burdensome to conduct compared to the
existing method which may result in
increased compliance.
DOE also proposes that test facilities
conducting compliance testing in
accordance with amended standards
promulgated by the fluorescent lamp
ballast standards rulemaking be
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National Volunteer Laboratory
Accreditation Program (NVLAP)
accredited, a program administered by
the National Institute of Standards and
Technology (NIST), or accredited by an
organization recognized by NVLAP.
NVLAP accreditation is a finding of
laboratory competence, certifying that a
laboratory operates in accordance with
NVLAP management and technical
requirements. The NVLAP program is
described in 15 CFR part 285, and
encompasses the requirements of ISO/
IEC 17025.18 NVLAP (or an organization
recognized by NVLAP) accreditation is
currently required for laboratories
providing certification and compliance
data for general service fluorescent,
general service incandescent, and
incandescent reflector lamps. Either of
these accreditation requirements would
ensure that all the data DOE uses in its
rulemaking comes from standardized
and quality controlled sources,
increasing confidence in the precision
of the data and limiting variations due
to differences between testing
laboratories. DOE determined that
NVLAP imposes fees of $9000 and
$8000 on years one and two of
accreditation. For the years following,
the fees alternate between $5000 and
$8000, with the $8000 fee
corresponding to the on-site evaluation
required every other year. Fees for other
accreditation organizations are expected
to be similar. DOE invites comment on
the benefits and burden imposed by the
requirement that certification and
compliance data come from an NVLAP
or NVLAP recognized organization
accredited laboratory.
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
18 International Organization for Standardization/
International Electrotechnical Commission, General
requirements for the competence of testing and
calibration laboratories. ISO/IEC 17025.
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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. In this section, DOE
updates the certification provided to the
Office of Advocacy of the Small
Business Administration (SBA)
subsequent to publication of the NOPR.
The SBA has set a size threshold for
manufacturers of fluorescent lamp
ballasts that defines those entities
classified as ‘‘small businesses’’ for the
purposes of the Regulatory Flexibility
Analysis. 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
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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 identify potential small
manufacturers as defined by SBA, DOE
conducted a market survey using all
available public information. DOE’s
research involved several industry trade
association membership directories,
product databases, individual company
Web sites, and marketing research tools
(e.g., Dun 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 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 at least 10 fluorescent
lamp ballast manufacturers that produce
covered fluorescent lamp ballasts and
can potentially be considered small
businesses out of the 42 ballast
manufacturers listed in the preliminary
technical support document of the
fluorescent lamp ballast standards
rulemaking.
The proposed rule includes revisions
to appendix Q and a new appendix Q1.
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.
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. As described in more
detail in sections III.C and III.D, the
proposed test procedure in appendix Q1
is generally less burdensome compared
to the existing test procedure, while
reducing measurement variation. The
proposed procedure uses only electrical
measurements which are generally
simpler and more quickly carried out
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than photometric measurements. The
proposed procedure only uses a
reference ballast once every 24 hours,
rather than during the performance
evaluation of each individual ballast.
This change reduces the number of
measurements necessary for assigning a
BLE and BF to a ballast compared to the
number of measurements necessary for
BEF and BF under the existing test
procedure. In addition, the proposed
method specifies a shorter lamp
seasoning period (12 hours versus 100
hours) because the lamp’s electrical
characteristics stabilize sooner than its
photometric characteristics.
To analyze the testing burden impacts
described above on small business
manufacturers, DOE first sought to
examine publically available financial
data for those companies identified as
small businesses to compare the
estimated revenue and profit of these
businesses 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. DOE estimates that
the incremental testing costs for an
average small business would be no
more and likely less than testing costs
under the existing BEF test procedure
for the reasons set forth in the following
paragraph.
The BLE procedure requires no
additional equipment compared to the
existing test procedure and eliminates
the usage of photocells or an integrating
sphere. In addition, the existing BEF test
procedure requires measurements of
lamp light output on a reference ballast
and measurements on a test ballast
during each test. Light output
measurements and electrical
measurements of the reference system
can require one to two hours depending
on the number of reference ballasts
available and the speed at which the
lamp reaches photometric stability.
Light output and electrical
measurements of the test ballast are
taken immediately after switching the
lamps from the reference to the test
system. In contrast, the BLE proposal in
this SNOPR requires the reference
lamps to be measured and stabilized on
a reference ballast only once every
twenty four hours. After this
stabilization, subsequent testing of the
ballasts of interest can take between 15
and 60 minutes. DOE estimates that
between 4 and 8 ballast samples could
be completed in an eight hour period
using the existing BEF test procedure,
while between 8 and 16 tests could be
completed using the BLE test procedure.
Therefore, DOE estimates the BLE
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procedure could result in an
incremental reduction in testing time of
about 50%. Assuming the labor rate for
carrying out either procedure is $100
per hour, the BLE procedure could
reduce testing costs by $50 to $100
dollars per test. DOE notes that
depending on setup, some facilities may
see less of a reduction in testing time or
potentially no change in testing time.
In this SNOPR, DOE is also proposing
that test labs be accredited by NVLAP or
an organization recognized by NVLAP.
Accreditation by NVLAP or an NVLAPrecognized organization may cost
approximately $8000 per year, which
DOE believes would not be 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 has provided its certification and
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
Manufacturers of fluorescent lamp
ballasts must certify to DOE that their
products comply with any applicable
energy conservation standard. In
certifying compliance, manufacturers
must test their products according to the
DOE test procedure for fluorescent lamp
ballasts, including any amendments
adopted for that test procedure. DOE has
proposed regulations for the
certification and recordkeeping
requirements for all covered consumer
products and commercial equipment,
including fluorescent lamp ballasts. 75
FR 56796 (Sept. 16, 2010). The
collection-of-information requirement
for the certification and recordkeeping
is subject to review and approval by
OMB under the Paperwork Reduction
Act (PRA). This requirement has been
submitted to OMB for approval. Public
reporting burden for the certification is
estimated to average 20 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.
Public comment is sought regarding:
whether this proposed collection of
information is necessary for the proper
performance of the functions of the
agency, including whether the
information shall have practical utility;
the accuracy of the burden estimate;
ways to enhance the quality, utility, and
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clarity of the information to be
collected; and ways to minimize the
burden of the collection of information,
including through the use of automated
collection techniques or other forms of
information technology. Send comments
on these or any other aspects of the
collection of information to Ms. Linda
Graves (see ADDRESSES), and 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
also available at https://www.gc.doe.gov).
DOE examined today’s proposed rule
according to UMRA and its statement of
policy and determined that the 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.
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
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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
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
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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.
jdjones on DSK8KYBLC1PROD with PROPOSALS-1
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
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,
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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
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
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71589
the Chairman of the FTC concerning the
impact of these test procedures on
competition, prior to prescribing a final
rule.
V. Public Participation
A. 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. Interested
parties 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.
B. Issues on Which DOE Seeks Comment
DOE welcomes comments on all
aspects of this rulemaking. See section
I for further detail. In addition, DOE is
particularly interested in receiving
comments and views of interested
parties concerning the following issues:
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1. Impact of Ballast Output on Lamp
Efficacy
Authority: 42 U.S.C. 6291–6309; 28 U.S.C.
2461 note.
DOE seeks comment on the impact of
lamp current crest factor, waveform, and
lamp operating frequency on the
efficacy of a fluorescent lamp. DOE also
seeks comment on its decision to adjust
the BLE of low-frequency ballasts by a
factor of 0.9. See section III.C.2 for
further detail.
2. Section 430.3 is amended by:
a. Redesignating paragraphs:
1. (c)(11) as (c)(14);
2. (c)(6) through (c)(10) as (c)(7)
through (c)(11);
3. (c)(12) as (c)(13);
4. (c)(13) as (c)(17);
b. Adding the phrase ‘‘, Appendix Q1’’
before ‘‘and’’ in paragraph (c)(5) and in
newly designated paragraph (c)(8); and
adding the phrase ‘‘Appendix Q1 and’’
in newly designated paragraph (c)(14)
before ‘‘Appendix’’;
c. Revising newly designated
paragraph (c)(13); and
d. Adding new paragraphs (c)(6),
(c)(12), (c)(15), and (c)(16).
These revisions and additions read as
follows:
2. Ballast Factor Calculation
DOE seeks comment on the proposed
technique for calculating ballast factor
and on the lamp arc powers empirically
derived. DOE also seeks comment on
how frequently reference lamp power
(on a reference ballast) should be
measured. See section III.D.4 for further
detail.
3. Impact of Reference Lamp Measured
Power Variation on Ballast Factor
DOE seeks comment on the impact of
reference lamp measured power
variation on the ballast factor
calculation. See section III.D.4 for
further detail.
4. Laboratory Accreditation
DOE seeks comment on the potential
benefits and burden imposed as a result
of requiring all certification and
compliance data to be generated at a
laboratory accredited by NVLAP or an
organization recognized by NVLAP. See
section III.H 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.
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Issued in Washington, DC on November 4,
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:
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§ 430.3 Materials incorporated by
reference.
*
*
*
*
*
(c) * * *
(6) ANSI C78.81–2010, Revision of
ANSI C78.81–2005 (‘‘ANSI C78.81–
2010’’), American National Standard for
Electric Lamps—Double-Capped
Fluorescent Lamps—Dimensional and
Electrical Characteristics, approved
January 14, 2010; IBR approved for
Appendix Q and Appendix Q1 to
subpart B.
