[Federal Register Volume 84, Number 204 (Tuesday, October 22, 2019)]
[Proposed Rules]
[Pages 56540-56587]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-22537]
[[Page 56539]]
Vol. 84
Tuesday,
No. 204
October 22, 2019
Part II
Department of Energy
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10 CFR Part 430
Energy Conservation Program: Energy Conservation Standards for
Fluorescent Lamp Ballasts; Proposed Rule
Federal Register / Vol. 84, No. 204 / Tuesday, October 22, 2019 /
Proposed Rules
[[Page 56540]]
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DEPARTMENT OF ENERGY
10 CFR Part 430
[EERE-2015-BT-STD-0006]
RIN 1905-AD51
Energy Conservation Program: Energy Conservation Standards for
Fluorescent Lamp Ballasts
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of proposed determination and request for comment.
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SUMMARY: The Energy Policy and Conservation Act of 1975, as amended
(EPCA), prescribes energy conservation standards for various consumer
products and certain commercial and industrial equipment, including
fluorescent lamp ballasts. EPCA also requires the U.S. Department of
Energy (DOE) to periodically determine whether more-stringent, amended
standards would be technologically feasible and economically justified,
and would result in significant energy savings. In this notice of
proposed determination (NOPD), DOE has initially determined that energy
conservation standards for fluorescent lamp ballasts do not need to be
amended and also asks for comment on this proposed determination and
associated analyses and results.
DATES:
Meeting: DOE will hold a webinar on Wednesday, October 30, 2019,
from 10:00 a.m. to 3:00 p.m. See section V, ``Public Participation,''
for webinar registration information, participant instructions, and
information about the capabilities available to webinar participants.
If no participants register for the webinar than it will be cancelled.
DOE will hold a public meeting on this proposed determination if one is
requested by November 5, 2019.
Comments: Written comments and information are requested and will
be accepted on or before December 23, 2019.
ADDRESSES: Interested persons are encouraged to submit comments using
the Federal eRulemaking Portal at http://www.regulations.gov. Follow
the instructions for submitting comments. Alternatively, interested
persons may submit comments, identified by docket number EERE-2015-BT-
STD-0006, by any of the following methods:
(1) Federal eRulemaking Portal: http://www.regulations.gov. Follow
the instructions for submitting comments.
(2) Email: [email protected]. Include the
docket number EERE-2015-BT-STD-0006 in the subject line of the message.
(3) Postal Mail: Appliance and Equipment Standards Program, U.S.
Department of Energy, Building Technologies Office, Mailstop EE-5B,
1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone:
(202) 287-1445. If possible, please submit all items on a compact disc
(``CD''), in which case it is not necessary to include printed copies.
(4) Hand Delivery/Courier: Appliance and Equipment Standards
Program, U.S. Department of Energy, Building Technologies Office, 950
L'Enfant Plaza SW, 6th Floor, Washington, DC 20024. Telephone: (202)
287-1445. If possible, please submit all items on a CD, in which case
it is not necessary to include printed copies.
No telefacsimiles (faxes) will be accepted. For detailed
instructions on submitting comments and additional information on this
process, see section VII of this document.
Docket: The docket, which includes Federal Register notices, public
meeting attendee lists and transcripts, comments, and other supporting
documents/materials, is available for review at http://www.regulations.gov. All documents in the docket are listed in the
http://www.regulations.gov index. However, not all documents listed in
the index may be publicly available, such as information that is exempt
from public disclosure.
The docket web page can be found at https://www.regulations.gov/document?D=EERE-2015-BT-STD-0006. The docket web page contains
instructions on how to access all documents, including public comments,
in the docket. See section VII, ``Public Participation,'' for further
information on how to submit comments through http://www.regulations.gov.
FOR FURTHER INFORMATION CONTACT:
Ms. Lucy deButts, U.S. Department of Energy, Office of Energy
Efficiency and Renewable Energy, Building Technologies Office, EE-5B,
1000 Independence Avenue SW, Washington, DC 20585-0121. Email:
[email protected].
Ms. Sarah Butler, U.S. Department of Energy, Office of the General
Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC 20585-0121.
Telephone: (202) 586-1777. Email: [email protected].
For further information on how to submit a comment or review other
public comments and the docket contact the Appliance and Equipment
Standards Program staff at (202) 287-1445 or by email:
[email protected].
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Synopsis of the Proposed Determination
II. Introduction
A. Authority and Background
1. Current Standards
2. History of Standards Rulemakings for Fluorescent Lamp
Ballasts
III. General Discussion
A. Product Classes and Scope of Coverage
B. Test Procedure
C. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
D. Energy Savings
1. Determination of Savings
2. Significance of Savings
E. Cost Effectiveness
F. Other Analyses
IV. Methodology and Discussion of Related Comments
A. Market and Technology Assessment
1. Scope of Coverage and Product Classes
a. Dimming Ballasts
b. Ballasts Operating at 480 V
c. Low-Current PS Ballasts
d. Low Frequency EMI Ballasts
2. Metric
a. Active Mode Energy Consumption
b. Standby Mode Energy Consumption
3. Technology Options
4. Screening Analysis
a. Screened-Out Technologies
b. Remaining Technologies
5. Product Classes
a. Existing Product Classes
b. Additional Product Classes
c. Summary
B. Engineering Analysis
1. Significant Data Sources
2. Representative Product Classes
3. Baseline Ballasts
4. More-Efficient Substitutes
5. Efficiency Levels
6. Scaling to Other Product Classes
7. Proprietary Designs
C. Product Price Determination
D. Energy Use Analysis
1. Reduced Wattage Fluorescent Lamps
2. Occupancy Sensors
3. Dimming Ballasts
4. Tubular LEDs
E. Life-Cycle Cost and Payback Period Analysis
1. Product Cost
2. Installation Cost
3. Annual Energy Consumption
4. Energy Prices
5. Maintenance and Repair Costs
6. Product Lifetime
7. Discount Rates
8. Energy Efficiency Distribution in the No-New-Standards Case
9. Payback Period Analysis
F. Shipments Analysis
1. Shipment Scenarios Modeled
2. Dimming Ballasts
3. Tubular LEDs
G. National Impact Analysis
[[Page 56541]]
1. Product Efficiency Trends
2. National Energy Savings
3. Net Present Value Analysis
H. Manufacturer Impact Analysis
1. Manufacturer Production Costs
2. Shipments Projections
3. Product and Capital Conversion Costs
4. Markup Scenarios
5. Manufacturer Interviews
a. Shift to Solid-State Lighting
b. Limited Investment in Fluorescent Lamp Ballasts
6. Discussion of MIA Comments
V. Analytical Results and Conclusions
A. Economic Impacts on Individual Consumers
1. Life-Cycle Cost and Payback Period
2. Rebuttable Presumption Payback
B. National Impact Analysis
1. Significance of Energy Savings
2. Net Present Value of Consumer Costs and Benefits
C. Economic Impacts on Manufacturers
1. Industry Cash Flow Analysis Results
2. Direct Impacts on Employment
3. Impacts on Manufacturing Capacity
4. Impacts on Subgroups of Manufacturers
5. Cumulative Regulatory Burden
D. Proposed Determination
1. Technological Feasibility
2. Cost Effectiveness
3. Significant Conservation of Energy
4. Other Analysis
5. Summary
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Order 12866
B. Review Under Executive Orders 13771 and 13777
C. Review Under the Regulatory Flexibility Act
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government
Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government
Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Information Quality
VII. Public Participation
A. Participation in the Webinar
B. Submission of Comments
C. Issues on Which DOE Seeks Comment
VIII. Approval of the Office of the Secretary
I. Synopsis of the Proposed Determination
Title III, Part B \1\ of the Energy Policy and Conservation Act of
1975, as amended (EPCA),\2\ established the Energy Conservation Program
for Consumer Products Other Than Automobiles. (42 U.S.C. 6291-6309)
These products include fluorescent lamp ballasts, the subject of this
NOPD.
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\1\ For editorial reasons, upon codification in the U.S. Code,
Part B was redesignated Part A.
\2\ All references to EPCA in this document refer to the statute
as amended through America's Water Infrastructure Act of 2018,
Public Law 115-270 (October 23, 2018).
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DOE is issuing this NOPD pursuant to the EPCA requirement that not
later than 6 years after issuance of any final rule establishing or
amending an energy conservation standard for a covered product, DOE
must publish either a notice of determination indicating that standards
for the product do not need to be amended, or a notice of proposed
rulemaking (NOPR) including new proposed energy conservation standards.
(42 U.S.C. 6295(m)(1)(A) and (B))
For this proposed determination, DOE analyzed fluorescent lamp
ballasts subject to standards specified in 10 CFR 430.32(m). In
addition, DOE evaluated whether current standards should be extended to
additional fluorescent lamp ballasts. Specifically, DOE considered
standards for dimming ballasts and 4-foot T8 medium bipin (MBP)
programmed start (PS) ballasts with an average current less than 140 mA
(hereafter low-current PS ballasts). Hence, potential amended energy
conservation standards in this NOPD refer not only to changes to
existing standards but also extension of standards to additional
fluorescent lamp ballasts.
DOE first analyzed the technological feasibility of more efficient
fluorescent lamp ballasts. For those fluorescent lamp ballasts for
which DOE determined it to be technologically feasible to have higher
standards or be subject to standards, DOE estimated energy savings that
would result from potential energy conservation standards by conducting
a national impacts analysis (NIA). DOE evaluated whether these amended
standards would be cost effective by conducting life-cycle cost (LCC)
and payback period (PBP) analyses, and estimated the net present value
(NPV) of the total costs and benefits experienced by consumers. In
addition to the consideration of these criteria, DOE conducted a
manufacturer impact analyses (MIA).
Based on the results of these analyses summarized in section V of
this document, DOE has tentatively determined that current standards
for fluorescent lamp ballasts do not need to be amended because amended
standards would not be cost effective.
II. Introduction
The following section briefly discusses the statutory authority
underlying this proposed determination, as well as some of the relevant
historical background related to the establishment of standards for
fluorescent lamp ballasts.
A. Authority and Background
Title III, Part B of EPCA includes the fluorescent lamp ballasts
that are the subject of this proposed determination. (42 U.S.C.
6292(a)(13)) EPCA prescribed energy conservation standards for these
products. (42 U.S.C. 6295(g)(5)) EPCA directed DOE to (1) conduct two
rulemaking cycles to determine whether these standards should be
amended; and (2) for each rulemaking cycle, determine whether the
standards in effect for fluorescent lamp ballasts should be amended so
that they would be applicable to additional fluorescent lamp ballasts.
(42 U.S.C. 6295(g)(7)(A) and (B)) Through amendments to EPCA under the
Energy Policy Act of 2005 (EPACT 2005), Public Law 109-58, Congress
promulgated new energy conservation standards for certain fluorescent
lamp ballasts. (EPACT section 135(c)(2); codified at 42 U.S.C.
6295(g)(8)(A))
The energy conservation program for covered products under EPCA
consists essentially of four parts: (1) Testing, (2) labeling, (3) the
establishment of Federal energy conservation standards, and (4)
certification and enforcement procedures. The Federal Trade Commission
(FTC) is primarily responsible for labeling, and DOE implements the
remainder of the program.
Subject to certain criteria and conditions, DOE is required to
develop test procedures to measure the energy efficiency, energy use,
or estimated annual operating cost of each covered product. (42 U.S.C.
6295(o)(3)(A) and (r)) Manufacturers of covered products must use the
prescribed DOE test procedure as the basis for certifying to DOE that
their products comply with the applicable energy conservation standards
adopted under EPCA and when making representations to the public
regarding the energy use or efficiency of those products. (42 U.S.C.
6293(c) and 6295(s)) Similarly, DOE must use these test procedures to
determine whether the products comply with standards adopted pursuant
to EPCA. (42 U.S.C. 6295(s)) The DOE test procedures for fluorescent
lamp ballasts appear at title 10 of the Code of Federal Regulations
(CFR) part 430, subpart B, appendix Q.
Federal energy conservation requirements generally supersede State
laws or regulations concerning energy conservation testing, labeling,
and standards. (42 U.S.C. 6297(a) through (c)) DOE may, however, grant
waivers of Federal preemption for particular State laws or regulations,
in accordance with
[[Page 56542]]
the procedures and other provisions set forth under 42 U.S.C. 6297(d)).
Pursuant to the amendments contained in the Energy Independence and
Security Act of 2007 (EISA 2007), Public Law 110-140, any final rule
for new or amended energy conservation standards promulgated after July
1, 2010, is required to address standby mode and off mode energy use.
(42 U.S.C. 6295(gg)(3)) Specifically, when DOE adopts a standard for a
covered product after that date, it must, if justified by the criteria
for adoption of standards under EPCA (42 U.S.C. 6295(o)), incorporate
standby mode and off mode energy use into a single standard, or, if
that is not feasible, adopt a separate standard for such energy use for
that product. (42 U.S.C. 6295(gg)(3)(A) and (B)) DOE's current test
procedures for fluorescent lamp ballasts address standby mode and off
mode energy use. In this analysis DOE considers such energy use in its
determination of whether energy conservation standards need to be
amended.
DOE is issuing this proposed determination pursuant to 42 U.S.C.
6295(m), which states that DOE must periodically review its already
established energy conservation standards for a covered product no
later than 6 years from the issuance of a final rule establishing or
amending a standard for a covered product. As a result of this review,
DOE must either publish a determination that standards do not need to
be amended or a NOPR, including new proposed standards (proceeding to a
final rule, as appropriate). (42 U.S.C. 6295(m)(1)) EPCA further
provides that, not later than 3 years after the issuance of a final
determination not to amend standards, DOE must make a new determination
and publish either a notice of determination that standards for the
product do not need to be amended, or a NOPR including new proposed
energy conservation standards (proceeding to a final rule, as
appropriate). (42 U.S.C. 6295(m)(3)(B)) DOE must make the analysis on
which the determination is based publicly available and provide an
opportunity for written comment. (42 U.S.C. 6295(m)(2)) A determination
that amended standards are not needed must be based on consideration of
whether amended standards will result in significant conservation of
energy, are technologically feasible, and are cost effective. (42
U.S.C. 6295(m)(1)(A) and (n)(2)) An evaluation of cost effectiveness
requires that DOE consider savings in operating costs throughout the
estimated average life of the covered products in the type (or class)
compared to any increase in the price of, or initial charges for, or
maintenance expenses of, the covered products that are likely to result
from the standard. (42 U.S.C. 6295(n)(2) and (o)(2)(B)(i)(II))
1. Current Standards
In a final rule published on November 14, 2011, DOE prescribed the
current energy conservation standards for fluorescent lamp ballasts
manufactured on and after November 14, 2014 (2011 FL Ballast Rule). 76
FR 70548. These standards require a minimum power factor of 0.9 or
greater for ballasts that are not residential ballasts or 0.5 or
greater for residential ballasts and a minimum ballast luminous
efficiency (BLE) as set forth in DOE's regulations at 10 CFR 430.32(m)
and repeated in Table II.1.
Table II.1--Federal Energy Conservation Standards for Fluorescent Lamp Ballasts
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BLE = A / (1 + B * average total lamp arc power [supcaret]-C) Where A, B, and C are as follows:
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Description A B C
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Instant start and rapid start ballasts (not classified as residential)
that are designed to operate:
4-foot medium bipin lamps, 2-foot U-shaped lamps, 8-foot slimline 0.993 0.27 0.25
lamps...............................................................
Programmed start ballasts (not classified as residential) that are
designed to operate:
4-foot medium bipin lamps, 2-foot U-shaped lamps, 4-foot miniature 0.993 0.51 0.37
bipin standard output lamps, 4-foot miniature bipin high output
lamps...............................................................
Instant start and rapid start ballasts (not classified as sign ballasts) 0.993 0.38 0.25
that are designed to operate 8-foot high output lamps...................
Programmed start ballasts (not classified as sign ballasts) that are 0.973 0.70 0.37
designed to operate 8-foot high output lamps............................
Sign ballasts that operate 8-foot high output lamps...................... 0.993 0.47 0.25
Instant start and rapid start residential ballasts that operate:
4-foot medium bipin lamps, 2-foot U-shaped lamps, 8-foot slimline 0.993 0.41 0.25
lamps...............................................................
Programmed start residential ballasts that are designed to operate:
4-foot medium bipin lamps, 2-foot U-shaped lamps..................... 0.973 0.71 0.37
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2. History of Standards Rulemakings for Fluorescent Lamp Ballasts
On September 19, 2000, DOE published a final rule in the Federal
Register, which completed the first of the two rulemaking cycles to
evaluate and amend the energy conservation standards for fluorescent
lamp ballasts (2000 FL Ballast Rule). 65 FR 56740. The rulemaking
established a standard reflecting a recommendation presented in a joint
comment submitted by members of the fluorescent lamp ballast (FLB)
industry and energy efficiency advocacy organizations. (Id.)
On October 18, 2005, DOE published a final rule in the Federal
Register codifying the new FLB standards established in EPACT 2005
section 135(c)(2) into the CFR at 10 CFR 430.32(m). 70 FR 60407. These
standards established ballast efficiency requirements for ballasts that
operate ``energy saver'' versions of full-wattage lamps, such as the
F34T12 lamp.
Following the amendments from EPACT 2005, the second rulemaking
cycle required by 42 U.S.C. 6295(g)(7) was completed with publication
of the 2011 FL Ballast Rule. 76 FR 70548. The 2011 FL Ballast Rule
changed the metric required for fluorescent lamp ballasts from ballast
efficacy factor (BEF) to ballast luminous efficiency (BLE) and set new
and amended energy conservation standards.
In support of the present review of the fluorescent lamp ballast
energy conservation standards, DOE prepared the ``Energy Conservation
Standards Rulemaking Framework Document for Fluorescent Lamp Ballasts''
(Framework Document), which describes the procedural and analytical
approaches DOE anticipated using to evaluate energy conservation
standards for fluorescent lamp ballasts. On June 23, 2015, DOE
published a notice announcing the availability of the Framework
document. 80 FR 35886. The Framework document is available
[[Page 56543]]
at https://www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=3.
DOE held a public meeting on July 17, 2015, at which it described
the various analyses that DOE would conduct as part of its review of
the energy conservation standards for fluorescent lamp ballasts, such
as the engineering analysis, the LCC and PBP analyses, and the NIA.
Representatives for manufacturers, trade associations, environmental
and energy efficiency advocates, and other interested parties attended
the meeting.\3\
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\3\ A transcript of the public meeting and supporting documents
are available in the docket for this proposed determination at:
https://www.regulations.gov/docket?D=EERE-2015-BT-STD-0006.
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III. General Discussion
DOE developed this proposed determination after considering oral
and written comments, data, and information from interested parties
that represent a variety of interests. This notice addresses issues
raised by these commenters.
A. Product Classes and Scope of Coverage
When evaluating and establishing energy conservation standards, DOE
divides covered products into product classes by the type of energy
used or by capacity or other performance-related features that justify
differing standards. In making a determination whether a performance-
related feature justifies a different standard, DOE must consider such
factors as the utility of the feature to the consumer and other factors
DOE determines are appropriate. (42 U.S.C. 6295(q)) The product classes
for this proposed determination are discussed in further detail in
section IV.A.5. This proposed determination covers fluorescent lamp
ballasts defined as a device which is used to start and operate
fluorescent lamps by providing a starting voltage and current and
limiting the current during normal operation. 10 CFR 430.2. The scope
of coverage is discussed in further detail in section IV.A.1.
B. Test Procedure
EPCA sets forth generally applicable criteria and procedures for
DOE's adoption and amendment of test procedures. (42 U.S.C. 6293)
Manufacturers of covered products must use these test procedures to
certify to DOE that their product complies with energy conservation
standards and to quantify the efficiency of their product. DOE's
current energy conservation standards for fluorescent lamp ballasts are
expressed in terms of BLE. (See 10 CFR 430.32(m).)
DOE published a test procedure final rule on October 22, 2009,
establishing standby mode energy consumption test procedures for
fluorescent lamp ballasts (2009 Standby Test Procedure). 74 FR 54445.
DOE published a test procedure final rule on May 4, 2011, establishing
revised active mode test procedures for fluorescent lamp ballasts (2011
Active Mode Test Procedure). 76 FR 25211. The test procedures for
fluorescent lamp ballasts are codified in appendix Q to subpart B of
part 430.\4\
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\4\ The 2011 Active Mode Test Procedure Final Rule established
appendix Q1 to subpart B of part 430, which was subsequently
redesignated as appendix Q to subpart B of part 430 by the
clarification rule published in 2015. 80 FR 31971 (June 5, 2015).