*
*
*
*
*
(12) 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 and
Appendix Q1 to Subpart B.
(13) ANSI C82.2–2002, Revision of
ANSI C82.2–1994 (R1995), American
National Standard for Lamp BallastsMethod of Measurement of Fluorescent
Ballasts, Approved June 6, 2002, IBR
approved for Appendix Q and
Appendix Q1 to subpart B.
*
*
*
*
*
(15) 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 and
Appendix Q1 to subpart B.
(16) 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 and Appendix Q1 to
subpart B.
*
*
*
*
*
3. Section 430.23 is amended by
revising paragraph (q) to read as follows:
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§ 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 6.2.6 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
standards for fluorescent lamp ballasts.
Ballast luminous efficiency (BLE) shall
be as determined in section 7.2 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 6.2.6 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. Section 430.25 is revised to read as
follows:
§ 430.25 Laboratory Accreditation
Program.
The testing for fluorescent lamp
ballasts shall be performed in
accordance with Appendix Q1 to this
subpart. The testing for general service
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*
*
*
*
*
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 of a
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).
*
*
*
*
*
Appendix Q is effective until the
compliance date of the amended standards
for fluorescent lamp ballasts. After this date,
2. Test Conditions.
2.1 Measurement of Active Mode Energy
Consumption, BEF. 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 described in this section (2.1) are
applicable to section 3.1 of section 3, Test
Method and Measurements.
2.2 Measurement of Standby Mode
Power. The measurement of standby mode
power need not be performed to determine
compliance with energy conservation
standards for fluorescent lamp ballasts at this
time. This and the previous 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
standby power are described in sections 5, 7,
and 8 of ANSI C82.2–2002. Fluorescent lamp
ballasts that are capable of connections to
Where:
Photocell output of lamp on test ballast is
determined in accordance with section
3.1.4.2, expressed in watts, and photocell
output of lamp on ref. ballast is
determined in accordance with section
3.1.4.1, expressed in watts.
4.2 Determine the Ballast Efficacy Factor
(BEF) using the following equations:
(a) Single lamp ballast
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Appendix Q to Subpart B of Part 430—
Uniform Test Method for Measuring the
Energy Consumption of Fluorescent
Lamp Ballasts
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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 3.2 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 C82.1–2004
(incorporated by reference; see § 430.3) for
testing low-frequency ballasts and ANSI
C82.11–2002 (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).
*
*
*
*
*
3.1.3.1 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.
*
*
*
*
*
3.1.4.1 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.
*
*
*
*
*
3.2.1 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:
(b) Multiple lamp ballast
E:\FR\FM\24NOP1.SGM
24NOP1
EP24NO10.391</MATH>
all fluorescent lamp ballasts shall be tested
using the provisions of Appendix Q1.
EP24NO10.390</MATH>
fluorescent lamps, general service
incandescent lamps, and incandescent
reflector lamps shall be performed in
accordance with Appendix R to this
subpart. The testing for medium base
compact fluorescent lamps shall be
performed in accordance with
Appendix W of this subpart. This
testing shall be conducted by test
laboratories accredited by the National
Voluntary Laboratory Accreditation
Program (NVLAP) or by an accrediting
organization recognized by NVLAP.
NVLAP is a program of the National
Institute of Standards and Technology,
U.S. Department of Commerce. NVLAP
standards for accreditation of
laboratories that test for compliance
with standards for fluorescent lamp
ballast ballast luminous efficiency
(BLE), fluorescent lamp efficacy, and
fluorescent lamp CRI are set forth in 15
CFR part 285. A manufacturer’s or
importer’s own laboratory, if accredited,
may conduct the applicable testing.
5. Appendix Q to subpart B of part
430 is amended by:
a. Adding an introductory paragraph
after the Appendix heading.
b. Revising sections 1.15, 1.16, 1.17,
and 2.
c. 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.
d. Revising newly 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.
e. 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.
f. Adding sections 3.1 and 3.2.1.
g. Revising section 4.
These revisions and additions read as
follows:
71591
71592
Federal Register / Vol. 75, No. 226 / Wednesday, November 24, 2010 / Proposed Rules
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):
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.
6. 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. Where ANSI C82.2–2002 (incorporated
by reference; see § 430.3) references ANSI
C82.1–1997, the operator shall use ANSI
C82.1–2004 (incorporated by reference; see
§ 430.3) for testing low-frequency ballasts
and shall use ANSI C82.11–2002
(incorporated by reference; see § 430.3) for
high-frequency ballasts.
2. Definitions
2.1. Cathode heating refers to power
delivered to the lamp by the ballast for the
purpose of raising the temperature of the
lamp electrode or filament.
2.2. Commercial ballast is a fluorescent
lamp ballast that is not a residential ballast
as defined in section 2.9 and meets technical
standards for non-consumer RF lighting
devices as specified in subpart C of 47 CFR
part 18.
2.3. High-frequency ballast is as defined in
ANSI C82.13–2002 (incorporated by
reference; see § 430.3).
2.4. Instant-start is the starting method
used instant-start systems as defined in ANSI
C82.13–2002 (incorporated by reference; see
§ 430.3).
2.5. 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.
2.6. Programmed-start is the starting
method used in programmed-start systems as
defined in ANSI C82.13–2002 (incorporated
by reference; see § 430.3).
2.7. Rapid-start is the starting method used
in rapid-start type systems as defined in
ANSI C82.13–2002 (incorporated by
reference; see § 430.3).
2.8. Reference lamp is a fluorescent lamp
that meets certain operating conditions as
defined by ANSI C82.13–2002 (incorporated
by reference; see § 430.3).
2.9. 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.
2.10. RMS is the root mean square of a
varying quantity.
3. Instruments
3.1. All instruments shall be as specified
by ANSI C82.2–2002 (incorporated by
reference; see § 430.3).
3.2. 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.
3.3. 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.
4. Test Setup
4.1. The ballast shall be connected to a
main power source and to the fluorescent
lamp load according to the manufacturer’s
wiring instructions and ANSI C82.1–2004
(incorporated by reference; see § 430.3) and
C78.81–2010 (incorporated by reference; see
§ 430.3).
4.1.1. Wire lengths between the ballast and
fluorescent lamp shall be the length provided
by the ballast manufacturer. Wires shall be
kept loose and not shortened or bundled.
4.1.1.1. If the wire lengths supplied with
the ballast are of insufficient length to reach
both ends of lamp, additional wire may be
added. The minimal additional wire length
necessary shall be added, and the additional
wire shall be the same wire gauge as the wire
supplied with the ballast. If no wiring is
provided with the ballast, 18 gauge or thicker
wire shall be used. The wires shall be
separated from each other and ground to
prevent parasitic capacitance for all wires
used in the apparatus, including those wires
from the ballast to the lamps and from the
lamps to the measuring devices.
4.1.2. The fluorescent lamp shall meet the
specifications of a reference lamp as defined
by ANSI C82.13–2002 (incorporated by
reference; see § 430.3) and be seasoned at
least 12 hours.
4.2. The ballast shall be connected to the
number of lamps equal to the maximum
number of lamps the ballast is designed to
operate.
4.3. The ballast shall be tested with a
reference lamp of the nominal wattage listed
in Table A.
TABLE A—LAMP-AND-BALLAST PAIRINGS & REFERENCE LAMP ARC POWER
Nominal
lamp
wattage
High
frequency
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.
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32
T8 MBP
30.8
29
34
32
T12 MBP
T8 MBP
32
30.8
29.81
29
34
86
T12 MBP
T8 HO RDC
32
N/A
29.81
86
95
59
T12 HO RDC
T8 slimline
SP
90
60.1
84.88
57
60
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.
jdjones on DSK8KYBLC1PROD with PROPOSALS-1
Low
frequency
T12 slimline
SP
60.5
56.91
E:\FR\FM\24NOP1.SGM
24NOP1
EP24NO10.393</MATH>
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.
Reference lamp arc
power
EP24NO10.392</MATH>
Ballast type
Lamp
diameter and
base
Federal Register / Vol. 75, No. 226 / Wednesday, November 24, 2010 / Proposed Rules
71593
TABLE A—LAMP-AND-BALLAST PAIRINGS & REFERENCE LAMP ARC POWER—Continued
Nominal
lamp
wattage
Ballast type
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.
Lamp
diameter and
base
Reference lamp arc
power
Low
frequency
High
frequency
T5 SO MiniBP
N/A
27.8
54
T5 HO MiniBP
N/A
53.8
32
T8 MBP
30.8
29
34
86
T12 MBP
T8 HO RDC
32
N/A
29.81
86
110
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 °F or less and are used in outdoor signs.
28
T12 HO RDC
106
100.03
MBP, Mini-BP, RDC, and SP represent medium bipin, miniature bipin, recessed double
contact, and single pin, respectively..
according to Figure 1 for rapid- and
programmed-start ballasts, Figure 2 for
instant-start ballasts operating SP lamps, and
Figure 3 for instant-start ballasts operating
MBP, mini-BP, and RDC lamps.
4.4.3.1. For the lamp arc current
measurement, the full transducer ratio shall
be set in the power analyzer to match the
current probe to the power analyzer.
Rin Power analyzer impedance
Rs Current probe output impedance
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24NOP1
EP24NO10.382</GPH>
ballasts operating medium bipin (MBP),
miniature bipin (mini-BP), or recessed
double contact (RDC) lamps. The
programmed- and rapid-start ballast test
setup includes two 1000 ohm resistors placed
in parallel with the lamp pins to create a
midpoint from which to measure lamp arc
voltage.
4.4.3. Lamp Arc Current. A current probe
shall be positioned on each fluorescent lamp
Where:
Iin Current through the current transducer
Vout Voltage out of the transducer
jdjones on DSK8KYBLC1PROD with PROPOSALS-1
4.4. Power Analyzer
4.4.1. The power analyzer shall have n +
1 channels where n is the number of lamps
a ballast operates.
4.4.2. Lamp Arc Voltage. Leads from the
power analyzer should attach to each
fluorescent lamp according to Figure 1 for
rapid- and programmed-start ballasts, Figure
2 for instant-start ballasts operating single
pin (SP) lamps, and Figure 3 for instant-start
EP24NO10.384</GPH>
Federal Register / Vol. 75, No. 226 / Wednesday, November 24, 2010 / Proposed Rules
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EP24NO10.383</GPH>
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71594
Federal Register / Vol. 75, No. 226 / Wednesday, November 24, 2010 / Proposed Rules
Where:
Total test ballast lamp arc power is the sum
of the lamp arc powers for all lamps
operated by the ballast as determined in
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PO 00000
accordance with section 6.2.5, expressed
in watts, and total reference ballast lamp
arc power is determined in accordance
with section 6.1.1, expressed in watts.
Frm 00029
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current, and power once per second in
accordance with the setup described in
section 4. Once the difference between the
maximum and minimum values for lamp arc
voltage, current, and power do not exceed
one percent over a four minute moving
window, the system shall be considered
stable.
6.2.3. Lamp Arc Voltage. Measure lamp arc
voltage (volts) using the setup described in
section 4.4.2.
6.2.4. Lamp Arc Current. Measure lamp arc
current (amps) using the setup described in
section 4.4.3.
6.2.5. Lamp Arc Power. The power
analyzer shall calculate output power by
using the measurements described in section
6.2.3 and 6.2.4.
6.2.6. 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.
6.2.7. 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.
6.2.8. 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.
6.2.9. Lamp Operating Frequency. Measure
the frequency of the waveform delivered
from the ballast to any lamp in accordance
with the setup in section 4.
7. Calculations
7.1. Calculate ballast factor (BF):
7.2. Calculate ballast luminous efficiency
(BLE).
E:\FR\FM\24NOP1.SGM
24NOP1
EP24NO10.386</GPH>
one input voltage shall be tested at that
specified voltage.
6. Test Method
6.1. Ballast Factor
6.1.1. Reference ballast lamp arc power
shall be measured with a reference ballast at
the same frequency as the test ballast in
accordance with ANSI C78.375–1997
(incorporated by reference; see § 430.3), ANSI
C78.81–2010 (incorporated by reference; see
§ 430.3), and ANSI C82.3–2002 (incorporated
by reference; see § 430.3). Total reference
ballast lamp arc power shall be equal to the
sum of the reference ballast lamp arc powers
of all the reference lamps used with the test
ballast. Reference ballast lamp arc power
shall be measured once every 24 hours.
6.1.1.1. If the reference ballast
characteristics are not specified in ANSI
C78.81–2010 (incorporated by reference; see
§ 430.3), then the reference ballast lamp arc
power shall be equal to the reference lamp
power value listed in Table A times the
maximum number of lamps the ballast is
designed to operate. The reference lamp
power selected from Table A should be at the
same frequency as the test ballast.
6.2. Ballast Luminous Efficiency.
6.2.1. The ballast shall be connected the
appropriate fluorescent lamps and to
measurement instrumentation as indicated
by the Test Setup in section 4.
6.2.2. The ballast shall be operated for at
least 15 minutes but no longer than 1 hour
until stable operating conditions are reached.
After this condition is reached, concurrently
measure the parameters described in sections
6.2.3 through 6.2.9.
6.2.2.1. Stable operating conditions are
determined by measuring lamp arc voltage,
EP24NO10.385</GPH>
jdjones on DSK8KYBLC1PROD with PROPOSALS-1
5. Test Conditions
5.1. 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 C78.81–2010
(incorporated by reference; see § 430.3), ANSI
C82.1–2004 (incorporated by reference; see
§ 430.3), ANSI C82.3–2002 (incorporated by
reference; see § 430.3), ANSI C82.11–2002
(incorporated by reference; see § 430.3), and
ANSI C82.13–2002 (incorporated by
reference; see § 430.3). All other normative
references shall be as specified in ANSI
C82.2–2002.
5.2. Room Temperature and Air
Circulation. The test facility shall be held at
25 ± 2°C, with minimal air movement as
defined in ANSI C78.375–1997 (incorporated
by reference; see § 430.3).
5.3. 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
multiple voltages, the ballast shall be tested
at 120V ± 0.1%. For ballasts designed and
labeled as cold-temperature outdoor sign
ballasts and capable of operating at multiple
voltages, the ballast shall be tested at 120V
± 0.1%. Ballasts capable of operating at only
71595
71596
Federal Register / Vol. 75, No. 226 / Wednesday, November 24, 2010 / Proposed Rules
[FR Doc. 2010–28793 Filed 11–23–10; 8:45 am]
BILLING CODE 6450–01–P
DEPARTMENT OF ENERGY
10 CFR Part 431
[Docket No. EERE–2010–BT–TP–0034]
RIN 1904–AC40
Energy Efficiency Program for Certain
Commercial and Industrial Equipment:
Test Procedures for Commercial
Refrigeration Equipment
Office of Energy Efficiency and
Renewable Energy, Department of
Energy.
ACTION: Notice of proposed rulemaking
and public meeting.
AGENCY:
The U.S. Department of
Energy (DOE) proposes amendments to
its test procedure for commercial
refrigeration equipment (CRE). The
amendments would update the
referenced industry test procedures to
the most current version, incorporate
methods to evaluate the energy impacts
resulting from the use of night curtains
and lighting occupancy sensors, and
allow testing of certain commercial
refrigerators at their lowest application
product temperature. These test
procedures will apply to commercial
refrigerators, freezers, and refrigeratorfreezers, as defined in the Energy Policy
and Conservation Act of 1975 (EPCA),
as amended. Use of any amended test
procedures will be required on the
compliance date of any standards
developed in the associated energy
conservation standard rulemaking. DOE
will hold a public meeting to receive
and discuss comments on the proposal.
DATES: DOE will hold a public meeting
in Washington, DC on Thursday,
January 6, 2011, from 9 a.m. to 4 p.m.
jdjones on DSK8KYBLC1PROD with PROPOSALS-1
SUMMARY:
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Additionally, DOE plans to conduct the
public meeting via webinar. DOE will
accept comments, data, and other
information regarding this notice of
proposed rulemaking (NOPR) before or
after the public meeting, but no later
than January 24, 2011. See section V,
‘‘Public Participation,’’ of this NOPR for
details.
You can attend the public meeting via
webinar, and registration information,
participant instructions, and
information about the capabilities
available to webinar participants will be
published on the following Web site:
https://www1.gotomeeting.com/join/
638471849. Participants are responsible
for ensuring their systems are
compatible with the webinar software.
The purpose of the meeting is to
receive comments and to help DOE
understand potential issues associated
with this proposed rulemaking. DOE
must receive requests to speak at the
meeting before 4 p.m., Thursday,
December 22, 2010. DOE must receive a
signed original and an electronic copy
of statements to be given at the public
meeting before 4 p.m., Thursday,
December 29, 2010.
ADDRESSES: The public meeting will be
held at the U.S. Department of Energy,
Forrestal Building, Room 1E–245, 1000
Independence Avenue, SW.,
Washington, DC 20585–0121. Please
note that foreign nationals planning to
participate in the public meeting are
subject to advance security screening
procedures which require advance
notice of 30 days prior to attendance of
the public meeting. 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 parties may submit
comments, identified by docket number
EERE–2010–BT–TP–0034 or Regulation
Identifier Number (RIN) 1904–AC40, by
any of the following methods:
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
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high-frequency ballasts and 0.9 for lowfrequency ballasts.
7.3. Calculate Power Factor (PF).
• E-mail: CRE–2010–TP–
0034@ee.doe.gov. Include the docket
number EERE–2010–BT–TP–0034 and/
or RIN 1904–AC40 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.
Written comments regarding the
burden-hour estimates or other aspects
of the collection-of-information
requirements contained in this proposed
rule may be submitted to Office of
Energy Efficiency and Renewable
Energy through the methods listed
above and by e-mail to
Christine_J._Kymn@omb.eop.gov.
Instructions: All submissions must
include the docket number or RIN for
this rulemaking. 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: Mr.
Charles Llenza, U.S. Department of
Energy, Office of Energy Efficiency and
Renewable Energy, Building
Technologies, EE–2J, 1000
Independence Avenue, SW.,
Washington, DC 20585–0121.
Telephone: (202) 586–2192,
Charles_Llenza@ee.doe.gov. In the
Office of General Council contact Mr.