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Subsequently, DOE published several final rules further refining
the test procedures for fluorescent lamp ballasts. On February 4, 2015,
in a final rule, DOE adopted amendments to further specify the
appropriate test procedure and that followed the intent of the 2011
Active Mode Test Procedure to support any new or revised energy
conservation standards at the time those standards require compliance.
80 FR 5896. On June 5, 2015, in a final rule, DOE revised definitions
and test setup, modified organization of requirements, and deleted
obsolete requirements. 80 FR 31971. On April 29, 2016, in a final rule,
DOE replaced all instances of ballast efficacy factor (BEF) with BLE as
applicable, added rounding instructions for BLE and power factor,
clarified represented value instructions for power factor, and
clarified lamp-ballast pairings for testing. 81 FR 25595.
In the Framework document, DOE requested comments on the current
test procedures for fluorescent lamp ballasts and whether amendments
are needed. Pacific Gas and Electric Company, Southern California Gas
Company, San Diego Gas and Electric Company, and Southern California
Edison, collectively referred to herein as the California investor-
owned utilities (CA IOUs), and the Northwest Energy Efficiency Alliance
(NEEA) recommended that DOE begin a review of its test procedure for
fluorescent lamp ballasts if it is considering expanding the scope of
standards to dimming ballasts. (CA IOUs, No. 10 at p. 3; NEEA, Public
Meeting Transcript, No. 5 at p. 68) The National Electrical
Manufacturers Association (NEMA) and Philips Lighting North America
Corporation (Philips) \5\ stated that some technical experts have been
considering an alternative testing procedure that would require
preheating potted ballasts. They asserted that this alternative test
procedure would remove the need to acquire large amounts of data and
save time but yield comparable results to the current DOE test
procedure. (Philips, No. 8 at p. 2; NEMA, No. 12 at p. 2)
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\5\ Between the time of the public meeting and the publication
of this NOPD, Philips Lighting changed its name to Signify. However,
because at the time, the name was Philips, as well as comments in
the docket were provided under the Philips name, throughout this
document, its comments will refer to the company name at the time of
the public meeting.
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DOE appreciates the feedback on DOE's current test procedures for
fluorescent lamp ballasts. DOE initiated a review of the test
procedures and on March 18, 2019, published a notice of proposed
rulemaking for FLB test procedures in which it discusses these comments
in detail (hereafter ``FLB TP NOPR''). 84 FR 9910.
C. Technological Feasibility
1. General
In evaluating potential amendments to energy conservation
standards, DOE conducts a screening analysis based on information
gathered on all current technology options and prototype designs that
could improve the efficiency of the products or equipment that are the
subject of the rulemaking. As the first step in such an analysis, DOE
develops a list of technology options for consideration in consultation
with manufacturers, design engineers, and other interested parties. DOE
then determines which of those means for improving efficiency are
technologically feasible. DOE considers technologies incorporated in
commercially available products or in working prototypes to be
technologically feasible. 10 CFR part 430, subpart C, appendix A,
section 4(a)(4)(i)
After DOE has determined that particular technology options are
technologically feasible, it further evaluates each technology option
in light of the following additional screening criteria: (1)
Practicability to manufacture, install, and service; (2) adverse
impacts on product utility or availability; and (3) adverse impacts on
health or safety. 10 CFR part 430, subpart C, appendix A, section
4(a)(4)(ii)-(iv) Additionally, it is DOE policy not to include in its
analysis any proprietary technology that is a unique pathway to
achieving a certain efficiency level. Section IV.A.4 of this document
discusses the results of the screening analysis for fluorescent lamp
ballasts, particularly the designs DOE considered, those it screened
out, and
[[Page 56544]]
those that are the basis for the standards considered in this proposed
determination. For further details on the screening analysis for this
proposed determination, see chapter 4 of the NOPD technical support
document (TSD).
2. Maximum Technologically Feasible Levels
When DOE considers amended standards for a type or class of covered
product, it must determine the maximum improvement in energy efficiency
or maximum reduction in energy use that is technologically feasible for
such a product. (42 U.S.C. 6295(p)(1)) Accordingly, in the engineering
analysis, DOE determined the maximum technologically feasible (``max-
tech'') improvements in energy efficiency for fluorescent lamp
ballasts, using the design parameters for the most efficient products
available on the market or in working prototypes. The max-tech levels
that DOE determined for this analysis are described in section IV.B of
this proposed determination and in chapter 5 of the NOPD TSD.
D. Energy Savings
1. Determination of Savings
For each efficiency level (EL) evaluated, DOE projected energy
savings from application of the EL to the fluorescent lamp ballast
purchased in the 30-year period that begins in the assumed year of
compliance with the potential standards (2023-2052). The savings are
measured over the entire lifetime of the fluorescent lamp ballasts
purchased in the previous 30-year period. DOE quantified the energy
savings attributable to each EL as the difference in energy consumption
between each standards case and the no-new-standards case. The no-new-
standards case represents a projection of energy consumption that
reflects how the market for a product would likely evolve in the
absence of amended energy conservation standards.
DOE used its NIA spreadsheet model to estimate national energy
savings (NES) from potential amended standards for fluorescent lamp
ballasts. The NIA spreadsheet model (described in section IV.G of this
document) calculates energy savings in terms of site energy, which is
the energy directly consumed by products at the locations where they
are used. For electricity, DOE reports NES in terms of both site and
source energy savings, which is the savings in the energy that is used
to generate and transmit the site electricity. DOE also calculates NES
in terms of full-fuel-cycle (FFC) energy savings. The FFC metric
includes the energy consumed in extracting, processing, and
transporting primary fuels (i.e., coal, natural gas, petroleum fuels),
and thus presents a more complete picture of the impacts of energy
conservation standards.\6\ DOE's approach is based on the calculation
of an FFC multiplier for each of the energy types used by covered
products or equipment. For more information on FFC energy savings, see
section IV.G of this document.
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\6\ The FFC metric is discussed in DOE's statement of policy and
notice of policy amendment. 76 FR 51282 (Aug. 18, 2011), as amended
at 77 FR 49701 (Aug. 17, 2012).
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2. Significance of Savings
In determining whether amended standards are needed, DOE must
consider whether such standards will result in significant conservation
of energy. (42 U.S.C. 6295(m)(1)(A)) In the Proposed Procedures for Use
in New or Revised Energy Conservation Standards and Test Procedures for
Consumer Products and Commercial/Industrial Equipment (``Proposed
Process Rule''), DOE recently proposed to define a significant energy
savings threshold. (84 FR 3910, February 13, 2019). Specifically, DOE
stated that it is considering using two step approach that would
consider both a quad threshold value and a percentage threshold value
to ascertain whether a potential standard satisfies 42 U.S.C.
6295(o)(3)(B) to ensure that DOE avoids setting a standard that ``will
not result in significant conservation of energy.'' 84 FR 3924. In a
subsequent Notice of Data Availability, DOE noted that because EPCA
uses a household energy consumption metric as a threshold for setting
standards for new covered products (42 U.S.C. 6295(l)(1)), DOE believes
that site energy would be the most appropriate metric for evaluating
energy savings across rulemakings. (86 FR 36037, July 26, 2019) As a
result, DOE provided national site energy savings data from its past
rulemakings for public comment to help inform DOE's decision regarding
whether (and how) to define a threshold for significant energy savings.
Consistent with this approach, in addition to source energy savings and
FFC energy savings, DOE's analysis presents site energy savings. In
addition, DOE's conclusions with respect to significance of energy
savings are based on site energy savings. DOE's updates to the Process
Rule have not yet been finalized.
E. Cost Effectiveness
In making a determination of whether amended energy conservation
standards are needed, EPCA requires DOE to consider the cost
effectiveness of amended standards in the context of the savings in
operating costs throughout the estimated average life of the covered
product compared to any increase in the price of, or in the initial
charges for, or maintenance expenses of, the covered product that are
likely to result from a standard. (42 U.S.C. 6295(m)(1)(A), (n)(2), and
(o)(2)(B)(i)(II))
In determining cost effectiveness of amending standards for
fluorescent lamp ballasts, DOE conducted LCC and PBP analyses to
evaluate the economic effects on individual consumers of potential
energy conservation standards for fluorescent lamp ballasts. To further
inform DOE's consideration of the cost effectiveness of amended
standards, DOE considered the NPV of total costs and benefits estimated
as part of the NIA. The inputs for determining the NPV of the total
costs and benefits experienced by consumers are (1) total annual
installed cost, (2) total annual operating costs (energy costs and
repair and maintenance costs), and (3) a discount factor to calculate
the present value of costs and savings.
F. Other Analyses
In addition, DOE conducted a MIA that determines the potential
economic impact of amended standards on FLB manufacturers.
The analyses employed by DOE in its consideration of each of the
criteria applied are discussed in the following sections.
IV. Methodology and Discussion of Related Comments
This section addresses the analyses DOE performed for this proposed
determination with regard to fluorescent lamp ballasts. Separate
subsections address each component of DOE's analyses. DOE used several
analytical tools to estimate the impact of potential energy
conservation standards. The first tool is a spreadsheet that calculates
the LCC savings and PBP of potential energy conservation standards. The
NIA uses a second spreadsheet set that provides shipments projections
and calculates NES and net present value of total consumer costs and
savings expected to result from potential energy conservation
standards. DOE uses the third spreadsheet tool, the Government
Regulatory Impact Model (GRIM), to assess manufacturer impacts of
potential standards. These three spreadsheet tools are available on the
website: https://
[[Page 56545]]
www.regulations.gov/docket?D=EERE-2015-BT-STD-0006.
A. Market and Technology Assessment
DOE develops information in the market and technology assessment
that provides an overall picture of the market for the products
concerned, including the purpose of the products, the industry
structure, manufacturers, market characteristics, and technologies used
in the products. This activity includes both quantitative and
qualitative assessments, based primarily on publicly available
information. The subjects addressed in the market and technology
assessment for this proposed determination include (1) a determination
of the scope and product classes, (2) manufacturers and industry
structure, (3) existing efficiency programs, (4) shipments information,
(5) market and industry trends, and (6) technologies or design options
that could improve the energy efficiency of fluorescent lamp ballasts.
The key findings of DOE's market assessment are summarized in the
following sections. See chapter 3 of the NOPD TSD for further
discussion of the market and technology assessment.
1. Scope of Coverage and Product Classes
Fluorescent lamp ballast means a device which is used to start and
operate fluorescent lamps by providing a starting voltage and current
and limiting the current during normal operation. 10 CFR 430.2. In this
analysis, DOE relied on the definition of ``fluorescent lamp'' in 10
CFR 430.2, which provides the specific lamp lengths, bases, and
wattages included by the term. Any product meeting the definition of
fluorescent lamp ballast is included in DOE's scope of coverage, though
all products within the scope of coverage may not be subject to
standards.
As part of its review of energy conservation standards for
fluorescent lamp ballasts, DOE also evaluated whether current standards
should be extended to additional fluorescent lamp ballasts.
Fluorescent lamp ballasts manufactured on or after November 14,
2014, that are designed and marketed to operate at an input voltage at
or between 120 volts (V) and 277 V, to operate with an input current
frequency of 60 hertz, and for use with fluorescent lamps as defined in
10 CFR 430.2, are currently required to comply with the energy
conservation standards at 10 CFR 430.32(m)(1).
Fluorescent lamp ballasts manufactured on or after November 14,
2014, that are designed and marketed to operate at an input voltage at
or between 120 and 277 V, to operate with an input current frequency of
60 hertz, for dimming to 50 percent or less of the maximum output of
the ballast, and to operate one or two F34T12 lamps, two F96T12 Energy
Saver (ES) lamps, or two F96T12 high output (HO) ES lamps are required
to comply with the energy conservation standards at 10 CFR
430.32(m)(2).
The following fluorescent lamp ballasts are exempt from standards:
(1) A dimming ballast designed and marketed to operate exclusively lamp
types other than one F34T12, two F34T12, two F96T12/ES, or two
F96T12HO/ES lamps; (2) a low frequency ballast that is designed and
marketed to operate T8 diameter lamps; is designed and marketed for use
in electromagnetic-interference-sensitive-environments only; and is
shipped by the manufacturer in packages containing 10 or fewer
ballasts; or (3) a programmed start ballast that operates 4-foot medium
bipin T8 lamps and delivers on average less than 140 milliamperes (mA)
to each lamp. 10 CFR 430.32(m)(3).
In the Framework document, DOE considered extending the scope of
standards to the following: (1) All dimming ballasts, (2) 4-foot T8 MBP
programmed start (PS) ballasts with an average current less than 140
mA, and (3) ballasts that operate on an input voltage of 480 V. DOE did
not consider extending the scope of standards to low frequency ballasts
that are designed and marketed to operate T8 diameter lamps and for use
in electromagnetic-interference-sensitive-environments (EMI-sensitive-
environments) only.
DOE received several general comments on its consideration of
extending standards to additional fluorescent lamp ballasts. Philips
noted that such consideration should account for the declining ballast
market that is reducing annually by about 20 percent. (Philips, No. 8
at p. 16) NEMA noted that no new products or categories of ballasts are
under development. (NEMA, No. 12 at p. 5) However, CA IOUs stated that
DOE has the opportunity to capture significant energy savings for
fluorescent lamp ballasts by expanding the scope of standards to
previously exempted products (e.g., dimming ballasts). CA IOUs
recommended that DOE evaluate the market and utility for ballasts used
in EMI environments, ballasts that operate at input voltages of 480 V,
and low-current PS ballasts to determine if exemptions for these
products are still warranted. (CA IOUs, No. 10 at p. 1) The Appliance
Standards Awareness Project (ASAP) similarly stated that DOE should
consider expanding the scope of standards to include other fluorescent
lamp ballasts to avoid potential loopholes. (ASAP, No. 7 at p. 3)
Lutron noted that because light-emitting diode (LED) technology is
still new and already more efficacious than fluorescent technology, it
is premature to subject LED drivers to standards. (Lutron, No. 9 at p.
3)
DOE conducted an assessment of whether standards should be extended
to certain fluorescent lamp ballasts that are not currently subject to
standards. DOE also evaluated whether current exemptions from standards
should be maintained. DOE notes that this proposed determination
addresses only fluorescent lamp ballasts and not any other technology
such as LED drivers. The following sections discuss DOE's consideration
of extending the scope of standards to additional fluorescent lamp
ballasts.
a. Dimming Ballasts
Currently, only certain dimming ballasts are subject to
standards.\7\ In the Framework document, DOE stated it would consider
extending standards to all dimming ballasts. Several stakeholders did
not support DOE considering standards for all dimming ballasts.
Universal Lighting Technologies (ULT) asserted that energy savings from
improving the efficiency of dimming ballasts were likely to be smaller
than energy savings from the use of controls in a space. (ULT, No. 6 at
p. 2) NEMA stated that its business market survey data indicated that
dimming ballasts are about 2.29 percent of the linear FLB market.
(NEMA, No. 12 at pp. 3-4) Philips stated that while the fixed output
ballast market has declined overtime and dimming ballasts have become a
larger portion of the overall mix, in absolute numbers, dimming
ballasts have not increased as indicated by NEMA's market data from the
past 12 quarters. Further, Philips noted that it will be difficult to
justify costs to improve efficiency of dimming ballasts over investment
in solid-state lighting (SSL) development. (Philips, No. 8 at pp. 10-
11) NEMA, Philips, and ULT indicated that the dimming ballast market
will shrink due to the penetration of solid-state lighting. (ULT,
[[Page 56546]]
No. 6 at p. 2; Philips, No. 8 at pp. 10-11; NEMA, No. 12 at p. 4)
---------------------------------------------------------------------------
\7\ Fluorescent lamp ballasts manufactured on or after November
14, 2014, that are designed to operate at an input voltage at or
between 120 and 277 V and with an input current frequency of 60
hertz, for dimming to 50 percent or less of the maximum output of
the ballast, and to operate one or two F34T12 lamps, two F96T12 ES
lamps, or two F96T12 HO ES lamps. 10 CFR 430.32(m)(2)
---------------------------------------------------------------------------
Several stakeholders expressed support for DOE analyzing standards
for all dimming ballasts. ASAP requested that DOE consider standards
for fluorescent lamp ballasts capable of dimming below 50 percent of
full output, and to include digitally addressable or networkable
ballasts. (ASAP, No. 7 at p. 2) ASAP and CA IOUs stated that the
California Title 24 (CA Title 24 \8\) building code will greatly
increase sales of ballasts capable of dimming below 50 percent of full
light output, which currently are not subject to DOE standards.
Therefore, ASAP and CA IOUs stated that the majority of ballasts
purchased for new construction projects (as well as some retrofit
projects according to CA IOUs) in California will not be regulated by
DOE. (CA IOUs, No. 10 at p. 2; ASAP, No. 7 at p. 2; CA IOUs, Public
Meeting Transcript, No. 5 at p. 106) ASAP added that it expects that
these changes in California will occur across the country as new
dimming ballasts become more widely available. (ASAP, No. 7 at p. 2)
---------------------------------------------------------------------------
\8\ California Energy Commission. 2013 Building Energy
Efficiency Standards for Residential and Nonresidential Buildings.
CEC[hyphen]400[hyphen]2012[hyphen]004-CMF-REV2. Sacramento, CA: CEC,
2012. Available at http://www.energy.ca.gov/2012publications/CEC-400-2012-004/CEC-400-2012-004-CMF-REV2.pdf.
---------------------------------------------------------------------------
However, ULT and NEMA asserted that PS fixed output ballasts that
are controlled by occupancy sensors or other control devices can meet
the requirements of California building codes and ASHRAE standards
(when adopted) and are already covered by DOE standards. ULT added that
outside of a specific room (e.g., conference room) a continuously
dimmed product is not necessary. Further, ULT noted that solid-state
lighting already comes standard with the ability to continuously dim.
(ULT, No. 6 at p. 2; NEMA, No. 12 at p. 4)
DOE appreciates the feedback regarding the shipment trends of
fluorescent lamp ballasts as a whole and that of dimming ballasts.
However, DOE has observed that since the 2011 FL Ballast Rule, product
offerings of dimming ballasts have increased. DOE's review of
manufacturer catalogs indicates a wide range of dimming ballast
products are now available for use with several lamp types.\9\ Further,
DOE has observed a range of efficiencies for dimming ballasts,
indicating that less efficient products can be improved. Additionally,
as noted by stakeholders, state and local regulations and building
codes with increased dimming and/or lighting control requirements
(e.g., CA Title 24 and ANSI/ASHRAE/IES Standard 90.1-2016 \10\) will
continue to support installation of dimming ballasts in the near
future. Therefore, DOE considers that standards for dimming ballasts
could result in potential energy savings.
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\9\ Specifically, 4-foot MBP lamps, 2-foot U-shaped lamps, 4-
foot MiniBP SO lamps, and 4-foot MiniBP HO lamps.
\10\ American Society of Heating, Refrigerating, and Air-
Conditioning Engineers. ANSI/ASHRAE/IES Standard 90.1-2016--Energy
Standard for Buildings Except Low-Rise Residential Buildings.
Atlanta, GA: ASHRAE, 2016.
---------------------------------------------------------------------------
Lutron and NEMA stated that regulations on dimming ballast
efficiency may reduce their availability and may limit potential energy
savings from dimming systems. (Lutron, No. 9 at p. 2; NEMA, No. 12 at
pp. 3-4) Lutron agreed with extending standards to dimming ballasts if
the standards accommodate functionality and features of dimming
ballasts when used in an intelligent light system, noting that these
systems will result in more energy savings than improving the
efficiency of dimming ballasts. (Lutron, No. 9 at p. 2)
In evaluating potential standards, DOE's analysis contemplates that
performance characteristics (including reliability), features, sizes,
capacities, and volumes available to the consumer would remain
available at improved efficiencies of the product.
In summary, in this analysis DOE considered standards for dimming
ballasts and presents the results of an analysis of the technological
feasibility, energy savings, and cost effectiveness of standards for
dimming ballasts.
b. Ballasts Operating at 480 V
Currently only fluorescent lamp ballasts designed and marketed to
operate at nominal input voltages at or between 120 and 277 V are
subject to standards. 10 CFR 430.32(m)(1)(i), (2)(i). ASAP requested
that DOE change the scope of current standards to include ballasts that
operate at 120 V to 480 V. (ASAP, No. 7 at p. 3) However, ULT, General
Electric (GE), and NEMA stated that the market for ballasts that
operate at 480 V is very small, and regulation of these products would
not result in a lot of energy savings. (GE, Public Meeting Transcript,
No. 5 at p. 38; ULT, No. 6 at p. 3; NEMA, No. 12 at p. 5) Philips
agreed and noted that current standards cover the vast majority of the
market by regulating ballasts that operate at input voltages of 120 V
to 277 V. (Philips, No. 8 at pp. 11-12)
ASAP and CA IOUs raised concerns that even if the market for these
products is small, they may become a loophole in industrial
applications because fluorescent technology has been replacing high-
intensity discharge (HID) lighting in high bay applications that are
often on 377 V or 480 V circuits. They encouraged DOE to determine if
this shift to fluorescent technology, particularly in the retrofit
market, will continue to increase in the future. (ASAP, No. 7 at p. 3;
CA IOUs, No. 10 at p. 10)
ULT stated that ballasts that operate at 480 V are typically used
in the industrial applications that function on highly transient power
(i.e., ``dirty power''). ULT and NEMA stated that these ballasts have
added circuitry to ensure that they can withstand high transient lines,
which also makes them expensive. (ULT, Public Meeting Transcript, No. 5
at p. 37; ULT, No. 6 at p. 3; NEMA, No. 12 at p. 5) GE added that
because these ballasts are niche products, manufacturers would not
expend time and effort to redesign them. (GE, Public Meeting
Transcript, No. 5 at p. 38) NEMA asserted that if regulated they would
become obsolete. (NEMA, No. 12 at p. 5)
When considering extending coverage to additional ballasts, DOE
considers whether potential energy conservation standards for these
products would result in significant energy savings. In the 2011 FL
Ballast Rule, DOE examined the ballast market and found input voltages
of 120 V to 277 V to be common to the U.S. market. Ballasts outside
this range were primarily designed for foreign markets, such as 347 V
ballasts for the Canadian market. 76 FR 70548, 70559. In this analysis,
based on DOE's review of manufacturer catalogs, fluorescent lamp
ballasts designed to operate at 120 V to 277 V remain the most common,
and product offerings for ballasts designed to operate at voltages
higher than 277 V were minimal. Further, based on manufacturer feedback
and DOE research, a shift from HID to fluorescent technology will
likely be minor as SSL technology continues to penetrate the lighting
market.\11\ Based on DOE's assessment, standards for fluorescent lamp
ballasts operating at 480 V would not likely result in significant
energy savings. Hence, DOE is not considering extending the scope of
standards to fluorescent lamp ballasts designed and marketed to operate
at voltages higher than 277 V.
---------------------------------------------------------------------------
\11\ There was no increase in shift from HID technology to
fluorescent technology in high-bay applications from 2012 to 2014
according to the DOE Adoption of Light-Emitting Diodes in Common
Lighting Applications. Available at http://energy.gov/sites/prod/files/2015/07/f24/led-adoption-report_2015.pdf.
---------------------------------------------------------------------------
[[Page 56547]]
c. Low-Current PS Ballasts
Currently DOE exempts from standards a PS ballast that operates 4-
foot T8 MBP lamps and delivers on average less than 140 milliamperes
(mA) to each lamp (i.e., low-current PS ballast). 10 CFR
430.32(m)(3)(iii). In the Framework document, DOE stated it will
reevaluate the justification for this exemption. (Framework Document,
No. 1 at p. 13)
NEMA, ULT, and GE stated that DOE should continue to exempt low-
current PS ballasts from standards as they are a niche market. (ULT,
Public Meeting Transcript, No. 5 at p. 37; NEMA, No. 12 at p. 5; GE,
Public Meeting Transcript, No. 5 at p. 38; Philips, No. 8 at p. 11) ULT
added that energy savings from standards would be offset by those
resulting from the low light output. (ULT, Public Meeting Transcript,
No. 5 at pp. 35-36)
ASAP raised concerns that low-current PS ballasts may become a
loophole in the future as they could serve as a low-cost option in
markets for inefficient equipment. (ASAP, Public Meeting Transcript,
No. 5 at p. 33) ULT responded that to operate at a low ballast factor,
a ballast must have an open current voltage, flicker control, as well
as cathodes, all of which add cost to such products. (ULT, Public
Meeting Transcript, No. 5 at pp. 35-36)
Further, NEMA and ULT stated that if regulated, these products
would not comply with DOE efficiency standards and become obsolete as
their low volume would not warrant redesign, eliminating a unique
utility. (NEMA, No. 12 at p. 5; ULT, No. 6 at p. 3) ASAP and CA IOUs
stated that the unique utility of low-current PS ballasts is unclear.
(ASAP, No. 7 at p. 3; CA IOUs, No. 10 at p. 10) ASAP stated that there
are multiple more-efficient lamp-and-ballast combinations available on
the market that can provide light output comparable to low-current PS
ballast systems. (ASAP, No. 7 at p. 3) CA IOUs suggested alternatives
such as using reduced-wattage lamps or fewer lamps and/or fixtures as
efficient replacements. However, CA IOUs stated that if DOE does find
the low-current PS ballasts have a unique utility, DOE should ensure
that they are operating as efficiently as possible. (CA IOUs, No. 10 at
p. 10)
During the 2011 FL Ballast Rule, DOE determined that ballasts
designed to operate 4-foot T8 MPB lamps are required to use some level
of cathode power when operating lamps at currents less than 155 mA to
maintain lamp life. Through testing, DOE learned the ballast factor of
these ballasts was similar to or less than 0.7, offering a unique
utility of low light output. Such ballasts also offered energy savings
from their low power levels and use with occupancy sensors. However,
DOE concluded that, because BLE decreases as current is decreased, none
of the PS ballasts tested with an average current of less than 140 mA
were able to meet the maximum efficiency levels analyzed in the PS
product class. Therefore, DOE exempted these low-current PS ballasts
from standards. 76 FR 70548, 70558.
In this analysis, DOE evaluated whether DOE should continue to
maintain the exemption of low-current PS ballasts. DOE has tentatively
determined that alternative options such as using PS ballasts with
operating current at 140 mA or higher, paired with reduced-wattage
lamps or decreasing the number of lamps in the system could provide low
light output levels comparable to those attained using low-current PS
ballasts. DOE identified lamp-and-ballast replacements that maintained
system light output within 10 percent of a lamp-and-ballast system
using a low-current PS ballast and saved energy.
Because there are reasonable alternatives to providing the low
light output utility offered by low-current PS ballasts, the low-light
feature provided may no longer be unique to these products as when DOE
evaluated them for the 2011 Ballast Rule. As such, DOE included in its
current analysis potential standards for PS ballasts that operate 4-
foot T8 MBP lamps and deliver on average less than 140 mA to each lamp.
d. Low Frequency EMI Ballasts
Currently DOE exempts low frequency ballasts designed and marketed
to operate T8 diameter lamps for use in EMI environments only (``low
frequency EMI ballasts''). They must be shipped by the manufacturer in
packages containing 10 or fewer ballasts. 10 CFR 430.32(m)(3)(ii) For
applications in which EMI has been or is expected to pose safety
concerns, magnetic ballasts that operate at low frequency are typically
recommended. Because these EMI-related safety concerns still exist, in
the Framework document, DOE stated it did not plan to remove this
exemption.
NEMA, GE, ULT, and Philips agreed that low frequency EMI ballasts
should not be subject to standards. (ULT, No. 6 at p. 3; Philips, No. 8
at p. 12; NEMA, No. 12 at p. 5; GE, Public Meeting Transcript, No. 5 at
p. 43) GE added that these are a low volume, niche product and the best
solution for EMI-sensitive environments. (GE, Public Meeting
Transcript, No. 5 at p. 43) ASAP stated that the exemption of these
ballasts made sense to the extent that EMI from technology continues to
be a concern. (ASAP, Public Meeting Transcript, No. 5 at pp. 42-43)
In the 2011 FL Ballast Rule, DOE conducted research and interviews
with FLB and fixture manufacturers to identify several applications as
potentially sensitive to EMI. Applications potentially sensitive to EMI
include but are not limited to medical operating room telemetry or life
support systems, airport control systems, electronic test equipment,
radio communication devices, radio recording studios, correctional
facilities, clean rooms, facilities with low signal-to-noise ratios,
and aircraft hangars or other buildings with predominantly metal
construction. 76 FR 70548, 70557. In this analysis, DOE tentatively
finds that EMI from fluorescent lamp ballasts continues to be a safety
concern.
ASAP asked for more information regarding the definition of EMI-
sensitive environments, Federal Communications Commission's (FCC's)
authority on this issue, and the method of sales and shipment to
restrict leakage of EMI-labeled product into other applications. (ASAP,
Public Meeting Transcript, No. 5 at pp. 42-43) FCC in 47 CFR part 18
regulates industrial, scientific, and medical (ISM) equipment that
emits electromagnetic energy on frequencies within the radio frequency
spectrum in order to prevent harmful interference to authorized radio
communication services. 47 CFR 18.101. Falling under the category of
radio frequency lighting devices, fluorescent lamp ballasts would be
subject to certain conduction limits. 47 CFR 18.307(c). (The Department
of Defense (DoD) also has its own EMI requirements.\12\) The FCC should
be consulted for further information on regulating products that emit
electromagnetic energy.
---------------------------------------------------------------------------
\12\ The DoD MIL-STD-461G section CE102 applies to conducted
emissions from power leads between 10 kilohertz (kHz) and 10
megahertz (MHz) while the standards in section RE102 apply to
radiated emissions between 10 kHz and 18 gigahertz (GHz). These
standards establish ``interface and associated verification
requirements for the control of the EMI emission and susceptibility
characteristics of electronic, electrical, and electromechanical
equipment and subsystems designed or procured for use by activities
and agencies of the Department of Defense (DoD).''
---------------------------------------------------------------------------
ASAP stated DOE should examine the full range of existing low EMI,
energy efficient fluorescent lamp technology options. (ASAP, No. 7 at
p. 4) CA IOUs stated instead of magnetic ballasts designed and labeled
specifically for use in EMI-sensitive environments,
[[Page 56548]]
consumers can use ``hybrid'' magnetic/electronic ballasts and remote-
mounted electronic ballasts, as well as LED light sources. CA IOUs
encouraged DOE to reconsider the need for these less efficient products
when alternatives are available. (CA IOUs, No. 10 at p. 10)
The source of EMI in a fluorescent lamp-and-ballast system consists
mainly of switching components (transistors) in the ballast and the
fluorescent lamp and lead wires. In high-frequency electronic ballasts,
switching components create rapidly changing electric fields eventually
resulting in interference with other circuits on the line. Low-
frequency magnetic ballasts do not have switching components,
dramatically reducing EMI generation. Additionally, lamp and lead wires
create a loop that in the presence of a rapidly switching alternating
current (AC) waveform creates an antenna for radiated EMI. This
phenomenon is more pronounced with electronic ballasts compared to
magnetic ballasts. For these reasons, magnetic ballasts are typically
recommended for use in EMI-sensitive environments.
In the 2011 FL Ballast Rule, DOE examined alternative options such
as use of external EMI filters with electronic ballasts as well as
shielding the ballast with conductive material to mitigate the effects.
However, DOE could not confirm that such methods would definitely
prevent issues related to EMI. In this analysis, DOE again researched
alternative options. In general, DOE found limited product offerings
for hybrid magnetic/electronic ballasts and remote-mounted electronic
ballasts. DOE's research indicated that the hybrid magnetic/electronic
ballasts would not meet existing efficiency standards. Further remote-
mounted electronic ballasts would require separate fixtures for the
lamp and for the ballast and require installation of additional
components such as EMI shielding on the leads and ferrite clamp on the
output wires to safeguard against EMI issues.\13\ While the typical LED
systems in which AC power is converted to DC would cause the same EMI
issues as electronic ballasts, direct DC-powered LED systems do have
the potential to mitigate EMI issues. However, these also would require
a fixture change. Further, because these products are not designed
specifically for EMI-sensitive applications, it is not clear that they
adequately mitigate the effects of EMI.
---------------------------------------------------------------------------
\13\ Philips states remote mounting impacts EMI behavior and
additional measures may be necessary to reduce EMI:
http://images.philips.com/is/content/PhilipsConsumer/PDFDownloads/United%20States/ODL20160330_001_UPD_en_US_PAd-1615DG_Advance_Xitanium_Indoor_Driver_20160324.pdf#page=5.
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ASAP stated that because residential ballasts are subject to less
stringent energy efficiency standards than commercial ballasts due to
being subject to more stringent FCC EMI requirements, DOE should at
least subject the low frequency EMI ballasts to the current residential
FLB energy efficiency standards. (ASAP, No. 7 at p. 4)
DOE's evaluation indicates that magnetic ballasts continue to not
meet existing standards, including those for residential ballasts.
ASAP also stated that DOE should evaluate if it is necessary to
further limit the language ``designed, labeled, and marketed for use in
EMI-sensitive environments only'' used to specify the exemption as it
creates a significant opportunity for low EMI, low price, and energy
inefficient ballasts to gain significant market share. ASAP encouraged
DOE to collect sales data on ballasts specified as low EMI and intended
for commercial use. (ASAP, No. 7 at pp. 3-4; ASAP, Public Meeting
Transcript, No. 5 at p. 43) Philips stated that EMI environments are
very specific (e.g., nuclear power plants, military bases) and because
of the low volume, these ballasts are more expensive. Therefore, it is
unlikely that they would start replacing electronic ballasts or LED
technology with low frequency EMI ballasts. (Philips, Public Meeting
Transcript, No. 5 at pp. 43-44)
DOE currently describes the exemption as ``A low frequency ballast
that is designed and marketed to operate T8 diameter lamps; is designed
and marketed for use in EMI environments only; and is shipped by the
manufacturer in packages containing 10 or fewer ballasts.'' 10 CFR
430.32(m)(3)(ii) DOE finds that because the definition requires the
application to be stated in all publicly available documents and caps
the amount of ballasts sold in one package, it is a sufficient
deterrent to potential unintended use of these ballasts. Further, based
on a review of manufacturer catalogs, DOE did not find a substantial
number of magnetic ballasts designed and marketed for use in EMI-
sensitive environments only, which might have indicated an increasing
market share.
Because magnetic ballasts are the only option that can definitively
address safety concerns regarding EMI and they do not meet existing
standards, DOE is not considering removing the current exemption for
low frequency EMI-sensitive ballasts.
2. Metric
a. Active Mode Energy Consumption
Current energy conservation standards for fluorescent lamp ballasts
are applicable to active mode energy use and are based on BLE. This
metric is a ratio of the power provided by the ballast to the lamp
divided by the input power to the ballast. The metric also includes an
adjustment factor to account for the reduced system efficacy associated
with operation at low-frequency (i.e., 60 Hertz). DOE continues to use
the BLE metric in this proposed determination to assess active mode
energy use.
DOE received comments recommending it adopt a weighted BLE metric
for dimming ballasts. CA IOUs stated that they had supported California
Energy Commission (CEC) in developing Title 20 state appliance energy
efficiency standards for fluorescent lamp ballasts and strongly
suggested DOE take this analysis into consideration in this effort. (CA
IOUs, No. 10 at p. 2) CA IOUs stated that dimming ballasts have a large
potential for energy savings because not all products dim the same way,
and prior to the CEC rule regarding dimming ballasts, there was no
description of ballast performance at dimmed settings. (CA IOUs, Public
Meeting Transcript, No. 5 at pp. 72-73)
Due to this lack of data, CA IOUs tested dimming ballasts to
understand performance below full light output using the DOE's test
procedure for fixed output ballasts. (These data are publicly available
in CEC's rulemaking docket: #14-AAER-1.) Specifically, CA IOUs tested
34 T8 dimming ballasts that operate from one lamp up to four lamps,
which were selected from 180 T8 dimming ballasts listed by the
Consortium for Energy Efficiency (CEE) as qualifying commercial
lighting products. In addition they tested seven T5 dimming ballasts
that operate two lamps. CA IOUs stated that this testing, while not
comprehensive of the full market, was a good starting point. CA IOUs
measured the performance of dimming ballasts at 100 percent full output
and then at input powers decreasing by 5 percent increments until
reaching zero light output using DOE's current test procedure. Based on
these data, CA IOUs noted that ballasts that have the same efficiency
at full light output may not perform the same at lower light output
levels. For instance, two ballasts may have the same performance at
full light output, but may have a 3-5 W difference in power consumption
at 50 percent of full output. (CA IOUs, No. 10 at pp. 2-3, 8;
[[Page 56549]]
CA IOUs, Public Meeting Transcript, No. 5 at pp. 17, 54)
Because of this difference in efficiency at lower light outputs, CA
IOUs stated that CEC has proposed standards for dimming fluorescent
lamp ballasts based on weighting the ballast efficiency measurements at
100 percent, 80 percent, and 50 percent of full arc power in order to
generate one BLE value. CA IOUs stated that 80 percent is a typical
setting when tuning light and a built-in assumption for savings in
certain utility lighting programs, and 50 percent is a representative
operating setting for bi-level dimming ballasts. CA IOUs also stated
that these levels were established after consulting with major FLB
manufacturers and stakeholders who agreed that accurate and repeatable
measurements could be taken at each of those operating levels. CA IOUs
stated that DOE consider using these two points but supported
additional test points below 50 percent of full light output and
recommended DOE conduct further analysis on the feasibility of
measurements at lower output levels. (CA IOUs, No. 10 at pp. 2-3; CA
IOUs, Public Meeting Transcript, No. 5 at pp. 17, 54) ASAP agreed with
CA IOUs that the test procedure and metric should be amended to measure
BLE at partial light output for dimming ballasts, specifically testing
at 80 and 50 percent of full light output in addition to 100 percent.
(ASAP, No. 7 at pp. 2-3)
The efficiency of a dimming ballast may differ at different light
outputs, and the efficiency at full light output may not reflect the
efficiency at which the ballast always performs in application.
However, DOE notes several issues with the accuracy and consistency in
determining the performance of dimming ballasts using a weighted metric
approach. First, the lack of conclusive data makes it difficult to
determine the appropriate weightings to assign to reduced light output
levels to reflect the most common use of dimming ballasts. For example,
the weightings proposed by CEC are based on approximate average energy
savings of dimming ballasts determined from a study on energy savings
from institutional tuning including the use of dimming ballasts and
switches (i.e., light levels adjusted based on location-specific needs
or building policies).\14\ This study determines energy savings for one
scenario of dimming ballast usage and is not necessarily representative
of the common application nor actual operating hours of these products.
---------------------------------------------------------------------------
\14\ Williams, Alison, Barbara Atkinson, Karina Garbesi, and
Francis Rubinstein. A Meta-Analysis of Energy Savings from Lighting
Controls in Commercial Buildings. Ernest Orlando Lawrence Berkeley
National Laboratory. September 2011.
---------------------------------------------------------------------------
Second, as data provided by CA IOUs show, there is no consistent
trend between efficiency and light output at lower levels across
products. Manufacturers apply a range of acceptable cathode powers at
lower currents and choose to do so through various techniques (i.e.,
step, gradual) resulting in varied performance at lower light output
levels. The range of acceptable cathode powers for T8 fluorescent
dimming systems is provided by NEMA LL 9,\15\ and both ballast and lamp
manufacturers design their products accordingly. Hence, the cathode
power required by a lamp may vary by lamp manufacturer. A manufacturer
who produces both ballasts and lamps may design both products to
provide/use the minimum amount of cathode heat. However, a manufacturer
who produces only ballasts may design their product to provide the
maximum amount of cathode heat so that it can operate all lamps
available on the market. DOE finds that it is important to allow for
this flexibility in designing ballasts and a metric should not favor
one approach over another.
---------------------------------------------------------------------------
\15\ NEMA LL 9-2011, Dimming of T8 Fluorescent Lighting Systems
(approved April 12, 2011).
---------------------------------------------------------------------------
Hence, it is unclear if a weighted BLE metric would be an accurate
representation of dimming ballasts in application or provide an
approach for appropriately measuring performance across dimming
products. Therefore, DOE evaluates the efficiency of dimming ballasts
as the BLE at full light output, which reflects the most energy
consumptive state. Measuring BLE at full light output ensures the
accuracy of measured values and provides a consistent basis for
comparing efficiencies across fluorescent lamp ballasts. DOE seeks
comments on its evaluation of the efficiency of dimming ballasts as BLE
at full light output. See section VII.C for a list of issues on which
DOE seeks comment.
For dimming ballasts, Philips recommended a ballast efficiency
metric that would include cathode power as opposed to the BLE metric
which does not. Philips explained that to dim light output the lamp
power and thereby cathode power is reduced. To prevent the resulting
possibility of shortening lamp life and unstable lamp operation, most
dimming ballasts utilize added cathode power in dimming mode. Philips
presented an example of a 2L T8 MBP 32 W ballast showing that at full
light output BLE and ballast efficiency are the same but at lower light
output levels, ballast efficiency is higher because it includes total
lamp arc power plus cathode power while BLE includes total lamp arc
power. Philips concluded that using the BLE metric at lower light
output levels would underrepresent the efficiency of the ballast.