E:\FR\FM\24NOP1.SGM
24NOP1
EP24NO10.388</GPH>
Where:
Ballast input power is determined in
accordance with section 6.2.6, input
voltage is determined in accordance with
section 6.2.7, and input current in
determined in accordance with section
6.2.8.
ballast as determined by section 6.2.5,
ballast input power is as determined by
section 6.2.6, and b is equal to 1.0 for
EP24NO10.387</GPH>
Where:
Total Lamp Arc Power is the sum of the lamp
arc powers for all lamps operated by the
]]>Agencies
[Federal Register Volume 75, Number 226 (Wednesday, November 24, 2010)]
[Proposed Rules]
[Pages 71570-71596]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-28793]
=======================================================================
-----------------------------------------------------------------------
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: Supplemental notice of proposed rulemaking.
-----------------------------------------------------------------------
SUMMARY: The U.S. Department of Energy (DOE) proposes to revise 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. Furthermore, this proposed test procedure would measure a
new metric, ballast luminous efficiency (BLE), which more directly
assesses the electrical losses in a ballast compared to the existing
ballast efficacy factor (BEF) metric. Rather than testing a ballast
with a resistive load as proposed in the March 24, 2010 notice of
proposed rulemaking (NOPR), the BLE test procedure would measure the
performance of a ballast while operating a fluorescent lamp.
DATES: DOE will accept comments, data, and information regarding this
supplemental notice of proposed rulemaking (SNOPR) no later than
December 27, 2010. See section V, ``Public Participation,'' of this
SNOPR for details.
ADDRESSES: Any comments submitted must identify the Fluorescent Lamp
Ballast Active Mode Test Procedure SNOPR, 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.
[[Page 71571]]
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.
Elizabeth 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: Elizabeth.Kohl@hq.doe.gov.
For additional information on how to submit or review public
comments, 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 Supplemental Notice of Proposed Rulemaking
III. Discussion
A. Existing Test Procedure
B. Metric
C. Test Procedures Considered
1. Resistor-based Ballast Efficiency Correlated to BEF
2. Lamp-based Ballast Efficiency Correlated to BEF
3. Improved Light-Output-Based Test Procedure
4. Relative System Efficacy
5. Dimming Ballast Test Procedure
D. Test Procedure Proposal
1. Test Conditions
2. Test Setup
3. Test Method
4. Calculations
5. Updates to Existing Test Procedure
6. Normative References for ANSI C82.2-2002
E. Burden To Conduct the Proposed Test Procedure
F. Impact on Measured Energy Efficiency
G. Scope of Applicability
H. 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. Submission of Comments
B. Issues on Which DOE Seeks Comment
1. Impact of Ballast Output on Lamp Efficacy
2. Ballast Factor Calculation
3. Impact of Reference Lamp Measured Power Variation on Ballast
Factor
4. NVLAP Accreditation
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) 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 EPCA, the overall program consists essentially of the
following parts: Testing, labeling, certification and enforcement, and
Federal energy conservation standards. The testing requirements consist
of test procedures that manufacturers of covered products must use as
the basis for certifying to DOE that their products comply with energy
conservation standards and for representing 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.
---------------------------------------------------------------------------
The Energy Independence and Security Act of 2007 also amended EPCA
to require DOE to review test procedures for all covered products at
least once every seven years. DOE must either amend the test procedures
or publish notice in the Federal Register of any determination not to
amend a test procedure. (42 U.S.C. 6293(b)(1)(A)) To fulfill this
periodic review requirement, DOE invites comment on all aspects of the
existing test procedures for fluorescent lamp ballasts 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. 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 relevant to this test
procedure rulemaking. On March 24, 2010, DOE published a notice of
public meeting and availability of the preliminary technical support
document
[[Page 71572]]
(TSD) for the fluorescent lamp ballast standards rulemaking. 75 FR
14319.
DOE also published a test procedure notice of proposed rulemaking
NOPR on March 24, 2010. 75 FR 14288. On April 26, 2010, DOE held a
joint public meeting to discuss the test procedure proposals in the
NOPR and the preliminary TSD for the fluorescent lamp ballast standards
rulemaking (hereafter ``NOPR public meeting''). All comments on the
fluorescent lamp ballast test procedure rulemaking are discussed in
section III of this proposed rulemaking.
As mentioned in the NOPR, 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. (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. This supplemental
notice of proposed rulemaking does not propose any changes to the
measurement of standby and off mode energy consumption for fluorescent
lamp ballasts.
II. Summary of the Supplemental Notice of Proposed Rulemaking
In this supplemental notice of proposed rulemaking (SNOPR), DOE
proposes to modify the current procedures for fluorescent lamp ballasts
to reduce measurement variation and reduce testing burden. The proposed
method would eliminate photometric measurements and propose the use of
electrical measurements of a lamp-and-ballast system. In addition, this
test procedure measures a new metric, ballast luminous efficiency
(BLE), which more directly assesses the electrical losses in a ballast
compared to the existing ballast efficacy factor (BEF) metric. The
SNOPR proposal also describes a new method for calculating the ballast
factor (BF) of a system. DOE also outlines the scope of applicability
of the test procedure and proposes a minor update of the existing test
procedure in appendix Q. The following paragraphs summarize these
proposed changes.
In the NOPR, DOE proposed a resistor-based ballast efficiency
measurement that would then be correlated to BEF. In response to
comments received citing the limitations of a resistor-based
measurement, DOE proposes in this SNOPR to measure ballast input power
and lamp arc power using only electrical measurements of a lamp-and-
ballast system. Variation in the measured power of a reference lamp is
minimized by the calculation of ballast luminous efficiency, where BLE
is equal to total lamp arc power divided by ballast input power. To
account for the increase in lamp efficacy associated with high-
frequency lamp operation versus low-frequency, DOE is also proposing an
adjustment to the BLE of low-frequency systems. DOE is proposing that
low-frequency BLE be multiplied by 0.9 to account for the approximately
10% increase in lighting efficacy associated with high-frequency lamp
operation. DOE also proposes a method for calculating the ballast
factor (BF) of a ballast by dividing the measured lamp arc power on the
test ballast by the measured lamp arc power on a reference ballast.
Ballast factor is under consideration in the fluorescent lamp ballast
standards rulemaking as criteria for defining product classes. In cases
where reference ballast operating conditions are unavailable, the SNOPR
provides a reference lamp power (specific to the ballast type) from an
ANSI standard or from empirical results. Particular lamp and ballast
pairings are specified for both the BLE and BF measurements.
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 provisions for the testing of ballasts identified in
the preliminary determination of scope. If the scope of coverage
changes in later stages of the fluorescent lamp ballast standards
rulemaking, DOE will add or remove provisions from the test procedure
so that it is consistent with the final scope of coverage of standards.
See section III.G for further detail.
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 will describe the efficiency of a ballast in terms of a
new metric, BLE. 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 BLE generated by the active mode test procedure proposed in
this rulemaking. As a result, DOE proposes that use of any revised test
procedure, to be published as Appendix Q1 of 10 CFR part 430 Subpart B,
would be required concurrent with the compliance date of any amended
fluorescent lamp ballast standards. DOE is required by a consent decree
to issue any amended fluorescent lamp ballast standards by June 30,
2011.
As described in the NOPR, 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 use of
any amended test procedure to be published at Appendix Q1 is required,
manufacturers should continue testing these ballasts using the existing
test procedure to determine compliance with existing standards. In the
NOPR, DOE proposed to make minor updates to the existing test
procedure, published at Appendix Q to Subpart B of part 430. The SNOPR
does not affect this proposal. DOE would update the reference to ANSI
C82.2-1984 in the existing test procedure (appendix Q) to ANSI C82.2-
2002.\3\ 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 use of the amendments to Appendix Q be
required upon the effective date of any test procedure final rule, 30
days after publication. In addition, the test procedures for any
ballasts that operate in standby mode are also located in Appendix Q.
---------------------------------------------------------------------------
\3\ ``American National Standards for Lamp Ballasts--Method of
Measurement of Fluorescent Lamp Ballasts,'' approved June 6, 2002.
---------------------------------------------------------------------------
III. Discussion
A. Existing Test Procedure
The existing ballast test procedure (in Appendix Q to subpart B of
10 CFR part
[[Page 71573]]
430) determines the energy efficiency of a fluorescent lamp ballast
based on light output measurements and ballast input power. The metric
used is called ballast efficacy factor. 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 \4\ 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 system by the photocell output of the reference
ballast system yields relative light output or ballast factor.
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 and multiplying by 100. A ballast
that produces more light than another ballast with the same input power
will have a larger BEF.
---------------------------------------------------------------------------
\4\ 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.
---------------------------------------------------------------------------
The National Electrical Manufacturers Association (NEMA) commented
that BEF measurements would vary by plus or minus five percent and that
this variation is unacceptable when trying to differentiate between
products that vary in efficiency by three to five percent. (NEMA, No.
15 at p. 13) For BEF, the variation in measured power of the reference
lamps (rated power 2.5%) plus the variation in the
photometric measurement system itself leads to the plus or minus 5%
variation. Given the variation observed in BEF measurement, NEMA also
does not believe a thousandths place digit in a BEF measurement
discussed in the proposed rule has any statistical validity. In
contrast, NEMA noted that for the ballast efficiency (BE) measurement
proposed in the NOPR, the power analyzer equipment introduces plus or
minus 1.5% variation into the measurement and the current transducer
and wiring capacitances contribute 1% for a total of plus or minus 2.5%
variation (NEMA, Public Meeting Transcript, No. 12 at p. 15-16, 22-25).