(Philips, No. 8 at pp. 16-29) Therefore, Philips asserted and NEMA
agreed that including cathode power in the metric is important because
it provides utility to dimming ballasts at lower light output levels.
(Philips, No. 8 at pp. 16-29; NEMA, No. 12 at p. 7) Philips noted that
measuring ballast efficiency would require more measurements, but
testing time could be reduced with the use of a multiport power
analyzer. (Philips, No. 8 at pp. 16-29)
Because DOE is using a metric of BLE measured at full light output
for dimming ballasts, the exclusion of cathode power from this
measurement would not underrepresent the efficiency of dimming ballasts
operating at lower light output levels. DOE is aware that the BLE
metric represents cathode power as a loss and that ballasts that use
cathode power will therefore appear less efficient than ballasts that
do not. DOE accounts for this potential difference in efficiency by
establishing separate product classes based on starting method. 10 CFR
430.32(m)(1)(ii)(B).
Philips also commented that the use of dimming ballasts is
different than fixed output ballasts because they are always part of a
lighting control system, whether or not it is a simple control. Philips
stated that if dimming ballasts are required to use less energy, then
to meet such requirements manufacturers will move control and
communications designs from within the ballast to a separate extender
box. Hence, while the ballast may be more efficient, the total
efficiency of the system may not increase. Therefore, Philips suggested
that DOE consider the entire system as opposed to only the ballast
efficiency in its analysis. (Philips, Public Meeting Transcript, No. 5
at p. 119)
The scope of this proposed determination is fluorescent lamp
ballasts and not an entire fluorescent lighting system. DOE finds that
BLE adequately captures the efficiency of all fluorescent lamp
ballasts. DOE does analyze energy use of the lamp-and-ballast system
and uses this assessment of system energy use in its downstream
analyses (i.e., LCC, NIA, etc.).
CA IOUs stated that it is likely that their analysis of
efficiencies of dimming ballasts in the dimming range below 140 mA will
also be useful in understanding the cathode heating needs and
determining appropriate standard levels
[[Page 56550]]
for fixed-output, low current ballasts. (CA IOUs, No. 10 at p. 10)
DOE appreciates the data provided by CA IOUs. As noted, DOE
evaluates all fluorescent lamp ballasts in this analysis based on BLE
measured at full light output.
b. Standby Mode Energy Consumption
EPCA requires energy conservation standards adopted for a covered
product after July 1, 2010, to address standby mode and off mode energy
use. (42 U.S.C. 6295(gg)(3)) EPCA defines active mode as the condition
in which an energy-using piece of equipment is connected to a main
power source, has been activated, and provides one or more main
functions. (42 U.S.C. 6295)(gg)(1)(A)(i)) Standby mode is defined as
the condition in which an energy-using piece of equipment is connected
to a main power source and offers one or more of the following user-
oriented or protective functions: Facilitating the activation or
deactivation of other functions (including active mode) by remote
switch (including remote control), internal sensor, or timer; or
providing continuous functions, including information or status
displays (including clocks) or sensor-based functions. (42 U.S.C.
6295)(gg)(1)(A)(iii)) Off mode is defined as the condition in which an
energy-using piece of equipment is connected to a main power source,
and is not providing any standby or active mode function. (42 U.S.C.
6295)(gg)(1)(A)(ii))
In the 2009 Standby Test Procedure, DOE determined that fluorescent
lamp ballasts do not exhibit off mode energy use. In addition, DOE
stated that the only ballasts subject to standby mode power
measurements would be those that incorporate some electronic circuit
enabling the ballast to communicate with and be part of a lighting
control system (e.g., a digitally addressable lighting interface,
DALI). 74 FR 54445, 54448.
Based on DOE's characterization of ballasts capable of operating in
standby mode in the 2009 Standby Test Procedure, NEMA and Philips
concluded that DOE considers ballasts capable of operating in standby
mode as digitally controlled ballasts, such as DALI. (NEMA, No. 12 at
p. 3; Philips, No. 8 at pp. 5-6) ULT and NEMA stated that DALI ballasts
are mostly used in conference rooms for atmospheric lighting and are
shrinking in market size. They stated that the most common linear
fluorescent lamp ballasts are operated as discrete devices from a
centralized control panel that sends on/off and dimming commands and do
not operate in standby mode. Further, ULT and NEMA asserted that 99
percent of the ballasts in the scope of this analysis do not operate in
standby mode. (ULT, No. 6 at p. 2; NEMA, No. 12 at pp. 2-3) Lutron
noted that DALI is not the only communication protocol used in ballasts
capable of standby mode power consumption. (Lutron, Public Meeting
Transcript, No. 5 at p. 49)
ASAP stated DOE should include digitally addressable or networkable
ballasts and consider the associated standby losses of these products.
ASAP expected dimming ballasts with digital control will be part of
luminaire level lighting control, which involves independently
controlling each luminaire in a space through integrated, programmable,
network sensors. ASAP added that in such scenarios while the ballast
may reduce active mode power consumption, it may also continue to
consume power when switched ``off'' and not emitting light. Therefore,
ASAP recommended that DOE should consider both standby losses and the
benefits of increased controllability in its consideration of coverage
for additional dimming ballasts. ASAP advised DOE to develop a better
definition for ``network standby.'' (ASAP, No. 7 at p. 2) Additionally,
CA IOUs recommended that DOE amend its standby mode test procedure to
specify that a communications network (if applicable) should be
connected to the ballast during testing to capture energy use in
``network standby.'' CA IOUs stated that this is important because
ballasts will likely be consuming additional energy while actively
``listening'' for commands when connected to a communications network.
(CA IOUs, No. 10 at p. 3)
NEMA stated that it is not easy to define a power consumption
standard for a networked product because the standby and full mode
power consumptions will vary based on the particular design and extent
of functionality. (NEMA, Public Meeting Transcript, No. 5 at pp. 49-50)
NEEA agreed with NEMA but noted that DOE would likely have to look at
network standby if it decides to regulate dimming ballasts. (NEEA,
Public Meeting Transcript, No. 5 at p. 50) Philips stated that DOE's
determination of ballasts capable of operating in standby mode prevents
conflict with other modes of operation defined in standards such as IEC
62301, which distinguishes between standby mode power and network mode
power. (Philips, No. 8 at pp. 5-7) Philips also recommended that DOE
develop a standby mode power test method that accounts for the wide
range of input voltages. (Philips, No. 8 at p. 8)
EPCA requires DOE to address the standby mode consumption of a
product. (42 U.S.C. 6295(gg)(3)) Based on DOE's definition of standby
mode, DOE continues to consider a ballast is in standby mode if it has
some electronic circuit enabling the ballast to communicate with and be
part of a lighting control system and if at zero light output the
ballast is standing by, connected to a main power source without being
disconnected by an on/off switch or other type of relay. 74 FR 54445,
54448. Therefore, standby mode energy consumption of a ballast
encompasses any communication by the ballast at zero light output. DOE
finds that additional definitions to capture communication through
specific types of protocols or systems (i.e., network) are not
necessary.
CA IOUs stated standby mode power constitutes a significant portion
of the overall dimming ballast annual energy use and noted that CEC
proposed a separate standard for standby mode power consumption for
dimming ballasts. (CA IOUs, No. 10 at p. 4) CA IOUs reported that
testing done according to DOE's test procedure showed dimming ballasts
to have standby mode power consumption ranging from 0.3 to 1.9 W. (CA
IOUs, Public Meeting Transcript, No. 5 at pp. 15-16) ASAP supported CA
IOUs comments recommending testing of standby mode energy consumption
of ballasts similar to that proposed by CEC. (ASAP, No. 7 at p. 3)
NEMA and Philips noted that standby power energy use in the U.S.
lighting industry varies greatly due to the wide range of functionality
provided by digital ballasts. (NEMA, No. 12 at p. 3; Philips, No. 8 at
p. 8) NEMA cautioned against overly restrictive limits on standby
power, as they could reduce consumer-demanded functionality and DOE
should note that lighting may become the point of connection for smart
products. (NEMA, Public Meeting Transcript, No. 5 at pp. 49-50; NEMA,
No. 12 at p. 3)
DOE tentatively finds in this analysis that a separate standard for
standby power is unnecessary. Currently FLB standards for active mode
are based on BLE, which is a ratio of the power provided by the ballast
to the lamp divided by the input power to the ballast. DOE finds that
for ballasts that are capable of standby mode operation, the
measurement of input power for BLE in active mode would include standby
mode power. Thus, DOE finds that energy conservation standards based on
measuring the BLE of the
[[Page 56551]]
ballast in active mode also capture the energy consumption in standby
mode, where applicable. Further, DOE's analysis of standards for
fluorescent lamp ballasts includes consideration of the continued
availability of products that provide consumer utility presently
provided.
3. Technology Options
In the Framework document, DOE identified several technology
options that would be expected to improve the efficiency of fluorescent
lamp ballasts, as measured by the DOE test procedure. To develop a list
of technology options, DOE reviewed manufacturer catalogs, recent trade
publications and technical journals, and consulted with technical
experts. Specifically, DOE identified technology options identified in
the 2011 FL Ballast Rule: magnetic FLB design, electronic FLB design,
varying lamp diameter, higher grade components, and improved circuit
design. In addition, DOE considered the following improved components
as technology options:
Increasing the number of steel laminations to lower core
losses,
Using optimized-gauge copper to increase the conductor
cross section to reduce winding losses,
Using wire with multiple smaller coils instead of one
larger coil to increase the number of turns of wire, and
Using shape-optimized winding to reduce the proximity
effect losses.
In the Framework document, DOE requested comments on technology
options for improving the BLE of fluorescent lamp ballasts. NEMA
pointed out that core losses in the transformers and inductors used in
electronic ballasts can be minimized by using low-loss ferrite
materials. (NEMA, No. 12 at p. 6) In this analysis, DOE also considered
the option of using low-loss ferrite materials to reduce the proximity
effect.
CA IOUs recommended that DOE analyze the technology options for
improving efficiency listed in the 2011 FL Ballast Rule, including
improved components such as magnetics, diodes, capacitors, and
transistors, as well as improved circuit design. (CA IOUs, No. 10 at p.
5)
Philips stated that the only way to increase efficiency would be to
move to a different technology. ULT, Philips, and GE added that they
and the industry are focusing on solid-state lighting, specifically
LED. (ULT, Public Meeting Transcript, No. 5 at pp. 45-46; Philips,
Public Meeting Transcript, No. 5 at p. 58; GE, Public Meeting
Transcript, No. 5 at p. 67) Further, NEMA, GE, Philips, and ULT
commented that fluorescent lamp ballasts are already at or close to
their maximum achievable efficiency, and that the currently regulated
products have no margin to improve efficiency. (NEMA, Public Meeting
Transcript, No. 5 at pp. 9-11; GE, Public Meeting Transcript, No. 5 at
p. 67; Philips, No. 8 at pp. 13-14; ULT, No. 6 at p. 5) NEMA, GE, and
ULT asserted that the last rulemaking compressed the available levels
of efficiency such that the current market only consists of a maximum
and a minimum level, with very little room for differentiation among
manufacturers. (NEMA, No. 12 at p. 7; GE, Public Meeting Transcript,
No. 5 at p. 67; ULT, Public Meeting Transcript, No. 5 at pp. 45-46)
Philips and ULT added that technology options such as transistors with
reduced resistance, lowering impedance value on capacitors, increasing
steel laminations, reducing winding resistance, increasing the turns of
wire, and reducing proximity effect losses are already incorporated in
current products. (Philips, Public Meeting Transcript, No. 5 at p. 58;
ULT, No. 6 at p. 5) Lutron stated DOE should assume that all the
dimming ballasts that are going to be available after any rule becomes
effective are already on the market. (Lutron, Public Meeting
Transcript, No. 5 at p. 104) Philips and GE noted that because
fluorescent technology is on the decline, there are no new investments
in fluorescent lamp ballasts. (Philips, Public Meeting Transcript, No.
5 at p. 58; GE, Public Meeting Transcript, No. 5 at p. 67)
Based on DOE's review of the product offerings and their
efficiencies in manufacturer catalogs and DOE's Compliance
Certification Management System (CCMS) database, there are ballasts on
the market at multiple levels of efficiencies. DOE finds that the
technology options identified, individually and/or in combination, are
being utilized to improve the efficiency of products. Therefore, DOE
continues to consider these technology options as a means to improve
the efficiency of fluorescent lamp ballasts.
Based on their test data for dimming ballasts, CA IOUs asserted
that cathode cutout is a major efficiency improvement opportunity for
dimming ballasts and is currently employed by multiple dimming ballast
manufacturers. CA IOUs compared two 3-lamp dimming ballasts, one that
saved energy by using less than the allowable cathode power at lower
currents and cutout cathode power at higher currents, and another that
saved less energy by employing a continuous maximum amount of allowable
cathode power. (CA IOUs, Public Meeting Transcript, No. 5 at p. 57; CA
IOUs, No. 10 at pp. 5-7)
NEMA commented that there are several patents on how to employ
cathode cutout technology and urged DOE to exercise caution not to
inadvertently favor one method over another. (NEMA, Public Meeting
Transcript, No. 5 at pp. 58-59) CA IOUs responded that based on
conservative assumptions for hot cathode resistance per the maximum
voltage allowance at lower currents defined by NEMA LL 9-2011, any
ballast can use anywhere from 0 up to 5.6 W per lamp of cathode power
at lower currents. CA IOUs stated that while not all manufacturers may
have access to every piece of technology, this range provided enough
space for achieving significant energy savings. CA IOUs added that
based on their analysis for CEC's proposed standards for dimming
ballasts, all major manufacturers had products meeting standards, and
they determined that the necessary technology is not being limited to
one or two manufacturers due to intellectual property issues. (CA IOUs,
Public Meeting Transcript, No. 5 at pp. 59-61; CA IOUs, No. 10 at pp.
5-7)
DOE agrees that cathode cutout can improve ballast efficiency and
considered it as a technology option in this analysis. Information
obtained in manufacturer interviews indicated that patents may apply to
certain methods of achieving cathode cutout, but achievement of the
highest levels of efficiency analyzed in this proposed determination
did not require use of technologies subject to a patent.
CA IOUs stipulated that improved components and other circuit
design approaches are also viable methods for improving dimming ballast
efficiency, and encouraged DOE to explore the full range of technology
options available to manufacturers. (CA IOUs, Public Meeting
Transcript, No. 5 at p. 57; CA IOUs, No. 10 at pp. 5-7)
DOE considers the full range of technology options identified, for
both dimming and fixed-output ballasts. DOE notes it considers the same
metric (i.e., BLE at full light output) for dimming ballasts as it does
for fixed-output ballasts (see section IV.A.2 for further details).
NEMA commented that steel laminations comprise a very small
percentage of magnetics in an electronic ballast and are used for line
frequency ballasts. Further, they are typically used for dedicated line
voltage such as 120 V AC. (NEMA, No. 12 at p. 6) Philips stated that
use of amorphous steel doesn't provide for an effective work
[[Page 56552]]
product and it will continue to use it only for magnetic ballasts.
(Philips, Public Meeting Transcript, No. 5 at p. 64)
DOE determined that using laminated sheets of steel to create the
core of the inductor may not minimize losses in ballasts that operate
at high frequencies. Therefore, because the ballasts analyzed in this
proposed determination are electronic ballasts and operate at high
frequencies, DOE did not consider laminated sheets of amorphous steel
or increasing the number of steel laminations to lower core losses as
technology options.
DOE agrees that the use of low-loss ferrite materials can minimize
losses in transformers and inductors used in ballasts. Ferrite is
already widely used in electronic ballasts. However, DOE determined
that ferrite can be optimized to reduce losses by changing the percent
composition from three principal oxides: Manganese oxide, zinc oxide,
and iron (III) oxide. If the ideal amounts of each oxide are selected,
the ferrite can have lower losses.\16\ For example, manganese-zinc
ferrite is a common solid core material selected for its size
efficiency and can be optimized for high frequencies, up to 2 MHz.\17\
Hence, in this analysis, DOE is including use of low-loss ferrite
materials to create the core of the inductor in the transformer of the
ballast as a technology option to increase ballast efficiency.
---------------------------------------------------------------------------
\16\ Standard Recommendations: Soft Ferrite Cores, A User's
Guide. 2011.
\17\ McLyman, C. Transformer and Inductor Design Handbook. 2011.
Boca Raton, FL: CRC Press.
---------------------------------------------------------------------------
NEMA also added that the technology option, as described by DOE,
which involves using wire with multiple smaller coils instead of one
larger coil is poorly defined. They indicated that this technology
option should refer to litz wire and added that most electronic ballast
manufacturers already use litz wire where appropriate. (NEMA, No. 12 at
p. 6)
The technology option of using wire with multiple smaller coils
(instead of the technology option of using one larger coil to increase
the number of turns of wire) describes a way to increase the inductance
of a coil and therefore the induced voltage of the transformer. The
magnitude of the induced voltage is based on the magnetic field in the
transformer (which is based on the inductance), the frequency of
operation, number of turns of the coil, and the cross sectional area of
the transformer. For the same length of wire, a series of smaller coils
will have a larger number of turns than one coil that has a core with a
large cross sectional area. The additional number of turns of the wire
will increase the induced voltage, and thereby minimize losses from the
transformer. Provided that the number of turns is increased more than
the cross sectional area is reduced, the series of smaller coils would
have fewer losses than one large coil. This technology option is
different from the use of litz wire. Litz wire refers to a bundle of
thin insulated wires braided together such that the same sides of the
two wires are not interacting with one another the entire time, thereby
minimizing the magnetic effects between wires that negatively affect
current flow. In this analysis DOE continues to consider both use of
multiple smaller coils and litz wire as technology options to increase
the efficiency of the ballast.
In summary, for this analysis, DOE considers the technology options
shown in Table IV.1. Detailed descriptions of these technology options
can be found in chapter 3 of the NOPD TSD.
Table IV.1--Fluorescent Lamp Ballast Technology Options
----------------------------------------------------------------------------------------------------------------
Technology option Description
----------------------------------------------------------------------------------------------------------------
Electronic Ballast............................. Use an electronic ballast design.
Improved Components:
Transformers/Inductors..................... Use litz wire to reduce winding losses.
Use wire with multiple smaller coils instead of one larger coil
to increase the number of turns of wire.
Use optimized-gauge copper to increase the conductor cross
section to reduce winding losses.
Use shape-optimized winding to reduce the proximity effect
losses.
Use low-loss ferrite materials to create the core of the
inductor.
Diodes..................................... Use diodes with a lower voltage drop.
Capacitors................................. Use capacitors with a lower effective series resistance.
Transistors................................ Use transistors with low drain-to-source resistance.
Improved Circuit Design:
Cathode Cutout or Cutback.................. Remove or reduce cathode/filament heating after lamp has
started.
Integrated Circuits........................ Substitute discrete components with an integrated circuit.
Starting Method............................ Use of instant start (IS) starting method instead of a rapid
start (RS) starting method.
----------------------------------------------------------------------------------------------------------------
4. Screening Analysis
DOE uses the following four screening criteria to determine which
technology options are suitable for further consideration in an energy
conservation standards rulemaking:
(1) Technological feasibility. Technologies that are not
incorporated in commercial products or in working prototypes will not
be considered further.
(2) Practicability to manufacture, install, and service. If it is
determined that mass production and reliable installation and servicing
of a technology in commercial products could not be achieved on the
scale necessary to serve the relevant market at the time of the
projected compliance date of the standard, then that technology will
not be considered further.
(3) Impacts on product utility or product availability. If it is
determined that a technology would have significant adverse impact on
the utility of the product to significant subgroups of consumers or
would result in the unavailability of any covered product type with
performance characteristics (including reliability), features, sizes,
capacities, and volumes that are substantially the same as products
generally available in the United States at the time, it will not be
considered further.
(4) Adverse impacts on health or safety. If it is determined that a
technology would have significant adverse impacts on health or safety,
it will not be considered further.
10 CFR part 430, subpart C, appendix A, 4(a)(4) and 5(b)
In summary, if DOE determines that a technology, or a combination
of technologies, fails to meet one or more of the listed four criteria,
it will be excluded from further consideration in
[[Page 56553]]
the engineering analysis. Additionally, it is DOE policy not to include
in its analysis any proprietary technology that is a unique pathway to
achieving a certain efficiency level.