DOE agrees that photometric based BEF measurements are more variable
than electrical measurement based BE measurements. In this test
procedure SNOPR, DOE is proposing a methodology that uses electrical
measurements of a lamp and ballast system to measure BLE. The BLE
metric includes a modification to the BE metric discussed in the NOPR
to account for changes in lamp efficacy as a result of differences in
lamp operating frequency.
B. Metric
In the NOPR, DOE proposed a resistor-based ballast efficiency
measurement that would then be correlated to BEF, for consistency with
the standards set forth at 42 U.S.C. 6295(g)(5) and (8). At the NOPR
public meeting, the Appliance Standards Awareness Project (ASAP) and
Earthjustice commented that they did not believe DOE was required to
regulate ballasts using the BEF metric. (ASAP, Public Meeting
Transcript, No. 12 at p. 98-99 \5\; Earthjustice, Public Meeting
Transcript, No. 12 at p. 100)
---------------------------------------------------------------------------
\5\ A notation in the form ``ASAP, Public Meeting Transcript,
No. 12 at p. 98-99'' 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 April 26, 2010; (2) in
document number 12 in the docket of this rulemaking; and (3)
appearing on pages 98 through 99 of the transcript.
---------------------------------------------------------------------------
In response to these comments, DOE is proposing a new metric to
describe the efficiency of a ballast called ballast luminous efficiency
(BLE). EPCA does not require DOE to set standards for fluorescent lamp
ballasts using the BEF metric and grants DOE the authority to use test
procedures for measuring energy efficiency that it determines are
appropriate. (42 U.S.C. 6291, 6295(g), and 6293(b)(5)) The BLE metric
and test procedure are based on the NEMA lamp-based ballast efficiency
(BE) test procedure considered in the test procedure NOPR. Similar to
the procedure considered in the NOPR, the BLE test procedure measures
ballast input power and lamp arc power of a lamp-and-ballast system.
The only difference between the BE procedure considered in the NOPR and
the proposed BLE test procedure is the proposed adjustment to the BLE
of low-frequency systems to account for the increase in lamp efficacy
associated with high-frequency lamp operation versus low-frequency.
Specifically, DOE is proposing that low-frequency BLE be multiplied by
0.9 to account for the approximately 10% increase in lighting efficacy
associated with high-frequency lamp operation. DOE also proposes a
method for calculating the ballast factor (BF) of a system by dividing
the measured lamp arc power on the test ballast by the measured lamp
arc power on a reference ballast. In cases where reference ballast
operating conditions are unavailable, the SNOPR provides a reference
lamp power (specific to the ballast type and operating frequency) from
an ANSI standard or from empirical results. The ballast factor
measurement is described in more detail in section III.D.4. Particular
lamp and ballast pairings are specified for both the BLE and BF
measurements.
DOE is proposing the BLE test procedure because it reduces
measurement variation and testing burden compared to the existing test
procedure. In contrast to BEF and RSE, the BLE metric can be used to
compare the efficiency across many different types of ballasts. DOE
also believes the use of a lamp-and-ballast system allows the ballast
to operate at its natural operating point and will more accurately
assess ballast performance than when the ballast test load is a
resistor. Furthermore, a resistive load can only model the effective
resistance of a lamp operated at a particular ballast factor, requiring
multiple ballast factor specific resistors to be specified and
increasing the testing cost to manufacturers. DOE also believes that
the use of electrical measurements and the calculation of BLE reduce
the impact of lamp manufacturing variation on the efficiency descriptor
compared to the existing test procedure.
C. Test Procedures Considered
In the NOPR, DOE proposed a resistor-based ballast efficiency
measurement correlated to BEF. DOE also provided descriptions of
alternative test procedures it considered in the course of developing
its proposal. Interested parties commented on the proposed methodology
and the three alternative methods considered. The following sections
discuss DOE's responses to interested party comments.
1. Resistor-Based Ballast Efficiency Correlated to BEF
In the NOPR, DOE proposed a test procedure to measure a resistor-
based BE, which would then be correlated to BEF. This procedure used
precision resistive loads to simulate the effective resistance of a
fluorescent lamp as the ballast load. In response, DOE received many
comments suggesting performance measurements of a lamp-and-ballast
system will provide more realistic data than a resistor and ballast
system while still reducing measurement variation compared to the
existing method. These
[[Page 71574]]
comments are discussed in additional detail in section III.C.2.
Discussed in the following paragraphs are comments DOE received on the
proposed transfer equations, the ballasts selected for testing, and
ballasts that do not operate resistors.
NEMA commented that it supports the BE method but prefers the
ballast to be paired with reference lamps rather than precision
resistors. NEMA and Osram Sylvania (OSI) commented that the ballast
needs to be paired with a resistor matched to the ballast factor of the
ballast for it to operate at its design point. A test procedure that
requires multiple ballast factor specific resistors would be very
expensive considering each resistive load bank costs 1000 to 2000
dollars and is only available on a custom order basis. (NEMA, No. 15 at
p. 5, 11; NEMA, Public Meeting Transcript, No. 12 at p. 21-22, 38-39,
105; OSI, Public Meeting Transcript, No. 12 at p. 80)
DOE agrees that specifying multiple ballast-factor specific
resistors would be burdensome and that the actual performance of a
ballast is better measured while it is operating the natural lamp load.
In this SNOPR, DOE proposes a procedure which is applicable to all
ballasts and uses lamp loads in the measurement of ballast luminous
efficiency.
DOE also received several comments in response to its proposed
transfer equations between BE and BEF. The Northwest Energy Efficiency
Alliance and the Northwest Power Conservation Council (NEEA and NPCC)
commented that the transfer equations between BE and BEF may be error
prone and may not attribute the correct BEF to a ballast. (NEEA & NPCC,
Public Meeting Transcript, No. 12 at p. 86-87, 89, 167-168; NEEA &
NPCC, No. 16 at p. 4-5) NEMA commented that a lighting designer might
prefer BE to be correlated to BEF in order to compare lighting
efficacy. NEMA also added that it does not believe small errors in the
transfer equation to be an issue, because lighting designers do not
require as high a level of accuracy when specifying a system. (NEMA,
No. 15 at p. 9) Philips commented that the approach with the transfer
equations is essentially to average the BEF values at a particular BE
value and to plot a line through these points. Philips noted that the
average BEF helps to account for the wide variation in BEF values.
(Philips, Public Meeting Transcript, No. 12 at p. 87-91) Philips also
indicated general agreement with the transfer equations for the
ballasts that operate four foot medium bipin lamps. (Philips, Public
Meeting Transcript, No. 12 at p. 94-95) OSI commented that the test
data used to develop the transfer equations could bias the results if
the BEF or BE values happened to test on the high or low end of the
expected distribution of data. (OSI, Public Meeting Transcript, No. 12
at p. 166-167) NEMA commented that a percentage shift in the transfer
equation between BE and BEF based on ballast factor would not
necessarily be the same for all ballast types. In addition, NEMA
commented that instant start ballasts should generally be more
efficient than programmed start ballasts and the transfer equations
should be consistent with this difference. (NEMA, Public Meeting
Transcript, No. 12 at p. 21, 25-26) DOE appreciates the comments on the
transfer equations. Because DOE is proposing a test procedure for BLE
without correlation to another metric, however, DOE does not need to
develop transfer equations or scaling relationships between equations.
In response to the test data presented in the fluorescent lamp
ballast standards rulemaking, NEEA and NPCC commented that they
understood DOE tested only normal BF ballasts and used scaling
relationships to derive the BE and BEF for the high and low BF
ballasts. (NEEA & NPCC, No. 32 at p. 4) DOE did test ballasts of all
ballast factors, including low and high BF models. However, DOE tested
low and high BF models using a resistor load that corresponded to a
lamp driven by a normal BF ballast in an effort to reduce the inventory
of resistors required for testing and reduce measurement burden.
Because the ballast operates differently when attached to a resistor
that does not properly match the ballasts' impedance, DOE developed
separate transfer equations to correlate BE to BEF for different bins
of BF (high, normal, and low \6\). In this SNOPR, however, DOE is
proposing a test procedure based on a lamp-and-ballast system that does
not employ resistive loads.
---------------------------------------------------------------------------
\6\ High ballast factor: BF >= 1.10; Normal ballast factor: 0.78
> BF > 1.10; Low ballast factor: BF <= 0.78.