DOE received some general comments regarding the screening
methodology and its application to fluorescent lamp ballasts. Philips
commented that occasionally the criterion of manufacturing practicality
has been slanted toward being theoretically possible rather than
economically justifiable for a ballast manufacturer and consumer.
Philips stated that DOE should be cognizant of the costs associated
with design-in, approbation, marketing, and implementation of that new,
revised design into luminaires and that it might not have a positive
business case. (Philips, No. 8 at p. 15)
When determining manufacturing practicality, DOE will only consider
a technology option practical to manufacture if mass production and
reliable installation and servicing of the technology can be achieved
in the appropriate scale and timeframe. DOE finds that the technology
options under consideration are being utilized in ballast designs for
commercially available ballasts and, therefore, meet the criteria of
practicable to manufacture. Regarding the costs associated with design
options, DOE considers economic impacts including costs to the
individual customers, manufacturers, and the nation of efficiency
levels incorporating design options under consideration in the LCC,
NIA, and MIA analyses.
DOE received several comments regarding the impact of the
technology options under consideration on the size of the ballast.
Philips and NEMA commented that any improvements in efficiencies will
likely cause an increase in the ballast footprint. (Philips, No. 8 at
p. 11; NEMA, No. 12 at p. 11) ULT, Philips, and NEMA emphasized that
avoiding technology and efficiency improvements that necessitate
changes in the physical size outside the normal ballast case footprint
would be an ideal approach. (ULT, No. 6 at p. 9; Philips, No. 8 at pp.
13-14; NEMA, No. 12 at p. 11) NEMA added that implementing efficiency
changes causing fluorescent lamp ballasts to have designs outside of
standard case sizes would increase maintenance costs. (NEMA, No. 12 at
p. 11) ULT also noted that any changes in technology that increase
ballasts' physical volume would be disruptive to the original equipment
manufacturer (OEM) and replacement channels. (ULT, No. 6 at p. 5)
Philips stated that while incremental design improvements leading to
additional energy savings with efficiency gains of 1 to 2 percent are
theoretically possible, they will result in a negative impact on
luminaire compliance with existing, size-based electrical requirements.
(Philips, No. 8 at pp. 13-14)
When determining adverse impacts to consumer utility and product
availability, DOE takes into account whether a technology option will
result in lessening of utility to the consumer. Therefore, in its
analysis, DOE accounts for scenarios in which a technology option
increases the size of the ballast making it unusable in an application
in which it is currently used. DOE found no evidence that the
technology options identified could not be utilized in a manner that
would maintain the size of the ballast.
Regarding impacts of technology options on costs, DOE does not
consider cost as a factor for screening out technology options. DOE
considers the economic impacts and costs on individual customers,
manufacturers, and the nation in the LCC, NIA, and MIA analyses.
DOE also received specific comments regarding the screening of
technology options under consideration. In the Framework document, DOE
considered using optimized-gauge copper or increasing the conductor
cross section to reduce winding losses, using wire with multiple
smaller coils, and using shape-optimized winding to improve the
transformer component of the ballast. ULT stated that industry already
considers the technology options of using optimized-gauge copper, wire
with multiple smaller coils, and using shape-optimized winding in the
development of their product and any adjustments would increase the
physical volume of these products. (ULT, No. 6 at pp. 4-5) NEMA
commented that copper losses can be minimized by increasing the cross
section of the conductor, but increasing the wire gauge can result in
larger, more costly magnetics. (NEMA, No. 12 at p. 6) Philips stated
that optimized-gauge copper or increasing the conductor cross section
may also increase the size of the ballast and increase manufacturing
costs. (Philips, No. 8 at p. 14)
Implementing certain technology options to increase ballast
efficiency may increase the size of the ballast. However, as noted in
manufacturer comments, these technology options are likely already
being used in certain commercially available products; therefore, DOE
believes it is possible to utilize them while maintaining the size of
the ballast so it would not impact the application in which it is used.
Philips noted that the use of multiple smaller coils is a good
approach that has been in use for a long time and is optimized at this
point; and while manufacturers could use smaller multiple coils, it
would increase the complexity of the process, possibly making the coil
wire easier to break. (Philips, No. 8 at p. 14)
Because DOE has observed ballasts at multiple efficiencies,
manufacturers are likely utilizing different levels of technology
options under consideration including the number of small coils used.
Therefore, DOE continues to consider the use of multiple smaller coils
as a design option.
Regarding shape-optimized wiring, Philips stated that while this
technique can reduce proximity effect losses in industries such as
motors, it is more complex and expensive for ballast manufacturers.
Philips added that if it used a special process to make an EF25 \18\
coil to reduce the proximity effect losses, it will increase efficiency
by 0.1 percent. (Philips, No. 8 at p. 14)
---------------------------------------------------------------------------
\18\ An EF25 coil is a coil for an E-shaped ferrite core that is
25 mm high.
---------------------------------------------------------------------------
In identifying design options, DOE does not consider costs, which
are analyzed in separate analyses. DOE identifies technology options
that will improve efficiency. However, improvement in efficiency is not
a criteria used to determine which technology options are suitable for
further consideration in an energy conservation standards rulemaking.
10 CFR part 430, subpart C, appendix A, 4(a)(4) Therefore, DOE
continues to consider shape-optimized wiring as a design option.
a. Screened-Out Technologies
For this analysis, DOE did not screen out any technology options
identified.
b. Remaining Technologies
After reviewing each technology, DOE tentatively concludes that all
of the identified technologies listed in section IV.A.3 pass all four
screening criteria to be examined further as design options in this
analysis. In summary, DOE did not screen out the following technology
options and considers them as design options in the engineering
analysis:
(1) Electronic Ballasts
(2) Improved Components
(a) Use litz wire to reduce winding losses.
(b) Use wire with multiple smaller coils instead of one larger coil
to increase the number of turns of wire.
(c) Use optimized-gauge copper or increase the conductor cross
section
[[Page 56554]]
to reduce winding losses.
(d) Use shape-optimized winding to reduce the proximity effect
losses.
(e) Use diodes with lower losses.
(f) Use capacitors with a lower effective series resistance.
(g) Use transistors with low drain-to-source resistance.
(h) Use low-loss ferrite to create the core of the inductor.
(3) Improved Circuit Design
(a) Remove filament heating after the lamp has started.
(b) Substitute discrete components with an integrated circuit.
DOE determined that these technology options are technologically
feasible because they are being used or have previously been used in
commercially available products or working prototypes. DOE also finds
that all of the remaining technology options meet the other screening
criteria (i.e., practicable to manufacture, install, and service and do
not result in adverse impacts on consumer utility, product
availability, health, or safety). For additional details, see chapter 4
of the NOPD TSD.
5. Product Classes
In general, when evaluating and establishing energy conservation
standards, DOE divides the covered product into classes by (1) the type
of energy used, (2) the capacity of the product, or (3) any other
performance-related feature that affects energy efficiency and
justifies different standard levels, considering factors such as
consumer utility. (42 U.S.C. 6295(q))
DOE received some general comments regarding product classes. ULT
and NEMA commented that current product class definitions should not be
changed. (ULT, No. 6 at p. 4; NEMA, No. 12 at p. 5) Giving the example
of a dimming ballast that can adjust the cathode power for a specific
lamp based on the lamp's filament impedance, Philips commented that DOE
should ensure that within the dimming product class, dimming ballasts
with added features not be eliminated because they consume more energy
than a standard dimming ballast. (Philips, Public Meeting Transcript,
No. 5 at p. 61)
In this analysis, DOE reviewed FLB types to identify those with a
capacity or other performance-related feature which other FLBs do not
have, and considered whether such feature would justify a higher or
lower standard compared to all other ballast types. In the following
sections, DOE discusses the resulting product classes DOE considered
for analysis and responds to comments on specific product class setting
factors.
a. Existing Product Classes
In the Framework document, DOE considered maintaining the product
classes for ballasts currently subject to standards. The product
classes are currently divided based on starting method, lumen package,
sign ballasts, and residential versus commercial application.
Both rapid start (RS) and PS ballasts use cathode power; however,
PS ballasts limit the voltage across the lamp to prevent glow discharge
during initial cathode heating resulting in an increase in lifetime
during on/off cycling, and the cathode heat can be removed or reduced
after the lamp is in full conduction. Therefore, DOE considers PS
ballasts to offer a performance-related feature that justifies a
different efficiency level compared to instant start (IS) ballasts.
Hence, DOE maintains a separate product class for ballasts with the PS
starting method in this analysis. See chapter 3 of the NOPD TSD for
further details.
To obtain a higher lumen package (i.e., amount of light from a
lamp-and-ballast system), certain lamps are designed to operate with
ballasts that run the lamps at high currents. Unlike ballasts
generally, ballasts designed to operate HO lamps are typically used in
high ceiling or outdoor applications. Ballasts operating HO lamps
operate at higher total lamp arc powers compared to standard output
(SO) lamps. BLE generally increases with total lamp arc power. However,
DOE found that even though 8-foot HO ballasts have higher lamp arc
powers, they generally have lower BLEs when compared to 8-foot single
pin (SP) slimline ballasts. This may be because this ballast type has a
different topology, or circuit design, than other ballast types (e.g.,
4-foot MBP and 8-foot SP slimline ballasts). Because the lumen package
provides a feature that other ballasts do not and that feature
justifies a different efficiency requirement compared to other
ballasts, DOE maintains a separate product class for ballasts that
operate 8-foot HO lamps. See chapter 3 of the NOPD TSD for further
details.
Ballasts that are designed for use in outdoor signs offer
performance-related features that other ballasts generally do not. To
operate in outdoor environments and to be able to handle numerous lamp
combinations, sign ballasts contain more robust components compared to
regular 8-foot HO ballasts in the commercial sector. Thus, sign
ballasts are inherently less efficient. Therefore, DOE maintains a
separate product class for sign ballasts that operate 8-foot HO lamps.
See chapter 3 of the NOPD TSD for further details.
Finally, DOE noted in the Framework document that it planned to
maintain separate product classes for residential and commercial
ballasts. DOE received several comments on this consideration. ASAP
encouraged DOE to consider the rationale for a product class for
residential ballasts. (ASAP, Public Meeting Transcript, No. 5 at pp.
50-51) NEEA agreed asserting that commercial ballasts work just as well
in a house and have no obvious impact on anything in the house. (NEEA,
Public Meeting Transcript, No. 5 at pp. 51-52) ASAP and CA IOUs
recommended DOE revisit its analysis of residential ballasts to account
for changes in the market, such as cost of higher quality components,
trends in ballast efficiency, or other factors that may have changed
since standards from the 2011 FL Ballast Rule took effect. (CA IOUs,
No. 10 at p. 9; ASAP, No. 7 at pp. 4-5; ASAP, Public Meeting
Transcript, No. 5 at p. 50-51)
Philips noted that residential ballasts are subject to more
stringent FCC EMI requirements, and some customers may have sensitive
equipment that requires extra protection. Further, Philips stated that
even if residential customers were satisfied with commercial ballasts,
because of the FCC requirements, manufacturers must produce separate
ballasts that include additional EMI filtering for the residential
market. (Philips, Public Meeting Transcript, No. 5 at p. 52) Lutron
agreed with Philips comments. (Lutron, Public Meeting Transcript, No. 5
at p. 52) Philips added that whereas incremental design improvements
leading to additional energy savings with efficiency gains of 1 to 2
percent are theoretically possible, they will result in a negative
impact on ballast compliance with FCC EMI requirements as specified in
47 CFR part 18. (Philips, No. 8 at pp. 13-14)
CA IOUs referred to a comment made in the 2011 FL Ballast Rule by
Acuity Brands Lighting, Inc. (Acuity) stating that a residential
ballast that achieves the same efficiency as the most efficient
commercial products would be 50 percent more expensive. CA IOUs stated
that this indicated it is technically feasible to improve the
efficiency of residential ballasts, though it may be more expensive.
(CA IOUs, No. 10 at p. 9) Further, ASAP and CA IOUs stated that the
increasing affordability and confidence in LED technology will provide
consumers with more cost-effective, efficient technology options while
regulations from EISA will limit the availability of less energy-
efficient options. Therefore, the potential risk of residential
fluorescent lighting users
[[Page 56555]]
``backsliding'' to less efficient lighting technologies due to the
possibly higher cost of energy efficient residential fluorescent lamp
ballasts has been significantly reduced. (CA IOUs, No. 10 at p. 9;
ASAP, No. 7 at pp. 4-5; ASAP, Public Meeting Transcript, No. 5 at pp.
50-51)
Further, ASAP and CA IOUs stated that compared to commercial
ballasts, more stringent EMI filter requirements for residential
ballasts may lower efficiency, but the less stringent power factor
requirements can increase efficiency by not requiring more robust power
factor control devices. CA IOUs and ASAP suggested that DOE analyze how
these two factors impact achievable efficiency through additional
testing and/or modeling, as necessary, and develop an adjustment factor
that can be applied to the current standard for commercial ballasts to
define an appropriate standard level for residential ballasts. Further,
CA IOUs and ASAP suggested that DOE not limit itself to available
commercial products and model achievable efficiency levels for
residential ballasts based on the same set of technology options
available to commercial ballasts. (CA IOUs, No. 10 at p. 9; ASAP, No. 7
at pp. 4-5; ASAP, Public Meeting Transcript, No. 5 at pp. 50-51)
In the 2011 FL Ballast Rule, DOE determined that the FCC requires
residential ballasts to have more stringent or maximum allowable EMI
and per American National Standards Institute (ANSI) standards \19\
have a lower minimum power factor than commercial ballasts. Based on
these differing requirements, DOE concluded that residential ballasts
serve distinct market sectors and applications. 76 FR at 70564. In this
analysis, DOE finds that these requirements continue to exist. Further,
DOE's review of ballast efficiencies showed that residential ballasts
are unable to achieve similar maximum efficiencies as commercial
ballasts. Therefore, because residential ballasts serve distinct market
sectors and applications, and are unable to meet commercial efficiency
levels, DOE continues to consider separate product classes for
residential ballasts.
---------------------------------------------------------------------------
\19\ ANSI C82.77-2002 requires residential ballasts to have a
minimum power factor of 0.5 and commercial ballasts to have a
minimum power factor of 0.9. American National Standard for Lighting
Equipment--Harmonic Emissions Limits--Related Power Quality
Requirements for Lighting Equipment (Approved January 17, 2002).
---------------------------------------------------------------------------
DOE did not model efficiencies for residential ballasts. Based on
its review of patents and product offerings, DOE did not find more
efficient prototypes or commercially available products with design
requirements similar to residential ballasts that could serve as a
basis for modeling higher efficiencies. Further, without a physical
model to test, it would be difficult to confirm that design changes
made to improve ballast efficiency would continue to allow the ballast
to meet FCC's EMI filter requirements. See chapter 5 of the NOPD TSD
for the assessment of efficiency levels of residential ballast product
classes.
NEMA commented that as this rulemaking proceeds and other
regulatory impacts are discussed, NEMA and Electrofed Canada have been
in discussions with FCC and Industry Canada regarding revisions to
emissions requirements for lighting products in North America. They
expect the forthcoming binational negotiations to determine the
appropriate emissions limits may take a few years. NEMA stated it will
keep DOE informed of the progress of these negotiations as this FLB
rulemaking progresses. NEMA cautioned that if emissions requirements
become more stringent across the board, added functionality and
filtering could impact price and efficiency. (NEMA, Public Meeting
Transcript, No. 5 at pp. 52-53)
DOE appreciates information on discussions regarding emissions
requirements for lighting products and looks forward to learning of
their progress.
b. Additional Product Classes
In the Framework document, DOE considered product classes for
dimming fluorescent lamp ballasts based on the following four factors:
(1) Residential versus commercial, (2) lamp type operated by the
ballast, (3) continuous versus step dimming, and (4) dimming
communication protocol.
Lutron and NEMA commented that proprietary control systems can save
the same or more energy than standardized control interfaces such as
DALI, and DOE should broadly define a product class to be ``digitally-
controlled dimming ballasts, such as DALI'' and should only include
ballasts that operate 4-foot T5 and T8 lamps. Lutron and NEMA added
that digital dimming ballasts have energy-saving advantages such as the
ability to react to demand response events and report power usage as
well as to allow for independent occupancy-sensed and daylighting
zones. They stated that these features require off-state power
consumption for which digital ballasts should be given an allowance.
(Lutron, No. 9 at p. 2; NEMA, No. 12 at pp. 5-6)
CA IOUs noted that CEC proposed one single product class for all
dimming ballasts including T5 and T8 dimming ballasts, irrespective of
number of lamps. However, CA IOUs shared initial test results
suggesting dimming ballasts operating 2L T5 may be able to achieve
higher efficiencies than those operating 2L T8 ballasts. CA IOUs
recommended that DOE test a full range of dimming ballasts that operate
T5 lamps to determine whether a separate product class is necessary to
set more appropriate standard levels for these ballasts. (CA IOUs, No.
10 at pp. 4-5)
Unlike other ballasts, dimming ballasts allow consumers to control
the level of light output. Further, DOE's research and feedback from
manufacturer interviews indicate that due to the added circuitry,
dimming ballasts are less efficient than standard ballasts. Therefore,
for this analysis, DOE maintains a separate product class for dimming
ballasts.
DOE recently published a request for information (RFI) on the
emerging smart technology appliance and equipment market. 83 FR 46886
(Sept. 17, 2018). In that RFI, DOE sought information to better
understand market trends and issues in the emerging market for
appliances and commercial equipment that incorporate smart technology.
DOE's intent in issuing the RFI was to ensure that DOE did not
inadvertently impede such innovation in fulfilling its statutory
obligations in setting efficiency standards for covered products and
equipment. In this NOPD, DOE seeks comment on the same issues presented
in the RFI as they may be applicable to fluorescent lamp ballasts.
DOE analyzed one product class for all types of dimming FLBs
regardless of use in sector, lamp type, or communication protocol used.
DOE did not identify any dimming ballasts designed and marketed only
for residential use. While some communication protocols used with
dimming ballasts provide added features, DOE's evaluation of dimming
ballast efficiencies indicated that these features did not affect
efficiency, and analysis of separate product classes based on
communication protocols was not necessary. Hence, for this analysis DOE
does not consider a separate product class for ballasts with digital
communication protocols.
Additionally, DOE's evaluation of the dimming ballast market and
feedback from manufacturer interviews did not indicate that
consideration of a separate product class (or classes) based on the
lamp type operated by a dimming ballast was justified. DOE's analysis
showed that with the exception of digital ballasts, the efficiency of
dimming ballasts operating T8 lamps is
[[Page 56556]]
comparable to those operating T5 lamps. Regarding digital ballasts,
product offerings showed that digital ballasts that operate T5 lamps
are slightly more efficient than digital ballasts that operate T8
lamps. Manufacturer catalogs also indicated that there are more product
offerings for digital ballasts that operate T5 lamps than T8 lamps. DOE
identified digital ballasts that operate T8 MBP lamps as lower volume
products, and tentatively determined that the lower efficiencies are
not due to the dimming function but instead because these ballasts are
likely not utilizing the most advanced technologies and the
efficiencies of these ballasts can be improved. As such, DOE
tentatively determined that a separate product class for digital
ballasts that operate T8 MBP lamps would not be justified.
As noted in section IV.A.1.c, DOE includes in the scope of this
analysis standards for low-current PS ballasts. In the Framework
document, DOE considered a separate product class for such ballasts,
based on factors such as lamp type operated by the ballast, starting
method, and ballast input voltage. DOE's review of efficiency data
indicates that low-current PS ballasts have a lower efficiency than
comparable PS ballasts. These ballasts typically have ballast factors
equal to or below 0.7 allowing them to offer low light outputs.
However, DOE finds that the ability to provide low light outputs can be
achieved by using ballasts with higher ballast factors paired with
reduced-wattage lamps or by decreasing the number of lamps in the
system. Therefore, because the ability to provide low light output is
not limited to low-current PS ballasts, DOE did not consider a separate
product class for these ballasts for the purpose of this analysis.
c. Summary
In summary, DOE assessed the product classes shown in the following
list in its analysis. In describing product classes, DOE includes the
types of lamps each class of ballast operates. In this analysis, DOE
updated the list of lamp types based on a review of the latest product
offerings on the market and added 4-foot T5 SO and 4-foot T5 HO lamp
types for the IS/RS (not classified as residential), IS/RS residential,
and PS residential product classes. See chapter 3 of the NOPD TSD for
further discussion.
(1) IS and RS ballasts (not classified as residential) that operate
(a) 4-foot MBP lamps
(b) 2-foot U-shaped lamps
(c) 4-foot T5 SO lamps
(d) 4-foot T5 HO lamps
(e) 8-foot SP slimline lamps
(2) PS ballasts (not classified as residential) that operate
(a) 4-foot MBP lamps
(b) 2-foot U-shaped lamps
(c) 4-foot T5 SO lamps
(d) 4-foot T5 HO lamps
(3) IS and RS ballasts (not classified as sign ballasts) that operate
(a) 8-foot HO lamps
(4) PS ballasts (not classified as sign ballasts) that operate
(a) 8-foot HO lamps
(5) Sign ballasts that operate
(a) 8-foot HO lamps
(6) IS and RS residential ballasts that operate
(a) 4-foot MBP lamps
(b) 2-foot U-shaped lamps
(c) 4-foot T5 SO lamps
(d) 4-foot T5 HO lamps
(e) 8-foot SP slimline lamps
(7) PS residential ballasts that operate
(a) 4-foot MBP lamps
(b) 2-foot U-shaped lamps
(c) 4-foot T5 SO lamps
(d) 4-foot T5 HO lamps
(8) Dimming ballasts that operate
(a) 4-foot MBP lamps
(b) 2-foot U-shaped lamps
(c) 4-foot T5 SO lamps
(d) 4-foot T5 HO lamps
B. Engineering Analysis
In the engineering analysis, DOE selects representative product
classes to analyze, selects baseline ballasts within those
representative product classes, and identifies more-efficient
substitutes for the baseline ballasts. DOE uses these more-efficient
ballasts to develop efficiency levels.
For this proposed determination, DOE selected more efficient
substitutes in the engineering analysis and determined the consumer
prices of those substitutes in the product price determination. DOE
estimated the consumer price of ballasts directly because reverse-
engineering ballasts is impractical due to the use of potting, a black
pitch added to the ballast enclosure to reduce vibration damage and act
as a heat sink for the circuit board. Potting does not allow for the
visual observation and identification of individual components of the
ballast making it infeasible to apply a reverse-engineering approach.
By combining the results of the engineering analysis and the product
price determination, DOE derived typical inputs for use in the LCC
analysis and NIA. Section IV.C discusses the product price
determination (see chapter 6 of the NOPD TSD for further detail).
The methodology for the engineering analysis consists of the
following steps: (1) Selecting representative product classes, (2)
selecting baseline lamps, (3) identifying more efficient substitutes,
(4) developing efficiency levels by directly analyzing representative
product classes, and (5) scaling efficiency levels to non-
representative product classes. The details of the engineering analysis
are discussed in chapter 5 of the NOPD TSD.
1. Significant Data Sources
DOE received several comments on data used in the engineering
analysis. To ensure DOE analyzes currently available compliant
products, Philips advised DOE to only use ballasts in DOE's CCMS
database to analyze the performance of fixed output ballasts. (Philips,
No. 8 at p. 30) Regarding dimming ballasts, low-current PS ballasts, or
480 V ballasts, ULT and NEMA commented that these products have not
been evaluated in terms of efficiency or test method changes, and such
assessments are necessary to ensure a meaningful analysis. (ULT, No. 6
at p. 5; NEMA, No. 12 at p. 7)
CA IOUs suggested DOE take into account the analysis they had
conducted in support of developing CEC's proposed standards for
fluorescent lamp ballasts. CA IOUs stated that for this analysis they
tested 34 T8 dimming ballasts selected from 180 T8 dimming ballasts
listed by the CEE as qualifying commercial lighting products and
additionally tested seven T5 dimming ballasts. CA IOUs noted that this
testing, while not comprehensive of the full market, was a good
starting point. (CA IOUs, No. 10 at p. 8) Further, CA IOUs added that
it is likely that their analysis of efficiencies of low-current PS
dimming ballasts will also be useful in understanding the cathode
heating needs and determining appropriate standard levels for fixed-
output, low-current ballasts. (CA IOUs, No. 10 at p. 10)
For this analysis, DOE developed a database of ballasts based on
manufacturer catalogs and DOE's CCMS public database.\20\ For ballasts
currently subject to energy conservation standards, DOE used BLE values
in the CCMS database. For ballasts not subject to standards, BLE values
are not present in the CCMS database, and DOE determined BLE values
using catalog data. This method was used for low-current PS ballasts
and dimming ballasts designed and marketed to operate exclusively lamp
types other than one F34T12, two F34T12, two
[[Page 56557]]
F96T12/ES, or two F96T12HO/ES lamps.
---------------------------------------------------------------------------
\20\ Compliance data are publicly available on DOE's Compliance
Certification Database available at http://www.regulations.doe.gov/certification-data/.
---------------------------------------------------------------------------
DOE used the test data for dimming ballasts provided by CA IOUs to
understand the general performance of these types of ballasts. However,
for the engineering analysis DOE relied on catalog data as it allowed
for an analysis of all dimming products available on the market.
Further, because DOE considered only standards based on a BLE value at
full light output, it did not analyze BLEs at lower light outputs to
develop ELs.
Additionally, DOE paired baseline and more-efficient ballasts with
full-wattage and/or reduced-wattage lamps, where appropriate, to
reflect the most common configurations of lamp-and-ballast systems. DOE
reviewed the lamp market and identified performance characteristics
common for the chosen lamps and determined the system initial and mean
lumen outputs. The tables provided in the sections that follow specify
only the characteristics of the representative unit with a full
wattage-lamp. The complete list of pairings of lamps with selected
representative units is available in chapter 5 of the NOPD TSD.
2. Representative Product Classes
In the case where a covered product has multiple product classes,
DOE identifies and selects certain product classes as
``representative'' and concentrates its analytical effort on those
classes. For fluorescent lamp ballasts, DOE chose product classes as
representative primarily because of their high market volumes. Within
certain representative product classes, DOE also selected multiple
representative ballast types to account for multiple high volume units
within the same product class.
In response to the Framework document, Philips commented that most
dimming ballasts use a 0-10 V communication protocol and nearly all are
in the commercial sector especially if it includes retail space but
noted that they do not have full visibility into application-specific
dimming habits. (Philips, No. 8 at p. 33)
In selecting representative product classes, DOE took into account
comments from stakeholders and also reviewed product offerings and
feedback from manufacturer interviews regarding market shares of
ballast types. Based on its assessment, DOE analyzed as representative
6 product classes and 13 ballast types as shown (in grey shading) in
Table IV.2. This includes analyzing ballasts using a 0-10 V
communication protocol as representative in the dimming product class.
BILLING CODE 6450-01-P
[[Page 56558]]
[GRAPHIC] [TIFF OMITTED] TP22OC19.000
BILLING CODE 6450-01-C
3. Baseline Ballasts
For each representative product class, DOE selected a baseline
ballast as a reference point against which to measure changes resulting
from energy conservation standards. Typically the baseline ballast is
the most common, least efficient ballast that meets existing energy
conservation standards. In this analysis, DOE selected as baselines the
least efficient ballast meeting standards that operated the most common
lamp type (i.e., wattage and diameter) and where possible, has the most
common ballast factor, input voltage, and operating voltage type \21\
for the product class. DOE used the BLE values from the CCMS database
to identify baseline ballasts for all product classes except dimming.
Because most dimming ballasts are not currently subject to standards
and therefore do not have CCMS data, DOE determined BLE values by using
catalog input power and associated total lamp arc power based on the
catalog ballast factor of the ballast.
---------------------------------------------------------------------------
\21\ Operating voltage type denotes whether the ballast can
operate multiple voltages and is considered universal or can only
operate one voltage and is considered dedicated.
---------------------------------------------------------------------------
In summary, DOE directly analyzed the baseline ballasts shown in
Table
[[Page 56559]]
IV.3. See chapter 5 of the NOPD TSD for more detail.
Table--IV.3 Baseline Ballasts
--------------------------------------------------------------------------------------------------------------------------------------------------------
Input voltage/ Input
Product class Ballast type Lamp type Starting method operating voltage Power Ballast power BLE
* (V) factor factor (W)
--------------------------------------------------------------------------------------------------------------------------------------------------------
IS/RS Commercial................ 2L 4-foot MBP...... 32 W T8 IS 277, Universal..... 0.97 0.89 57.6 0.903
4L 4-foot MBP...... 32 W T8 IS 277, Universal..... 0.98 0.88 112.2 0.916
2L 8-foot SP 59 W T8 IS 277, Universal..... 0.98 0.88 109.2 0.920
slimline.
PS Commercial................... 2L 4-foot MBP...... 32 W T8 PS 277, Universal..... 0.90 0.88 57.1 0.900
4L 4-foot MBP...... 32 W T8 PS 277, Universal..... 0.90 0.87 110.5 0.920
2L 4-foot MiniBP SO 28 W T5 PS 277, Universal..... 0.98 1.00 62.4 0.891
2L 4-foot MiniBP HO 54 W T5 PS 277, Universal..... 0.98 0.99 116.8 0.912
IS/RS 8-foot HO................. 2L 8-foot RDC HO... 110 W T12 RS 277, Universal..... 0.99 0.89 197.7 0.900
Sign............................ 4L 8-foot RDC HO... 110 W T12 RS 120, Dedicated..... 0.90 ** 0.61 271.6 0.898
IS/RS Residential............... 2L 4-foot MBP...... 32 W T8 IS 120, Dedicated..... 0.50 0.88 58.9 0.872
Dimming......................... 2L 4-foot MBP 0-10V 32 W T8 PS 277, Universal..... 0.98 0.88 59.0 0.871
2L 4-foot MiniBP SO 28 W T5 PS 277, Universal..... 0.98 1.00 64.0 0.869
0-10V.
2L 4-foot MiniBP HO 54 W T5 PS 277, Universal..... 0.98 1.00 118.0 0.912
0-10V.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Universal indicates that the ballast can operate multiple voltages (i.e., 120 V or 277 V); dedicated indicates it can only operate the voltage
specified.
** DOE found limited information on ballast factors of ballasts in the Sign product class. Based on this information, DOE used the most common ballast
factor found in catalogs for the product class for representative units that did not specify ballast factor.
4. More-Efficient Substitutes
DOE selected more-efficient ballasts as replacements for each of
the baseline ballasts by considering technologies not eliminated in the
screening analysis. DOE considered these technologies in the
engineering analysis, either by modeling potential efficiency
improvements due to the design options or by analyzing commercially
available ballasts in which the design options are incorporated.
As fluorescent lamp ballasts are designed to operate fluorescent
lamps, DOE considered properties of the entire lamp-and-ballast system
in the engineering analysis. Fluorescent lamp ballasts are capable of
operating several different configurations and wattages of lamps, so
DOE chose the most common fluorescent lamp used with each ballast type
for analysis. Further, DOE selected a more-efficient fluorescent lamp
ballast with the same or similar ballast factor as the baseline
ballast, so that light output would be maintained without needing to
change the spacing of the fixture. Specifically, DOE ensured that
potential substitutes maintained the system light output within 10
percent of the baseline lamp-and-ballast system light output.
Finally, DOE selected more-efficient substitutes that showed an
improvement in BLE and a reduction in input power. As with the baseline
ballasts, DOE used the BLE values from the CCMS database for all
product classes except those dimming classes which are not currently
subject to standards and therefore do not have CCMS data. For dimming
ballasts, DOE determined BLE values by using catalog input power and
associated total lamp arc power based on the catalog ballast factor of
the ballast.
ULT and NEMA commented that the data manufacturers submit to DOE's
CCMS database should be reproducible and, therefore, could be used in
modeling. (ULT, No. 6 at p. 6; NEMA, No. 12 at p. 8) Regarding modeling
potential system efficiency, NEMA and ULT encouraged DOE to take into
account factors such as form factor, ability to reproduce in
manufacturing, and tolerance of all incorporated parts, and then
conduct physical tests of any models and design projections not
available in the market or dismiss them from analysis. (NEMA, No. 12 at
p. 7; ULT, No. 6 at p. 6) ULT also asserted that the HID rulemaking had
modeled products at efficiency levels that could not be manufactured.
(ULT, Public Meeting Transcript, No. 5 at p. 70)
When evaluating more-efficient substitutes, DOE can model potential
efficiency improvements based on design options identified in the
screening analysis. As noted in section IV.A.4, the technology options
identified as design options must be technologically feasible;
practicable to manufacture, install, and service; have no adverse
impacts on product utility or product availability; and have no adverse
impacts on health or safety.
For the IS/RS 2L 8-foot SP slimline representative ballast type,
DOE modeled a representative unit at EL 3 (EL values are provided in
Table IV.4). As noted, in most cases BLE increases with increasing
total lamp arc power for fluorescent lamp ballasts. DOE found that 4L
4-foot MBP ballasts, which operate similar total lamp arc powers as 2L
8-foot SP slimline ballasts, are able to meet EL 3. Further, DOE found
that ballasts operating 2L 8-foot T12 SP slimline lamps also meet EL 3.
Therefore, DOE determined that design options in commercially available
ballasts meeting EL 3 could be applied to a ballast operating two 8-
foot T8 SP slimline lamps to achieve a higher efficiency. DOE assumed
the modeled ballast would have characteristics common to the product
class such as universal operating voltage, normal ballast factor, and
0.98 power factor (PF). Using a common ballast factor for the product
class, DOE determined the lamp arc power and BLE for a ballast
operating two 8-foot T8 SP slimline lamps that would meet EL 3. The
performance characteristics of the modeled 2L 8-foot SP slimline
ballast are shown in Table IV.4.
ULT and NEMA stated that while reduced-wattage lamp-and-ballast
systems are common and the first step to offering higher energy
savings, the ballasts in these systems have added features that make
them less efficient. ULT noted that ballasts designed to operate
reduced-wattage lamps require higher open circuit voltages and flicker
control. (ULT, No. 6 at p. 7; ULT, Public Meeting Transcript, No. 5 at
pp. 82-83; NEMA, No. 12 at p. 9)
As noted previously, DOE chose baseline and more-efficient
substitute representative units that operate the most common lamps,
which in many cases are full-wattage lamps. DOE's review of products in
the market indicates that highly efficient ballasts operating full-
wattage lamps can also operate reduced-wattage lamps. DOE notes sign
ballasts as an exception, which predominantly operate full-wattage 8-
foot T12 recessed double contact (RDC) HO lamps and have limited
reduced-wattage options. Therefore, the analysis accounts for any
[[Page 56560]]
potential impacts on efficiency due to added features required for
operating reduced-wattage lamps.
ASAP recommended that reference lamps rather than ballast
manufacturer's specified lamps be used in DOE's analysis of total
system energy consumption of the lamp-and-ballast system. (ASAP, Public
Meeting Transcript, No. 5 at pp. 71-72)
DOE paired baseline and more-efficient ballasts with full-wattage
and/or reduced-wattage lamps, where appropriate, to reflect the most
common configurations of lamp-and-ballast systems. DOE reviewed the
lamp market and identified performance characteristics common for the
chosen lamps and determined the system initial and mean lumen outputs.
The complete list of pairings of lamps with selected representative
units is available in chapter 5 of the NOPD TSD.
5. Efficiency Levels
After identifying more-efficient substitutes for each of the
baseline ballasts, DOE developed ELs based on the consideration of
several factors, including: (1) The design options associated with the
specific ballasts being studied, (2) the ability of ballasts across
wattages to comply with the standard level of a given product class,
and (3) the max-tech level.
In this analysis, DOE used the same equation-based approach used in
the 2011 FL Ballast Rule. DOE determined that a power law equation best
modeled the observed trend between total lamp arc power and average
BLE. Specifically, DOE used the following equation that relates the
total lamp arc power operated by a ballast to BLE to develop ELs:
[GRAPHIC] [TIFF OMITTED] TP22OC19.001
where power = average total lamp arc power and A, B, and C are
constants that vary by product class.
DOE conducted extensive testing in the 2011 FL Ballast Rule to
develop the above equation. Based on this testing, DOE determined the
exponent C, which relates power to ballast losses, to be 0.25 for the
IS starting method and 0.37 for the PS starting method. Further, DOE
applied an adjustment factor A to reflect BLE values representative of
testing at the average test lab. DOE developed coefficient B based on
the tested BLE values for each product class and adjusted it to reflect
different levels of efficiencies based on representative
characteristics of the product class. Based on DOE's analysis of data
in this proposed determination, DOE determined that the methodology
used in the 2011 FL Ballast Rule to determine exponent C and adjustment
factor A remain valid.
DOE received some general comments on ballast efficiency levels.
ASAP stated that the shift to solid-state lighting will come with
higher costs of drivers and light sources, and fluorescent lamp
ballasts should not become the lowest common denominator in terms of
price and performance. (ASAP, Public Meeting Transcript, No. 5 at pp.
31-32) ULT and NEMA commented that because manufacturing was close to
the implementation date of the last rulemaking, all products on the
market manufactured after November 2014 will be at the minimum or
slightly higher than the minimum BLE standard. Therefore, these
products reflect both the minimum and maximum technology efficiency
levels. (ULT, No. 6 at p. 5; NEMA, No. 12 at p. 7) Philips agreed that
ballast technology is already close to its maximum potential. (Philips,
No. 8 at p. 15)
DOE identified several commercially available ballasts performing
at efficiency levels higher than existing standards. The efficiencies
determined from manufacturer catalogs and certification data indicate
several efficiency levels higher than the existing standard. Thus,
manufacturers appear to be utilizing more advanced technologies than
required to just meet the standard level.
DOE based initial ELs on the more-efficient representative units
selected for each product class. For product classes with multiple
representative ballast types, DOE established ELs after considering the
representative units of all representative ballast types in the product
class.
To establish final minimum efficiency requirements for each EL, DOE
evaluated whether any adjustments were necessary to the initial ELs to
ensure ballasts were available across a range of lamp arc powers and
ballast factors representative of each product class. For example, DOE
found ballasts operating certain lamp arc powers or ballasts factors do
not meet the highest efficiency level. DOE reviewed these products and
found they are low volume and are likely not using the most recent
advanced technologies. Some of them operated a total lamp arc power
that was between the total lamp arc powers operated by ballasts that
did comply with the highest standard level analyzed. Based on this
review, these FLBs appear to not have been fully optimized to achieve
the highest efficiency levels, and can be improved. Based on its
observations and analysis, DOE tentatively determined that no
additional adjustments to the initial ELs were necessary.
The ELs and characteristics of the representative units are
summarized in Table IV.4 through Table IV.9. Grey shading indicates the
modeled unit for the two-lamp 8-foot SP slimline representative ballast
type operating a T8 lamp. See chapter 5 of the NOPD TSD for more
detail.
BILLING CODE 6450-01-P
[[Page 56561]]
[GRAPHIC] [TIFF OMITTED] TP22OC19.002
As shown in Table IV.4 for the IS/RS commercial representative
product class, three ELs are analyzed. The baseline, presented in Table
IV.3, represents a basic ballast with an efficiency near the existing
standard level. EL 1 represents an improved ballast with more-efficient
components (e.g., transformers, diodes, capacitors, transistors) that
minimize losses and circuit design (e.g., integrated circuitry). EL 2
represents an advanced ballast with improved components and improved
circuit design. EL 3 is the maximum technologically feasible level and
represents a ballast with the most efficient combination of improved
components and circuit design.
Table IV.5--PS Commercial Representative Units
--------------------------------------------------------------------------------------------------------------------------------------------------------
Input voltage/ Input
Product class EL Ballast type Lamp type Starting operating Power Ballast power BLE
method voltage * (V) factor factor (W)
--------------------------------------------------------------------------------------------------------------------------------------------------------
PS Commercial................ EL 1 2L 4-foot MBP... 32 W T8 PS 277, Universal. 0.97 0.88 56.3 0.913
4L 4-foot MBP... 32 W T8 PS 277, Universal. 0.98 0.87 109.5 0.928
2L 4-foot MiniBP 28 W T5 PS 277, Universal. 0.98 1.00 61.4 0.905
SO.
2L 4-foot MiniBP 54 W T5 PS 277, Universal. 0.97 1.00 115.9 0.928
HO.
EL 2 2L 4-foot MBP... 32 W T8 PS 277, Universal. 0.98 0.88 53.9 0.953
4L 4-foot MBP... 32 W T8 PS 277, Universal. 0.99 0.87 107.6 0.944
2L 4-foot MiniBP 28 W T5 PS 277, Universal. 0.98 1.00 59.8 0.929
SO.
2L 4-foot MiniBP 54 W T5 PS 277, Universal. 0.98 1.00 113.6 0.947
HO.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Universal indicates that the ballast can operate multiple voltages (i.e., 120 V or 277 V).