---------------------------------------------------------------------------
In its testing for development of the resistor-based BE test method
for the NOPR, DOE observed that some ballasts did not operate
resistors. NEMA commented that its round robin testing for its own
investigation of the resistor-based BE test procedure showed that some
ballasts do not start or operate correctly with resistor loads. NEMA
commented that in some cases, the ballast senses the resistor is a non-
lamp load and will shut down or fail to start entirely. Some labs
overcome this issue by starting the ballast without this resistive load
connected and then introducing the resistor after a short time (as
short as 500 milliseconds). This setup can require program controllers
which add parasitic capacitance and inductance. (NEMA, No. 15 at p. 5,
8) NEMA and General Electric (GE) also commented that the issue of some
ballasts not operating resistors can be resolved by changing the
procedure to involve lamp loads rather than resistors. NEMA noted that
ballasts are designed to operate lamps, not resistors, and that using a
lamp load will ensure a ballast starts and operates properly. (NEMA,
Public Meeting Transcript, No. 12 at p. 39, 96-97; GE, Public Meeting
Transcript, No. 12 at p. 97-98; NEMA, No. 15 at p. 6) Finally, the CA
Utilities commented that they did not support the use of different test
procedures for ballasts that do and do not operate resistors. (CA
Utilities, No. 13 at p. 2-3) DOE agrees that a change of test procedure
to involve lamp loads rather than resistive loads will resolve the
issue of some ballasts not operating resistors properly and will
provide a procedure applicable to all ballasts.
2. Lamp-Based Ballast Efficiency Correlated to BEF
In the NOPR, DOE considered a lamp-based BE measurement that would
then be correlated to BEF using transfer equations. DOE defined this
lamp-based BE as lamp arc power divided by ballast input power such
that cathode heating power was included in the input but not in the
output. This procedure is based largely on the BE test procedure
described in the NEMA Alternative Test Procedure Handout, available at
https://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/fl_ballast_tp_nema.pdf. In this SNOPR, DOE is proposing a
variation of lamp-based BE called ballast luminous efficiency (BLE).
BLE is equal to lamp arc power divided by input power and then
multiplied by an adjustment factor based on high- or low-frequency lamp
operation. This adjustment factor accounts for the decreased lighting
efficacy of low-frequency lamp operation. DOE references the BLE
procedure in the responses to comments that follow on the lamp-based BE
procedure, and provides more detail on the BLE procedure in section
III.D. As discussed in the following paragraphs, DOE received comments
suggesting a ballast should be tested with a lamp load (not a
resistor), as well as comments on the potential drawbacks and benefits
of the BE metric compared to BEF, a new method for the measurement of
ballast factor, and the
[[Page 71575]]
validity of the lamp-based BE procedure for ballasts other than
instant- and programmed-start ballasts with full cathode cutout.
DOE received several comments suggesting that BE is better measured
with a lamp-and-ballast system rather than a resistor and ballast
system. NEMA commented in the NOPR public meeting that it supports the
adoption of the lamp-based BE test procedure. NEMA commented that the
lamp-based BE procedure is simple, repeatable (testing variation of
2.5 percent), and can be used to generate a stand-alone BE
value or combined with a transfer equation to calculate BEF. NEMA also
indicated that the procedure provides a clear description of ballast
performance while minimizing the effects of reference lamps on the
ballast and lamp system. (NEMA, No. 15 at p. 2, 7, 14; NEMA, Public
Meeting Transcript, No. 12 at p. 20-21, 165-166; NEMA, Public Meeting
Transcript, No. 12 at p. 38) NEMA commented that the ballast should
operate a reference lamp when lamp arc power and ballast input power
are measured. (NEMA, No. 15 at p. 14) Finally, OSI commented that
ballast design laboratories are familiar with electrical efficiency
testing, and typically make these measurements rather than photometric
measurements when designing ballasts. (OSI, Public Meeting Transcript,
No. 12 at p. 60).
NEEA and NPCC commented that they prefer the usage of fluorescent
lamps as the load for a ballast when testing for ballast efficiency
compared to the usage of resistive loads. (NEEA & NPCC, No. 16 at p. 5;
NEEA & NPCC, No. 32 at p. 4 \7\) NEMA and GE also recommended that
lamps be utilized as the load for testing the BE of a ballast. They
also noted that lamps respond to the current supplied by a ballast, are
readily available and inexpensive to procure, and provide a natural
operating load for the ballast. (NEMA, Public Meeting Transcript, No.
12 at p. 22, GE, Public Meeting Transcript, No. 12 at p. 103; NEMA, No.
15 at p. 6-7) Philips agreed that the ballast should operate a lamp for
the measurement of BE. (Philips, Public Meeting Transcript, No. 12 at
p. 39) NEMA also commented that by correctly matching the lamp
impedance to the ballast, the maximum power transfer from the ballast
to the lamp occurs and the ballast operates at its design point and
design efficiency. (NEMA, No. 15 at p. 6) Reference lamps are
standardized and well characterized and can be procured from any lamp
manufacturer. (NEMA, No. 15 at p. 6) Philips and GE commented that the
lamp load should be a reference lamp to keep the ballast near its
designed operating point. The reference lamp provides a common
electrical operating point. (Philips, Public Meeting Transcript, No. 12
at p. 64; GE, Public Meeting Transcript, No. 12 at p. 63, 80) The CA
Utilities agreed, commenting that if DOE adopts a BE based test
procedure, it should use reference lamps as the ballast load. (CA
Utilities, No. 13 at p. 2)
---------------------------------------------------------------------------
\7\ This written comment was submitted to the docket of the
fluorescent lamp ballast standards rulemaking [Docket No. EERE-2007-
BT-STD-0016; RIN 1904-AB50].
---------------------------------------------------------------------------
DOE agrees that electrical measurements of ballast performance are
more realistic while the ballast is operating a lamp load compared to a
purely resistive load. Though a resistive load provides a constant and
repeatable operating point, a precision resistor is more expensive than
a lamp, does not change impedance in response to ballasts of different
ballast factor, and does not always provide the proper operating point
for the ballast. DOE also understands that electrical measurements are
commonly used in ballast design labs to ascertain performance. In this
SNOPR, DOE is proposing ballast performance measurements based on a
reference lamp-and-ballast system as the new test procedure for
fluorescent lamp ballasts based on the NEMA Test Procedure Handout and
comments from Philips and GE.
Philips and GE also commented that BE would be a more appropriate
metric than BEF, because BE is a metric that allows for the comparison
of all ballast systems, including different numbers of lamps or lamp
type, using a common basis for the metric. (Philips, Public Meeting
Transcript, No. 12 at p. 71; GE, Public Meeting Transcript, No. 12 at
p. 74) GE also commented that BE is a useful metric for original
equipment manufacturers when deciding which products to combine into
their lighting systems. (GE, Public Meeting Transcript, No. 12 at p.
74-75) NEEA and NPCC commented, however, that a lighting designer may
be more interested in meeting a lumen per unit area requirement than
achieving a one or two percent difference in ballast efficiency. (NEEA
& NPCC, Public Meeting Transcript, No. 12 at p. 73) NEEA and NPCC
commented that ballasts are not useful except as part of a lighting
system, suggesting that for a lighting product, lighting output per
unit power input is the metric that matters. Because ballasts of
increased electrical efficiency do not always produce the same amount
of light, NEEA and NPCC gave first preference to an improved light-
output-based test procedure, followed by a lamp-based BE metric without
correlation to BEF, and finally the resistor-based BE test procedure
with multiple ballast-factor specific resistors specified for each
lamp. NEEA and NPCC also commented that lamp operating frequency has a
large impact on light output. (NEEA & NPCC, No. 16 at p. 2, 5) In its
written comments, NEMA stated that BEF could be calculated from BE
using the reference arc power listed in ANSI C78.81-2010. NEMA also
noted that its method of correlating BE to BEF would allow
manufacturers to express the performance of the ballast in terms of BEF
to engineers and lighting consultants while still using an electrical
measurement for indicating compliance with energy conservation
standards. (NEMA, No. 15 at p. 9)
The CA Utilities commented that the existing test procedure is more
appropriate than the lamp-based BE measurement because it measures the
two most important parameters to ballast consumers: Input power and
light output. The CA Utilities commented that ballasts with the same BE
may produce more or less light from the same lamp depending on the
frequency at which they operate the lamp. Furthermore, the CA Utilities
commented that for high-frequency ballasts, variations in frequency,
crest factor, and wave shape can affect lamp efficacy. However, if DOE
proposes a BE test procedure, the CA Utilities commented that they
encourage DOE to keep the standards in terms of BE and not correlate to
BEF. (CA Utilities, No. 13 at p. 1-3)
DOE believes BLE is the best metric for assessing the performance
of a ballast. BLE provides for wide comparability among all types of
ballasts and can distinguish between the efficacy of high- and low-
frequency lamp operation. For ballast customers who prefer the BEF
metric, DOE agrees that manufacturers could provide a BEF value
calculated from the BLE measurement using the technique suggested by
NEMA. As explained in the paragraphs that follow, DOE proposes a
modification to the measurement of BE (resulting in the BLE metric) in
this SNOPR to address the concerns of the CA Utilities and NEEA and
NPCC on the impact of lamp operating frequency on light output. More
detail on the BLE metric proposed in this SNOPR is provided in section
III.D.
To account for the change in lighting efficacy as a result of lamp
operating frequency, DOE has developed a modification to the metric
measured in
[[Page 71576]]
the NEMA Alternative Test Procedure Handout that DOE calls BLE. Under
this metric, the lamp arc power for ballasts that operate lamps at low
frequency will be multiplied by 0.9. This adjustment factor compensates
for the reduced lamp efficacy that results from low-frequency
operation. Figure III.1 shows lamp efficacy increases with increased
operating frequency up to about 20 kHz, after which, lamp efficacy is
close to constant.\8\ DOE believes it is reasonable to assume a fixed
adjustment factor for all high-frequency ballasts, as most high-
frequency ballasts operate at greater than 20 kHz. DOE believes the
impact of lamp current crest factor (LCCF) and waveform to have a
minimal impact on efficacy compared to the difference between low and
high frequency operation. Lamp current crest factor is limited by ANSI
standards and does not affect lamp efficacy significantly. DOE also
believes the difference in waveform has a minimal impact on lamp
efficacy because the limitations on lamp current crest factor and power
factor constrain the variety of waveforms present in the market. DOE
seeks comment and data on the impact of LCCF and waveform on lamp
efficacy and on its decision to adjust BLE for low-frequency ballasts
by a factor of 0.9.