As shown in Table IV.5 for the PS commercial product class, two ELs
are analyzed. The baseline, presented in Table IV.3, represents a basic
ballast with an efficiency near the existing standard level. EL 1
represents an improved ballast with more-efficient components (e.g.,
transformers, diodes, capacitors, transistors) that minimize losses and
circuit design (e.g., integrated circuitry). EL 2 is the maximum
technologically feasible level and represents a ballast with the most
efficient combination of improved components and circuit design.
[[Page 56562]]
[GRAPHIC] [TIFF OMITTED] TP22OC19.003
As shown in Table IV.6 for the IS 8-foot HO commercial product
class, two ELs are analyzed. The baseline, presented in Table IV.3,
represents a basic ballast with an efficiency near the existing
standard level. EL 1 represents an improved ballast with more-efficient
components (e.g., transformers, diodes, capacitors, transistors) that
minimize losses and circuit design (e.g., use of cathode cutout
technology, integrated circuitry). EL 2 is the maximum technologically
feasible level and represents a ballast with the most efficient
combination of improved components and circuit design.
Table IV.7--Sign Representative Units
--------------------------------------------------------------------------------------------------------------------------------------------------------
Input voltage/ Ballast Input
Product class EL Ballast type Lamp type Starting operating Power factor power BLE
method voltage * (V) factor ** (W)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Sign......................... EL 1 4L 8-foot RDC HO 110 W T12 IS 120, Dedicated. 0.99 0.61 265.1 0.920
EL 2 4L 8-foot RDC HO 110 W T12 IS 120, Dedicated. 0.90 0.61 258.4 0.944
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Dedicated indicates it can only operate the voltage specified.
** DOE found limited information for ballast factor, and therefore used the most common ballast factor found in product class for representative units
that did not specify ballast factor.
As shown in Table IV.7 for the sign product class, two ELs are
analyzed. The baseline, presented in Table IV.3, represents a basic
ballast with an efficiency near the existing standard level. EL 1
represents an improved ballast with more-efficient components (e.g.,
transformers, diodes, capacitors, transistors) that minimize losses and
circuit design (e.g., integrated circuitry). EL 2 is the maximum
technologically feasible level and represents a ballast with the most
efficient combination of improved components and circuit design.
Table IV.8--IS/RS Residential Representative Units
--------------------------------------------------------------------------------------------------------------------------------------------------------
Input voltage/ Input
Product class EL Ballast type Lamp type Starting operating Power Ballast power BLE
method voltage * (V) factor factor (W)
--------------------------------------------------------------------------------------------------------------------------------------------------------
IS/RS Residential............ EL 1 2L 4-foot MBP... 32 W T8 IS 120, Dedicated. 0.56 0.85 56.2 0.884
EL 2 2L 4-foot MBP... 32 W T8 IS 120, Dedicated. 0.56 0.85 55.2 0.899
EL 3 2L 4-foot MBP... 32 W T8 IS 120, Dedicated. 0.55 0.83 53.1 0.913
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Dedicated indicates it can only operate the voltage specified.
As shown in Table IV.8 for the IS/RS residential product class,
three ELs are analyzed. The baseline, presented in Table IV.3,
represents a basic ballast with an efficiency near the existing
standard level. EL 1 represents an improved ballast with more-efficient
components (e.g., transformers, diodes, capacitors, transistors) that
minimize losses and circuit design (e.g., integrated circuitry). EL 2
represents an advanced ballast with improved components and improved
circuit design. EL 3 is the maximum technologically feasible level and
represents a ballast with the most efficient combination of improved
components and circuit design.
CA IOUs stated DOE has the opportunity to capture significant
energy savings by raising standards for residential ballasts to levels
closer to those of commercial ballasts. (CA IOUs, No. 10 at p. 1) ASAP
agreed that DOE should reassess the market and set more appropriate
levels for residential ballasts to capture additional energy savings.
(ASAP, No. 7 at p. 4)
Based on DOE's review of ballast efficiencies discussed previously,
residential ballasts are unable to achieve maximum efficiencies similar
to commercial ballasts. DOE identified the more-efficient substitute
representative units for residential ballasts and identified the
efficiency levels specified in Table IV.8. Based on the methodology and
data, DOE finds these efficiency levels to be appropriate for the
residential ballast product class.
[[Page 56563]]
[GRAPHIC] [TIFF OMITTED] TP22OC19.004
BILLING CODE 6450-01-C
As shown in Table IV.9 for the dimming product class, three ELs are
analyzed. The baseline, presented in Table IV.3, represents a basic
ballast with an efficiency near the existing standard level. EL 1
represents an improved ballast with more-efficient components (e.g.,
transformers, diodes, capacitors, transistors) that minimize losses and
circuit design (e.g., use of cathode cutout technology, integrated
circuitry). EL 2 represents an advanced ballast with improved
components and improved circuit design. EL 3 is the maximum
technologically feasible level and represents a ballast with the most
efficient combination of improved components and circuit design.
CA IOUs requested DOE review their work in support of developing
CEC's standards for dimming ballasts and noted that they have provided
numerous associated documents to the docket of this rulemaking
including results from testing performance of dimming ballasts from 100
percent full light output down to the minimum dimming level where the
lamp is still producing light. (CA IOUs, Public Meeting Transcript, No.
5 at pp. 72-73; CA IOUs, No. 10 at p. 2) CA IOUs stated that while they
supported DOE's consideration of dimming ballasts for standards, they
recommended that DOE not adopt a less stringent standard than the one
proposed by CEC for dimming ballasts. (CA IOUs, No. 10 at p. 2)
However, NEMA stated that DOE should not simply implement the
standards proposed by CEC for T8 and T5 dimming ballasts because if
those dimming ballasts were tested using DOE's current test method, no
dimming ballasts would be available for sale in the United States.
(NEMA, Public Meeting Transcript, No. 5 at pp. 9-11) Lutron asserted
that the market in California will be driving dimming ballast sales as
it is the only state that has building code requirements for dimming
ballasts. Therefore, Lutron questioned the need for standards stricter
than those already adopted by California for dimming ballasts as no one
will manufacture separate products for California and the rest of the
country. (Lutron, Public Meeting Transcript, No. 5 at pp. 61-62)
DOE recognizes that certain products evaluated for this NOPD may be
subject to State regulation. As noted, DOE is conducting this
evaluation of FLB pursuant to the direction in EPCA (see section II.A).
Consistent with that statutory direction DOE is evaluating a potential
standard for dimming ballasts
[[Page 56564]]
based on BLE at full light output rather than based on a weighted
metric.
Table IV.10 summarizes the efficiency requirements at each EL for
the representative product classes. DOE seeks comment on the ELs under
consideration for the representative product classes, including the max
tech levels. See section VII.C for a list of issues on which DOE seeks
comment.
Table IV.10--Summary of ELs for Representative Product Classes
----------------------------------------------------------------------------------------------------------------
BLE = A/(1+B*total lamp arc power[caret]-C)
where A, B, and C are as follows:
Representative product class Efficiency level -----------------------------------------------
A B C
----------------------------------------------------------------------------------------------------------------
IS/RS Commercial...................... EL 1.................... 0.993 0.24 0.25
EL 2.................... .............. 0.21 ..............
EL 3.................... .............. 0.16 ..............
PS Commercial......................... EL 1.................... 0.993 0.43 0.37
EL 2.................... .............. 0.31 ..............
IS/RS Residential..................... EL 1.................... 0.993 0.33 0.25
EL 2.................... .............. 0.28 ..............
EL 3.................... .............. 0.24 ..............
IS/RS 8-foot HO....................... EL 1.................... 0.993 0.24 0.25
EL 2.................... .............. 0.14 ..............
Sign.................................. EL 1.................... 0.993 0.32 0.25
EL 2.................... .............. 0.24 ..............
Dimming............................... EL 1.................... 0.993 0.56 0.37
EL 2.................... .............. 0.48 ..............
EL 3.................... .............. 0.40 ..............
----------------------------------------------------------------------------------------------------------------
6. Scaling to Other Product Classes
DOE identified and selected certain product classes as
representative and analyzed these product classes directly. DOE chose
these representative product classes primarily due to their high market
volumes. The ELs for product classes that were not directly analyzed
(``non-representative product classes'') were then determined by
scaling the ELs of the representative product classes. Specifically,
DOE did not analyze PS 8-foot HO ballasts or PS residential ballasts
directly. NEMA and ULT recommended that DOE test all products to be
covered because scaling may not produce the correct values. (NEMA, No.
12 at p. 8; ULT, No. 6 at p. 6)
In this analysis, DOE developed ELs for the PS 8-foot HO product
class by scaling the ELs of the IS/RS 8-foot HO product class and the
ELs for PS residential product class by scaling the ELs of the IS/RS
residential product class. The primary difference between these sets of
product classes is the starting method. Hence, DOE developed scaling
factors by identifying pairs of the same ballast type manufactured by
the same manufacturer, within the same product family, that differed
only by starting method. The tested and certified efficiency values
submitted to the DOE CCMS as well as manufacturer catalog data for
these ballast pairs were used to calculate the scaling factors. From
this analysis DOE determined that the ballasts with a PS starting
method are 2 percent less efficient than those with IS starting method.
DOE then applied this reduction in BLE to develop the appropriate EL
equation curves for the PS 8-foot HO and PS residential product class.
Because it is based on tested CCMS and manufacturer-provided catalog
values, DOE has tentatively determined that this an accurate method for
developing the ELs of the PS 8-foot HO and PS residential product
classes. See chapter 5 of the NOPD TSD for more details.
Table IV.11 summarizes the efficiency requirements at each EL for
the non-representative product classes. DOE seeks comment on the ELs
under consideration for the non-representative product classes,
including the max-tech levels. See section VII.C for a list of issues
on which DOE seeks comment.
Table IV.11--Summary of ELs for Non-Representative Product Classes
----------------------------------------------------------------------------------------------------------------
BLE = A/(1+B*total lamp arc power[caret]-C)
where A, B, and C are as follows:
Non-representative product class Efficiency level -----------------------------------------------
A B C
----------------------------------------------------------------------------------------------------------------
PS 8-foot HO.......................... EL 1.................... 0.973 0.45 0.37
EL 2.................... .............. 0.26 ..............
PS Residential........................ EL 1.................... 0.973 0.54 0.37
EL 2.................... .............. 0.46 ..............
EL 3.................... .............. 0.39 ..............
----------------------------------------------------------------------------------------------------------------
7. Proprietary Designs
In the Framework document, DOE explained it would consider in its
engineering and economic analyses all design options that are
commercially available or present in a working prototype, including
proprietary designs, that meet the screening criteria discussed in
section IV.A.4. DOE will consider a proprietary design in the
subsequent analysis only if it does not represent a unique path to a
given efficiency level. If the proprietary design is the only approach
available to achieve a given efficiency level, then DOE will eliminate
the efficiency level from further analysis. However, if the efficiency
level can be achieved by a number of design approaches, including a
proprietary design, DOE will continue to examine the given efficiency
level.
[[Page 56565]]
NEMA and ULT commented that as long as DOE follows the methodology
laid out in the Framework document, they will not have an issue with
the examination of proprietary designs. (NEMA, No. 12 at p. 8; ULT, No.
6 at p. 6) NEMA reiterated its comments made in CEC rulemaking
proceedings on cathode cutout that there may be various interlinked
patents regarding cathode cutout and encouraged DOE to exercise caution
not to inadvertently favor one patented method over another. (NEMA,
Public Meeting Transcript, No. 5 at pp. 58-59)
DOE received feedback in manufacturer interviews that while there
are various patents related to ballast efficiency, the efficiencies of
ballasts can be improved without reliance on a patented technology. DOE
is not aware of any efficiency level under consideration that can only
be achieved by a proprietary design.
C. Product Price Determination
Typically, DOE develops manufacturer selling prices (MSPs) for
covered products and applies markups to create end-user prices to use
as inputs to the LCC analysis and NIA. Because fluorescent lamp
ballasts are difficult to reverse-engineer (i.e., not easily
disassembled due to potting), DOE directly derives end-user prices for
the ballasts covered in this proposed determination.
In the Framework document, DOE stated that for commercial and
industrial ballast designs, fluorescent lamp ballasts can go through
two types of distribution channels: sold within fixtures and sold as
replacement ballasts. In the fixture distribution channel, the
manufacturer sells the ballast to an OEM--in this case, the fixture
manufacturer--who in turn sells the ballast in a fixture to an
electrical wholesaler (i.e., distributor). The distributor sells it to
a contractor, who passes it on to the end-user. In the replacement
distribution channel, the manufacturer sells the ballast to an
electrical wholesaler, who sells it to a contractor, who passes it on
to the end-user. For residential ballast designs, DOE assumes that the
manufacturer sells the ballast to an OEM who in turn sells it in a
fixture to a home improvement retailer, where it is purchased by the
consumer.
GE commented that the distribution channels considered in the
Framework document analysis are similar to the 2011 FL Ballast Rule and
appear to be appropriate. (GE, Public Meeting Transcript, No. 5 at p.
91) Philips agreed that the value chain had been accurately mapped out.
(Philips, No. 8 at p. 34)
In this analysis, DOE retained the basic structure of distribution
channels described in the Framework document with minor modifications
based on additional research and information learned through
manufacturer interviews. DOE determined that ballasts can be sold by
electrical wholesalers to the end-user in large volume via a
contractor; in large volume without a contractor; and in low volume
without a contractor (e.g., homeowners). Based on estimated shipments,
DOE assigned a weighting of 85 percent for large volume via contractor;
10 percent for large volume without a contractor; and 5 percent for low
volume without a contractor. DOE accounted for all three scenarios in
developing end-user prices for representative units identified in the
engineering analysis.
ULT and NEMA commented that the best way to understand the cost of
products is to work with individual manufacturers under a
confidentiality agreement. They stated that teardown analysis or
bottom-up analysis would be difficult because of the use of potting
material in ballast design, which is still very common. (ULT, Public
Meeting Transcript, No. 5 at p. 75; ULT, No. 6 at p. 6; NEMA, No. 12 at
p. 8) Philips commented that product teardowns should not be used for
market pricing predictions, but only for possible product manufacturing
cost analysis and reverse engineering because market prices are not
determined on a cost plus basis. Further, Philips noted that while blue
book prices may be directionally accurate, they will not account for
additional discounts and pricing programs available in the value chain.
Philips commented that NEMA data on market units and dollars could be
useful in making pricing assumptions and suggested DOE work directly
with NEMA to obtain relevant data by channel, and if that was not
possible they could provide DOE with their local market analysis
expert. (Philips, No. 8 at pp. 30, 34)
DOE was unable to obtain blue book prices (i.e., manufacturer
suggested prices) for ballasts and did not utilize the teardown
approach due to use of potting in ballasts. To develop end-user prices
for fluorescent lamp ballasts, DOE began with a consistent set of
prices by determining an average electrical wholesaler price for each
representative unit. DOE determined that in addition to electrical
distributors such as Grainger, internet retailers can also serve as
wholesalers of fluorescent lamp ballasts. Therefore, DOE collected
prices from electrical distributors and internet retailers for each
representative unit and/or ballast with similar performance
characteristics to develop an average wholesaler price.
For the replacement channel, DOE used this average wholesaler price
to determine the end-user prices for ballasts going through each
wholesaler pathway: Large volume (no contractor), large volume (with
contractor), and low volume (no contractor). DOE used the average
wholesaler price as the large volume (no contractor) end-user price.
DOE applied a contractor markup of 13 percent to the average wholesaler
price to develop the large volume (with contractor) end-user price. DOE
determined that ballasts sold through the low volume pathway would be
sold by home centers. However, DOE found limited price data for
representative units at home centers. Therefore, based on manufacturer
feedback DOE applied an estimated 20 percent markup to the average
wholesaler price to determine the low volume (no contractor) consumer
price. DOE then weighted the large volume (with contractor) price by 85
percent; large volume (no contractor) price by 10 percent; and low
volume (no contractor) price by 5 percent to develop an average
weighted end-user price for each representative unit.
For the fixture channel, DOE applied an OEM markup of 21 percent to
the average weighted end-user price determined for the replacement
channel.
Based on manufacturer feedback, DOE determined that the estimated
shipments going through the replacement channel and fixture channel are
each 50 percent. DOE applied this weighting to the average end-user
prices for the replacement and OEM channels to develop the final end-
user price of a representative unit. Once DOE calculated end-user
prices, DOE added sales tax and, if appropriate, installation costs to
derive the total, installed end-user cost. See chapter 6 of the NOPD
TSD for pricing results and further details on the pricing methodology.
DOE received comments on price trends for dimming ballasts.
Although CA IOUs and CEC used slightly different methods to understand
the cost effectiveness of dimming ballasts, CA IOUs stated that both
methods showed cost-effective results. They encouraged DOE to review
both CEC methodology, which was more similar to a tear down approach,
and the CA IOU methodology, which was more of a statistical analysis of
ballast prices on the market. (CA IOUs, Public Meeting Transcript, No.
5 at p. 75)
CA IOUs stated that they completed a multivariable regression
analysis on dimming fluorescent lamp ballasts
[[Page 56566]]
available from online retailers to evaluate cost effectiveness of a
standard for dimming ballasts. Through this research, CA IOUs found no
statistical correlation between product efficiency and price, but
rather the results of the regression model suggested that dimming FLB
price is more strongly correlated to manufacturer, how many lamps it
can operate, and whether or not it is digitally controllable, rather
than efficiency. CA IOUs referred to a graphical representation of data
they had collected, which indicated that there is no clear trend
suggesting that higher efficiency ballasts are generally more expensive
than lower efficiency ballasts. CEC's cost-effectiveness evaluation
focused on the cost of implementing cathode cutout technology to make
the dimming ballasts more efficient. Based on the TSD from the 2011 FL
Ballast Rule, CEC assumed that the incremental cost of cathode cutout
was $0.89 for a 2-lamp ballast, which was scaled by $0.10 per lamp,
resulting in the highest incremental cost for a 4-lamp ballast as
$1.09. (CA IOUs, No. 10 at pp. 8-9)
In the product price determination, DOE developed end-user prices
for each representative unit. As noted in the engineering analysis,
these representative ballasts incorporate the design options to achieve
the EL under consideration. Therefore, DOE's end-user prices would
include the use of the cathode cutout design option used in a
representative unit. DOE's evaluation of prices for dimming ballasts
indicate that end-user price does increase with the efficiency of
dimming ballast. Further, in interviews, manufacturers indicated that
generally all things considered equal, prices will increase with FLB
efficiency. DOE seeks comment on the methodology and results for
estimating end-user prices for fluorescent lamp ballasts in this
analysis. See section VII.C for a list of issues on which DOE seeks
comment. Chapter 6 of the NOPD TSD provides details on DOE's
development of end-user prices for fluorescent lamp ballasts.
D. Energy Use Analysis
The purpose of the energy use analysis is to determine the annual
energy consumption of fluorescent lamp ballasts at different BLE in
representative U.S. commercial and industrial buildings, outdoor
installations, and single-family homes and multi-family residences, and
to assess the energy savings potential of increased BLE for fluorescent
lamp ballasts. The energy use analysis estimates the range of energy
use of fluorescent lamp ballasts in the field (i.e., as they are
actually used by consumers). The energy use analysis provides the basis
for other analyses DOE performed, particularly assessments of the
energy savings and the savings in consumer operating costs that could
result from adoption of amended standards.
The energy conservation standards for fluorescent lamps are not
within the scope of this analysis; however, the input power of the
complete lamp-and-ballast system is considered for the energy use
analysis because ballasts are not intended to operate without lamps.
The energy use characterization provides estimates of annual energy use
for representative lamp-and-ballast systems that DOE evaluates in the
LCC and PBP analyses and the NIA. To develop annual energy use
estimates, DOE multiplied annual usage (in hours per year) by the
system input power (in watts).
DOE selected the most common fluorescent lamps used with each
analyzed ballast to develop representative lamp-and-ballast systems.
DOE developed the system input power estimates in the engineering
analysis. To characterize the country's average use of fluorescent lamp
ballasts for a typical year, DOE developed annual operating hours by
sector, using data from the 2015 U.S. Lighting Market Characterization
(LMC), which was published in 2017.\22\
---------------------------------------------------------------------------
\22\ U.S. Department of Energy-Office of Energy Efficiency and
Renewable Energy. 2015 U.S. Lighting Market Characterization.
November 2017. https://energy.gov/eere/ssl/2015-us-lighting-market-characterization.
---------------------------------------------------------------------------
Philips stated that it was unclear how DOE would assign each
ballast type into one or more sectors. Many types of ballasts can be
used in both commercial and industrial applications that would affect
their usage profile. Philips expected DOE to use an appropriate method
to assign the different ballasts the various sectors. (Philips, No. 8
at p. 31) DOE agrees that fluorescent lamp ballasts are used in many
applications, and a single ballast model could be used within different
sectors. In chapter 7 of the NOPD TSD, DOE analyzed the typical
operating hours of the different sectors. DOE then weighted the ballast
operation by sector to develop average operating hours.