---------------------------------------------------------------------------
\8\ Rea, Mark S., ed. The IESNA Lighting Handbook: Reference &
Application, 9th Edition. 2000. The Illuminating Engineering Society
of America: New York, New York.
[GRAPHIC] [TIFF OMITTED] TP24NO10.375
DOE received comment that the term ballast efficiency already has
an accepted meaning in industry. NEMA commented that ballast efficiency
can be defined as a purely electrical measurement that documents the
true efficiency of a ballast by dividing total ballast output power by
ballast input power. NEMA commented that ballast efficiency by itself
does not account for the reduced system efficiency associated with
ballasts that employ cathode heating and suggested measuring a metric
defined as lamp arc power divided by ballast input power. (NEMA, No. 15
at p. 15; Philips, Public Meeting Transcript, No. 12 at p. 71-72)
Philips commented that while cathode heating does increase lamp column
efficacy, it does not offset the added energy required to heat the lamp
electrodes. (Philips, Public Meeting Transcript, No. 12 at p. 44-46) In
the NOPR, DOE defined ballast efficiency as lamp arc power divided by
ballast input power, but in the SNOPR, DOE is proposing the metric
ballast luminous efficiency (BLE), which is defined as lamp arc power
divided by ballast input power multiplied by an adjustment factor for
low-frequency operation. The alternative nomenclature BLE also
indicates that the metric is slightly different than a true ballast
efficiency measurement. DOE believes the BLE procedure accurately
accounts for the diminished system efficacy associated with lamp
cathode heating by only including lamp arc power (not cathode heating)
in the ballast output measurement.
GE and NEMA commented that the impact of lamp to lamp variation is
minimized with the lamp-based BE test procedure because variations in
lamp measured power will impact ballast input power and ballast output
power in such a way that the ratio of ballast efficiency is mostly
unaffected. (GE, Public Meeting Transcript, No. 12 at p. 62-63; NEMA,
No. 15 at p. 6) DOE agrees that the metric of lamp arc power divided by
ballast input power is mostly unaffected by lamp to lamp variation.
Because variations in lamp power affect both the numerator and
denominator, the calculation of BE (as defined in the NOPR) or BLE (as
defined in this SNOPR) minimizes the impact. This is in contrast to the
existing light-output based test procedure where variations in lamp
measured power have significant impact on ballast input power but not
relative light output.
NEMA commented that the lamp-based BE measurement would be
preferable to the resistor-based BE measurement proposed in the NOPR
because it would allow for measurement of ballast performance at steady
state. The resistor-based BE method involves measurement of ballast
performance within one minute of energizing the ballast, and the
resistor then needs to rest for one minute so that an increase in
temperature would not impact its resistance. NEMA commented that unlike
resistors, lamps do not have a duty cycle requirement necessitating
them to be run for long periods of time without deviation from the
desired operating point. (NEMA, No. 15 at p. 6) GE commented that the
lamp-based BE test procedure measures ballast performance at steady-
state, in contrast to the resistor-based test procedure proposed in the
NOPR. NEMA and GE
[[Page 71577]]
commented that certain ballast components such as magnetics and diodes
operate at higher efficiency once they have reached a steady state
temperature. Testing at steady state therefore captures the in-practice
performance of a ballast. (GE, Public Meeting Transcript, No. 12 at p.
82-83; NEMA, No. 15 at p. 6) Philips agreed that measurement of the
ballast performance is more realistic at steady state than within one
minute of energizing. (Philips, Public Meeting Transcript, No. 12 at p.
163)
DOE agrees that the lamp-based BE test procedure is simpler and
more representative of ballast performance than the resistor-based
method. Because a lamp does not have a short duty cycle, the lamp-and-
ballast system can be operated for a long enough time to reach steady
state and the ballast measurement can be representative of typical
operation. In this SNOPR, DOE is proposing a BLE test procedure in
which, like the BE method, the performance of a ballast is measured at
steady state while operating a lamp load.
The lamp-based BE test procedure would define particular lamp and
ballasts pairings for testing ballast performance. In its written
comments, NEMA recommended that instant-start ballasts and programmed-
rapid-start ballasts with cathode cut-out should be tested with a full
wattage load. (NEMA, No. 15 at p. 6-7) In this SNOPR, DOE is proposing
to pair ballasts with the most common wattage lamp for testing purposes
(see section III.D.2 for additional detail). In the case of instant-
start ballasts and programmed-rapid-start ballasts (with or without
full cathode cut-out), DOE is proposing that these ballasts operate
full-wattage lamps which are also the most common wattage in these
groupings. Some ballasts, such as rapid start T12 ballasts, are paired
with reduced wattage or energy saver lamps as this will be the most
common pairing. The proposal for lamp-and-ballast pairing in this SNOPR
is the same as discussed in the test procedure NOPR.
GE also commented on the transfer equations for BE to BEF, stating
that fitting a line of best fit to tested BEF and BE data would be a
reasonable method of developing a transfer equation between the two
metrics. (GE, Public Meeting Transcript, No. 12 at p. 64-65) GE
commented that separate empirically derived transfer equations would
likely be needed for ballasts that either employ or do not employ
cathode heating. (GE, Public Meeting Transcript, No. 12 at p. 65-66) At
the NOPR public meeting, Philips commented that it developed
correlations between BE and BEF for instant start ballasts and ballasts
with cathode cutout when using the lamp-based BE test procedure.
(Philips, Public Meeting Transcript, No. 12 at p. 36) NEMA commented
that separate transfer equations for ballasts of different ballast
factor would be unnecessary with a lamp-based BE test procedure. (NEMA,
No. 15 at p. 6) The CA Utilities commented that they did not agree with
using the same transfer equations for converting BE to BEF for high and
low frequency ballasts because of the change in lamp efficacy. A high-
and low-frequency ballast with the same BE would not have the same BEF.
(CA Utilities, No. 13 at p. 2) In its written comments, NEMA stated
that BEF could be calculated from BE using the reference arc power
listed in ANSI C78.81-2010 \9\. NEMA suggested multiplying BE by 100,
dividing by number of lamps, and dividing by the ANSI reference lamp
arc power. Philips commented that this technique is based on the
assumption that light output is directly proportional to arc power for
all ballast types over the ballast factor range from 0.75 to 1.15. NEMA
provided test data that supports this claim. NEMA also commented that
the calculation favors ballasts with less cathode heating, which is
consistent with the goal of promoting energy efficient systems. (NEMA,
No. 29 at p. 3; NEMA, No. 15 at p. 15-16; Philips, Public Meeting
Transcript, No. 12 at p. 51-53)
---------------------------------------------------------------------------
\9\ American National Standard for Electric Lamps--Double-Capped
Fluorescent Lamps--Dimensional and Electrical Characteristics,
Approved January 14, 2010.
---------------------------------------------------------------------------
In the SNOPR, DOE is proposing to measure BLE directly without
correlation to another metric. To convert the existing standards from
BEF to BLE, however, DOE used the NEMA suggested calculation (rather
than empirical correlations) to convert the existing BEF energy
conservation standards to BLE standards. DOE used different conversion
equations to assign the associated BLE for high- or low-frequency
ballasts, in agreement with the CA Utilities' comment.
To convert from BEF to BLE, DOE multiplied the BEF values by the
corresponding reference lamp arc power listed in Table III.2 and the
number of lamps operated by the ballast. As described in section
III.D.4, these reference arc powers originate from ANSI C78.81-2010 or
IEC 60081 Ed 5.0, the results of empirical analysis performed by DOE,
or scaling from a similar lamp type (as described in the next
paragraph). For example, for ballasts that operate two F34T12 lamps,
DOE multiplied 1.35 (BEF) by two (number of lamps) and 29.81 (high-
frequency reference lamp arc power based on empirical testing) which
resulted in a BLE of 80.5%. To convert the same BEF to a low-frequency
equivalent BLE, DOE multiplied 1.35 by two (number of lamps), 32 (low-
frequency reference lamp arc power), and 0.9 (lamp operating frequency
adjustment factor) which resulted in a BLE of 77.8%. Table III.1 lists
the existing standards and their corresponding values in BLE using the
methodology described in this paragraph.
DOE did not have high-frequency ANSI reference specifications or
empirical data for F40T12 or F96T12 lamps. To estimate high-frequency
lamp arc powers for the F40T12 lamp, DOE scaled the low-frequency ANSI-
based F40T12 reference power using the ratio of high-frequency to low-
frequency reference powers for the F34T12 lamp. For the F96T12 lamp,
DOE used the same methodology using the ratio of high- to low-frequency
reference power for the F96T12/ES lamp to scale the low-frequency ANSI-
based F96T12 reference power to high-frequency.
Table III.1--Existing BEF Standards and Corresponding BLE Conversion
----------------------------------------------------------------------------------------------------------------
Ballast Total Ballast
Ballasts that operate: input nominal efficacy BLE Low- BLE High-
voltage lamp watts factor frequency frequency
----------------------------------------------------------------------------------------------------------------
One F40T12 lamp..................................... 120/277 40 2.29 80.4 83.2
Two F40T12 lamps.................................... 120/277 80 1.17 82.1 85.0
Two F96T12 lamps.................................... 120/277 150 0.63 85.1 89.7
Two F96T12HO lamps.................................. 120/277 220 0.39 74.4 78.0
One F34T12 lamp..................................... 120/277 34 2.61 75.2 77.8
[[Page 71578]]
Two F34T12 lamps.................................... 120/277 68 1.35 77.8 80.5
Two F96T12/ES lamps................................. 120/277 120 0.77 83.9 88.4
Two F96T12/HO/ES lamps.............................. 120/277 190 0.42 68.0 71.3
----------------------------------------------------------------------------------------------------------------
While DOE is proposing the BLE metric in this SNOPR, DOE also
proposes a method for calculating ballast factor of a ballast by
dividing the measured lamp arc power on the test ballast by the
measured lamp arc power on a reference ballast. In some cases, when
reference ballast operating conditions are unavailable, the SNOPR
provides a reference lamp power from an ANSI standard or from empirical
results. As described in the preliminary analysis of the fluorescent
lamp ballast standards rulemaking, DOE is considering categorizing
ballasts into different groups (product classes) based on ballast
factor. These product classes could then be subject to different energy
conservation standards. DOE could use the ballast factor measurement in
this test procedure to assign a ballast to a particular product class.
See section III.D.4 for additional detail on the ballast factor
calculation.
In commenting on the lamp-based BE procedure, which is similar to
the suggested lamp-based BE test procedure outlined in the NEMA
Alternative Test Procedure Handout, Philips indicated that the NEMA
procedure was only valid for instant-start ballasts and programmed-
start ballasts with full cathode cutout. Philips stated that NEMA had
not completed enough due diligence for ballasts with cathode heating to
make a proposal. Philips indicated that the existing light output based
procedure could be used for ballasts without cathode heating. Philips
also commented that DOE could make the assumption in the test procedure
to include cathode heating as ballast losses and account for this
difference in the energy conservation standard. (Philips, Public
Meeting Transcript, No. 12 at p. 36, 38, 47, 65, 71-72) Then, in
written comments, NEMA provided supplemental information suggesting a
modification to the test setup to support ballasts that employ cathode
heating. NEMA indicated that two 1,000 ohm resistors should be placed
in parallel with both sets of lamp pins, generating a midpoint from
which to measure the lamp discharge voltage. NEMA also noted that the
resistors are of high enough impedance not to affect the lamp operating
characteristics and low enough impedance not to affect the measurement
system. (NEMA, No. 15 at p. 7) In response to the original NEMA
proposal that was applicable only to ballasts without cathode heating,
NEEA and NPCC commented that they do not support a test procedure that
is only applicable to certain ballasts. (NEEA & NPCC, No. 16 at p. 3-4)
NEEA and NPCC commented that the existing test procedure for BEF
applies equally well to all ballast types, which is not the case for
the lamp-based BE alternative, the NOPR resistor-based BE proposal, or
the procedure as outlined in the NEMA Alternative Test Procedure
Handout. GE commented that the use of more than one test procedure for
ballasts subject to the same energy conservation standard was not
desirable. (GE, Public Meeting Transcript, No. 12 at p. 97-98)
DOE agrees that the test procedure for fluorescent lamp ballasts
should be applicable to all ballasts subject to the same standards. DOE
believes that the test setup with resistors in parallel with the lamp
pins would allow for repeatable BE measurements, as well as BLE
measurements, for rapid- and programmed-start ballast regardless of the
level of cathode heating. Rather than require the ballast to be tested
to determine the level of cathode heating, DOE would use the voltage
divider for all rapid- and programmed-start ballasts. The voltage
divider would provide a position in the circuit to measure the lamp arc
voltage assuming the arc begins near the center of the ballast. This is
in contrast to a setup without the divider when lamp arc voltage would
vary depending on the position of the hotspot on each electrode. As a
result, DOE believes that NEMA's suggested test setup augments the BE
procedure, and the proposed BLE procedure, such that both procedures
are applicable to all ballasts.
3. Improved Light-Output-Based Test Procedure
In the NOPR, DOE considered improving the existing light-output
based test procedure to reduce measurement variation. The measurement
variation in the existing procedure can be attributed to operating
conditions, variation in measured power of reference lamps,
inconsistent output power measurements in determining ballast factor,
and ambient temperature. DOE invited comment on the clarified
methodologies and tighter tolerances for temperature and reference lamp
measured power.
The CA Utilities commented that they supported the improvements to
the existing test procedure presented in the NOPR to reduce measurement
variation, including tightening reference lamp tolerance, requiring
uniform operating conditions, taking measurements at constant voltage
(consistent with the general service fluorescent lamps test procedure
listed in 10 CFR part 430 appendix R to subpart B), using only one
approach for calculating BF, and testing universal voltage commercial
ballasts at 277V and residential universal voltage ballasts at 120V.
(CA Utilities, No. 13 at p. 2) NEEA and NPCC also supported the
improvements to the existing test procedure with the exception of the
ambient temperature specification, which they believed would be
extraordinarily costly. NEEA and NPCC preferred the improved light-
output-based method to all other test procedure proposals. (NEEA &
NPCC, No. 16 at p. 1-3) NEEA and NPCC also commented that DOE should
test the proposed changes with a large sample size so that statistics
such as standard deviation can be computed. NEEA and NPCC commented
that this data is needed to judge the existing test procedure against
the proposed amendment and alternatives. (NEEA & NPCC, No. 16 at p. 3)
General Electric (GE), Philips, and NEMA agreed that controlling a
photometric laboratory to 25 [deg]C 0.5 [deg]C is a
significant undertaking and would require upgrades of the air
conditioning and air handling controls and could require some
specialized equipment. (GE, Public Meeting Transcript, No. 12 at p. 59,
105; Philips, Public Meeting Transcript, No. 12 at p. 60-61; NEMA, No.
15 at p. 7) Philips and NEMA also commented that decreasing the
tolerance on reference lamps would significantly increase the burden in
identifying reference lamps compared to the already difficult process
of meeting
[[Page 71579]]
the current specification. (Philips, Public Meeting Transcript, No. 12
at p. 60-61; NEMA, No. 15 at p. 7-8) NEEA and NPCC disagreed with NEMA
on the issue of reference lamp variation, commenting that while the
process of identifying reference lamps is tedious, they did not see any
reason why this technique introduced unmanageable variation into the
test process. (NEEA & NPCC, No. 16 at p. 2) GE commented that the BEF
metric is based heavily on the input power to the ballast. However, a
vast majority of the input power is dependent on the lamp, and the
ballast manufacturer has no control over this lamp power. As a result,
input power and BEF will vary in response to the measured power of the
lamp, potentially making high performance ballasts look less efficient.
Furthermore, the BEF test procedure, as defined, contains some latitude
that permits variation between test laboratories. (GE, Public Meeting
Transcript, No. 12 at p. 35-36)
DOE agrees that a tighter tolerance on ambient temperature would be
more burdensome to manufacturers, though it would decrease measurement
variation. DOE also believes that tightening the tolerance on reference
lamp measured power would increase the burden for lamp identification
because fewer lamps would meet the more stringent specification. While
DOE agrees with NEEA and NPCC that the process of identifying reference
lamps can be accurately carried out at any test laboratory, because a
reference lamp can vary in measured power up to plus or minus 2.5% of
the rated lamp power (existing requirements) or up to 1% in the
improved light output based test procedure, the permitted variation in
measured power introduces variation into the BEF metric. The same
ballast paired with reference lamps of different measured power will
measure different ballast input power, impacting the value of BEF. All
other procedural improvements and clarifications including requiring
uniform operating conditions, taking measurements at constant voltage,
using only one approach for calculating BF, and testing universal
voltage commercial ballasts at 277V and residential universal voltage
ballasts and cold-temperature sign ballasts at 120V would reduce
testing variation without appreciably increasing testing burden. DOE
does not plan to investigate the improved light output based test
procedure through testing because it believes BLE to be a better metric
and test procedure. DOE believes its proposal of BLE is less burdensome
than an improved light-output based method, potentially reduces
measurement variation to a greater extent, and generates a
straightforward descriptor of electrical losses. The BLE measurement
and calculation also minimize the impact of lamp measured power
variation. Therefore, DOE believes there is minimal benefit to
requiring a tighter tolerance on reference lamp power variation in the
context of the proposed test procedure.
Because discrepancies may exist in BEF test data from different
sources, NEEA and NPCC suggested that any changes to the existing test
procedure should place ballasts both above and below the mean values,
not systematically generate tested performance above the mean. (NEEA &
NPCC, No. 16 at p. 6) GE commented that the discrepancies in data could
signify a compliance problem and that manufacturers should notify DOE
of observed instances of non-compliance. GE also indicated that
manufacturers may shop around at different laboratories to find an
improvement in ratings. (GE, Public Meeting Transcript, No. 12 at p.
35, 172-173) Philips commented th