1. Reduced Wattage Fluorescent Lamps
ULT stated that the use of reduced wattage (also known as energy
saving) lamps in the marketplace is very common. (ULT, No. 6 at p. 7)
NEMA, SCE, and ULT stated that reduced wattage lamps are the first step
in energy savings for a large portion of the market. (NEMA, No. 12 at
p. 9; SCE, Public Meeting Transcript, No. 5 at pp. 81-82; ULT, No. 6 at
p. 7) DOE agrees and modeled a mixture of full wattage and multiple
reduced wattage options (where they exist) for many of the fluorescent
lamps operated by the fluorescent lamp ballasts. See chapter 5 of the
NOPD TSD for more details.
2. Occupancy Sensors
NEMA and ULT stated that occupancy sensors will be in the off mode
more than the on mode with the exception of those installed in offices.
In general, these are installed in areas that are not frequently
occupied. Spaces can include but are not limited to bathrooms,
stairwells, closets, hallways, and warehouse aisles, where sensors are
off most of the time. For occupancy sensors used in offices to turn
lights off after a preset time of inactivity, the time in the on mode
would be difficult to generalize because it would differ greatly from
installation to installation. (NEMA, No. 12 at p. 4; ULT, No. 6 at p.
8) NEMA and Lutron directed DOE to review work conducted by Lawrence
Berkeley National Laboratory (LBNL) for additional data on occupancy
sensors.\23\ (NEMA, No. 12 at pp. 9-10; Lutron, No. 9 at pp. 2-3) DOE
reviewed the LBNL reports and one report specifically mentioned by
Lutron states that energy savings from occupancy controls per zone were
27 percent. However, savings primarily occurred at night between 6 p.m.
and 1 a.m. and during early morning and evening hours when occupancy
tended to be irregular.\24\
---------------------------------------------------------------------------
\23\ A technical publications list is available at Lawrence
Berkeley National Laboratory. DOE relied primarily on A Meta-
Analysis of Energy Savings from Lighting Controls in Commercial
Buildings, available at https://eta.lbl.gov/publications/meta-analysis-energy-savings-lighting.
\24\ Lawrence Berkeley National Laboratory. Monitored Lighting
Energy Savings from Dimmable Lighting Controls in the New York Times
Headquarters Building. 2013. Available at https://windows.lbl.gov/publications/monitored-lighting-energy-savings-dimmable-lighting-controls-new-york-times.
---------------------------------------------------------------------------
DOE stated in the Framework document that in the 2011 FL Ballast
Rule, DOE adjusted the annual operating hours for the ballasts in the
commercial sector that are controlled by occupancy sensors by roughly
30 percent compared to the other ballasts. Lutron and NEMA stated that
reduced hours are high for intelligent systems using dimming ballasts
with multiple control types. Occupancy sensors and time clock operation
have the potential to dramatically reduce operating hours. For this
analysis, DOE also reduced the operating hours for MBP lamps in the PS
commercial product class by 30
[[Page 56567]]
percent to account for the use of occupancy sensors.
NEMA and ULT stated that operating hours can vary for the same
model of a ballast installed in different applications. NEMA and ULT
suggested that it would be best to develop an average usage number to
apply to ballasts and that to figure all scenarios would be virtually
impossible. (NEMA, No. 12 at p. 9; ULT, No. 6 at p. 7) DOE agrees and
assigned a single average usage to each of the different ballast types.
Within the LCC analysis, DOE includes a distribution of operating hours
in the Crystal Ball \TM\ (a commercially available software program)
analysis used to determine the average LCC savings as well as the
percentage of net customers experiencing a net cost. Resultant average
values calculated from the Crystal Ball \TM\ distributions were used in
the NIA.
3. Dimming Ballasts
During the framework public meeting, both GE and CA IOUs stated
that dimming ballasts will have an operating profile different from
fixed-output (non-dimming) ballasts. Dimming ballasts are typically
operating in advanced systems, and as a result, might have fewer
operating hours or be operating in a dim mode compared to a standard
static system. GE stated that dimming ballasts will have a lower energy
use profile, which might be difficult to determine, but it will be less
than a non-dimming ballast profile of 100 percent output, 100 percent
of the time. (GE, Public Meeting Transcript, No. 5 at pp. 78-79, 88-89;
CA IOUs, Public Meeting Transcript, No. 5 at p. 89)
To develop the energy usage profile for dimming ballasts, DOE
reviewed A Meta-Analysis of Energy Savings from Lighting Controls in
Commercial Buildings by LBNL.\25\ GE suggested this document as a
potential source on the effects of controls on lighting systems but
cautioned that there is a broad range of results from even the same
control type. (GE, Public Meeting Transcript, No. 5 at pp. 86-87)
Lutron also stated during the public meeting that they would provide
references in written comments. (Lutron, Public Meeting Transcript, No.
5 at p. 88) Lutron and NEMA both referenced in written comments an LBNL
study on energy savings using controls with dimming ballasts. (Lutron,
No. 10 at p. 3; NEMA, No. 12 at p. 10) The LBNL study referenced in the
written comments is a different version but includes the same data as
the LBNL meta-analysis previously cited.\26\
---------------------------------------------------------------------------
\25\ Lawrence Berkeley National Laboratory. A Meta-Analysis of
Energy Savings from Lighting Controls in Commercial Buildings.
Available at https://eta.lbl.gov/publications/meta-analysis-energy-savings-lighting.
\26\ Williams et al. Lighting Controls in Commercial Buildings.
Leukos: The Journal of the Illuminating Engineering Society. 2012.
8(3): pp. 161-180. Available at https://eaei.lbl.gov/publications/lighting-controls-commercial.
---------------------------------------------------------------------------
DOE reviewed the meta-analysis and found that Tables 3 and 4 in the
LBNL study present the average savings for each control type by
building and by control type for peer-reviewed and non-peer-reviewed
papers, respectively. Energy savings greater than 30 percent were
common from daylighting and personal tuning (controls typically
utilizing dimming technology).
Lutron and NEMA stated that dimming ballasts and associated
controls and sensors have the potential to save energy in the form of a
reduced load and not solely in the reduction of operating hours.
(Lutron, No. 10 at p. 3; NEMA, No. 12 at p. 10) DOE agrees and
developed a duty cycle of operation to characterize the energy use of
the dimming ballast.
Southern California Edison (SCE) suggested that DOE consider
dimming ballasts operating below 50 percent. (SCE, Public Meeting
Transcript, No. 5 at pp. 38-39) CA IOUs recommended that DOE review
documents generated for and submitted to CEC's efforts to develop state
requirements for dimming ballasts. CA IOUs submitted these documents to
DOE as part of their written comments. (CA IOUs, No. 10 at p. 2) In
addition, CA IOUs stated that California's duty cycle for fluorescent
dimming ballasts was designed to coincide with elements in California's
energy code, Title 24, and involves output at 100 percent, 80 percent,
and 50 percent light output. (CA IOUs, Public Meeting Transcript, No. 5
at p. 86)
California's analysis assumes that the dimming ballast operates 20
percent of the time at 100 percent light output, 50 percent of the time
at 80 percent light output, and 30 percent of the time at 50 percent
light output.\27\ Compared to 100 percent of the time at 100 percent
light output, this California duty cycle results in an energy savings
of 26 percent. In contrast for this preliminary analysis, DOE analyzed
a different duty cycle. DOE analyzed a duty cycle that yielded energy
savings closer to the values reported in the LBNL meta-analysis. DOE
used 10 percent of the time at 100 percent light output, 30 percent of
the time at 70 percent light output, and 60 percent of the time at 30
percent light output.
---------------------------------------------------------------------------
\27\ Table 4.3 Average Energy Use for Qualifying Products. p. 16
CA IOUS. Dimming Fluorescent Lamp Ballasts. Codes and Standards
Enhancement (CASE) Initiative for PR2013: Title 20 Standards
Development. (TN 78109) Updated version dated August 5, 2013.
Available at https://efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=12-AAER-02B.
---------------------------------------------------------------------------
Dimming ballasts have very limited use in residential applications.
Both Lutron and NEEA reiterated the low use of dimming ballasts in
residential applications. (Lutron, Public Meeting Transcript, No. 5 at
pp. 87-88; NEEA, Public Meeting Transcript, No. 5 at p. 87) DOE agrees
and assumed 98 percent of dimming ballasts were in commercial
applications and 2 percent were in residential applications.
GE and ULT stated that reduced wattage lamps are not used with
dimming ballasts because of difficulties with dimming these lamps and
other reasons. (GE, Public Meeting Transcript, No. 5 at p. 80; ULT,
Public Meeting Transcript, No. 5 at pp. 81-82) Because dimming ballasts
are compatible with reduced wattage lamps, some dimming ballasts and
reduced wattage systems are likely in use. DOE accounts for this low
usage in its weighting of such systems.
4. Tubular LEDs
ULT stated that although tubular LEDs (TLEDs) are becoming
prevalent, the ballasts in the field were not designed to operate
TLEDs. NEMA and ULT highlighted that standards bodies require
certification that the ballast and given lamp can operate. (ULT, Public
Meeting Transcript, No. 5 at p. 83; NEMA, Public Meeting Transcript,
No. 5 at pp. 84-85) Both NEMA and ULT cautioned that some
incompatibility between the ballast and the TLED may occur in the
field. NEMA and ULT recommended to not include these lamps in the
analysis and if necessary address TLEDs separate from the ballast.
(NEMA, No. 12 at p. 9; ULT, No. 6 at p. 7) DOE agrees with ULT that
TLEDs are becoming prevalent. DOE also reiterates that the scope of
this analysis is the fluorescent lamp ballast and only includes TLEDs
in the analysis because the operation of these lamps by the ballast
affects the energy use, and that in the field fluorescent lamp ballasts
are operated, to a degree, with TLEDs.
ASAP referenced research by other DOE programs that TLEDs operating
in a luminaire designed for a fluorescent lamp are significantly less
energy efficient than dedicated LED luminaires. (ASAP, No. 7 at p. 5)
DOE agrees that differences exist between modified fluorescent
luminaires using a TLED and a luminaire designed solely to operate
LEDs. DOE notes that LED luminaires are not part of this analysis.
[[Page 56568]]
ASAP recommended analyzing the TLED market to evaluate its effect
on the overall energy savings over time. (ASAP, No. 7 at p. 5) GE and
Philips stated that the prevalence of TLEDs is growing rapidly. GE
speculated that TLEDs are currently a low percentage of the overall
installed base. (GE, Public Meeting Transcript, No. 5 at p. 80;
Philips, No. 8 at p. 32) DOE includes a change in TLED penetration over
time in this analysis. As the mixture of lamps operated by the ballast
changes to include differing amount of TLEDs, the energy use of the
ballast changes.
Philips discussed that there is an inverse relationship with the
use of TLEDs on fluorescent lamp ballasts. As a general rule, the
combination of fluorescent lamp ballast and TLED results in a lower
power draw, but the operation of a fluorescent lamp ballast and
fluorescent lamp results in a greater ballast efficiency. (Philips, No.
8 at p. 32) Philips also stated that it manufactures a ballast to be
paired with specific fluorescent lamps and does not know if the ballast
is being paired with a TLED or if the wattage of the TLED is 14, 15, 17
or some other wattage value. (Philips, Public Meeting Transcript, No. 5
at pp. 83-84) Philips stated that TLEDs are available in the 12 to 17 W
range and offer significant energy savings when used with compatible
fluorescent lamp ballasts. (Philips, No. 8 at p. 32) Philips stated
that the power draw for TLEDs will continue to decrease into the
future. (Philips, Public Meeting Transcript, No. 5 at p. 82) DOE agrees
that ballast efficiency can differ for the same ballast operating a
fluorescent lamp and a TLED. DOE used the operating power for TLEDs in
the analysis. DOE also analyzed the larger TLED market to determine
representative values of fluorescent lamp ballasts operating TLEDs.
DOE seeks comment on the methods to improve DOE's energy-use
analysis, as well as any data supporting alternate operating hour
estimates or assumptions regarding dimming of fluorescent lamp
ballasts. DOE seeks comment on the type, prevalence, and operating hour
reductions related to the use of lighting controls used separately in
commercial, industrial, and residential sectors. DOE seeks comment on
the assumptions and methodology for estimating annual operating hours.
See section VII.C for a list of issues on which DOE seeks comment.
Chapter 7 of the NOPD TSD provides details on DOE's energy use analysis
for fluorescent lamp ballasts.
E. Life-Cycle Cost and Payback Period Analysis
DOE conducted LCC and PBP analyses to evaluate the economic effects
on individual consumers of potential energy conservation standards for
fluorescent lamp ballasts. In particular, DOE performed LCC and PBP
analyses to evaluate, in part, the savings in operating costs
throughout the estimated average life of fluorescent lamp ballasts at
different ELs compared to any associated increase in costs of
fluorescent lamp ballasts likely to result from standards at each EL.
The effect of amended energy conservation standards on individual
consumers usually involves a reduction in operating cost and an
increase in purchase cost. DOE used the following two metrics to
measure effects on the consumer:
The LCC (life-cycle cost) is the total consumer expense of
an appliance or product over the life of that product, consisting of
total installed cost (manufacturer selling price, distribution chain
markups, sales tax, and installation costs) plus operating costs
(expenses for energy use, maintenance, and repair). To compute the
operating costs, DOE discounts future operating costs to the time of
purchase and sums them over the lifetime of the product.
The PBP (payback period) is the estimated amount of time
(in years) it takes consumers to recover the increased purchase cost
(including installation) of a more-efficient product through lower
operating costs. DOE calculates the PBP by dividing the change in
purchase cost at higher efficiency levels by the change in annual
operating cost for the year that amended standards are assumed to take
effect.
For any given efficiency level, DOE measures the change in LCC
relative to the LCC in the no-new-standards case, which reflects the
estimated efficiency distribution of fluorescent lamp ballasts in the
absence of new or amended energy conservation standards. Similarly, the
PBP for a given efficiency level is measured relative to the baseline
reflecting the efficiencies customers are estimated to select absent an
amended standard.
For each considered efficiency level in each product class, DOE
calculated the LCC and PBP for a nationally representative set of
potential customers. Fluorescent lamp ballasts are used widely in
commercial, industrial, and residential settings. For each ballast
class, DOE identified the types of customers likely to use the
ballasts, the number of hours per year each customer type would likely
use the ballasts, and a probability of selection for each customer type
in the Monte Carlo analysis.
Inputs to the calculation of total installed cost include the cost
of the product--which includes manufacturer production costs (MPCs),
manufacturer markups, retailer and distributor markups, and sales
taxes--and installation costs. Inputs to the calculation of operating
expenses include annual energy consumption, energy prices and price
projections, repair and maintenance costs, product lifetimes, and
discount rates. DOE created distributions of values for product
lifetime, energy prices, annual operating hours (which determines
energy consumption), discount rates, and sales taxes, with
probabilities attached to each value, to account for their uncertainty
and variability.
The computer model DOE uses to calculate the LCC and PBP, which
incorporates Crystal Ball\TM\, relies on a Monte Carlo simulation to
incorporate uncertainty and variability into the analysis. The Monte
Carlo simulations sample input values from the probability
distributions and FLB user samples. The model calculated the LCC and
PBP for products at each efficiency level for 10,000 FLB installations
per simulation run.
DOE calculated the LCC and PBP for all consumers of fluorescent
lamp ballasts as if each were to purchase a new product in the expected
year of required compliance with potential amended standards. Any
amended standards would apply to fluorescent lamp ballasts manufactured
3 years after the date on which any amended standard is published. (42
U.S.C. 6295(m)(4)(A)) For purposes of its analysis, DOE used 2023 as
the first year of compliance with any amended standards for fluorescent
lamp ballasts.
Table IV.12 summarizes the approach and data DOE used to derive
inputs to the LCC and PBP calculations. The subsections that follow
provide further discussion. Details of the spreadsheet model, and of
all the inputs to the LCC and PBP analyses, are contained in chapter 8
of the NOPD TSD and its appendices.
[[Page 56569]]
Table IV.12--Summary of Inputs and Methods for the LCC and PBP Analysis
*
------------------------------------------------------------------------
Inputs Source/method
------------------------------------------------------------------------
Product Cost................. Derived by multiplying product costs from
the engineering analysis by (one plus)
sales tax rates.
Installation Costs........... Baseline installation cost determined
with data from RSMeans. Assumed no
change with efficiency level.
Annual Energy Use............ The total annual energy use multiplied by
the hours per year. Average number of
hours based 2015 LMC.
Energy Prices................ Based on the Energy Information
Administration's (EIA's) Form 861 data
for 2017.\28\ Average energy prices
determined for 50 states plus the
District of Columbia.
Energy Price Trends.......... Based on Annual Energy Outlook 2019
(AEO2019) price projections.
Repair and Maintenance Costs. Assumed no change with efficiency level.
Product Lifetime............. Average: 12.5 Years for commercial
installations (approximately 38,000
hours), 12.5 years for outdoor
installations (approximately 41,000
hours), 11.4 years for industrial
installations (50,000 hours), and 15
years for residential installations
(approximately 10,800 hours).
Discount Rates............... For residential product class, the
calculations involve identifying all
possible debt or asset classes that
might be used to purchase the considered
appliances, or might be affected
indirectly. Primary data source was the
Federal Reserve Board's Survey of
Consumer Finances. For other product
classes, the calculations involve
estimating weighted average cost of
capital for large numbers of companies
and using the results to develop
discount rate distributions. Primary
data were from the Damodaran online web
site \29\ and the Federal Reserve
Board.\30\
Rebound Effect............... Rebound is not assumed to be present
among FLB consumers. Most consumers are
commercial and industrial consumers, and
the FLB/light user tends to not see the
bills so there would be no perceived
change in the cost of using the light.
Compliance Date.............. 2023.
------------------------------------------------------------------------
* References for the data sources mentioned in this table are provided
in the sections following the table or in chapter 8 of the NOPD TSD.
1. Product Cost
---------------------------------------------------------------------------
\28\ DOE used Average Price by State by Provider (EIA-826),
sorted for Total Electric Industry, obtained from the EIA web page
https://www.eia.gov/electricity/data/state/.
\29\ See the data page on Damodaran Online, http://
pages.stern.nyu.edu/~adamodar.
\30\ In addition to the previously referenced Survey of Consumer
Finances, DOE used interest rate data obtained from the Federal
Reserve Bank of St. Louis' FRED Economic Data tool found at https://fred.stlouisfed.org/.
---------------------------------------------------------------------------
As noted in section IV.C, DOE rulemaking analyses typically
calculate consumer product costs by multiplying MPCs developed in the
engineering analysis by the markups along with sales taxes. For
fluorescent lamp ballasts, the engineering analysis determined customer
prices directly; therefore, for the LCC analysis, the only adjustment
was to add sales taxes.
In prior energy conservation standards rulemakings, DOE estimated
the total installed costs per unit for equipment and then assumed that
costs remain constant throughout the analysis period. This assumption
is conservative because equipment costs tend to decrease over time. In
2011, DOE published a notice of data availability (NODA) titled
Equipment Price Forecasting in Energy Conservation Standards Analysis.
76 FR 9696 (Feb. 22, 2011). In the NODA, DOE proposed a methodology for
determining whether equipment prices have trended downward in real
terms. The methodology examines so-called price or experiential
learning, wherein, with ever-increasing experience with the production
of a product, manufacturers are able to reduce their production costs
through innovations in technology and process.
Consistent with the February 2011 NODA, DOE examined historical
price data specific to electronic ballasts. As discussed in Chapter 8
and Appendix 8C of the NOPD TSD, this analysis yielded learning
coefficients indicating a 14.8 percent decrease in ballast prices for
every doubling in cumulative ballast shipments. Although this price
trend was incorporated into the LCC model, it was excluded from the LCC
results presented in this NOPD. With shipments falling from historical
values, cumulative shipments do not double relative to 2015 (the last
year of historical data) in any shipments scenario, and shipments go to
zero in one scenario essentially at the projected start date for
amended standards. See section IV.F.1 for further details on shipments.
Given this range of possible shipments, for the LCC results presented
in this NOPD, the price change over time was assumed to be zero; or, in
other words, the price trend coefficient was set to 1.00 for all years
of the LCC (and NIA) analyses.
Lamp manufacturing is also subject to the learning process. The
focus of this NOPD is the fluorescent lamp ballast. However,
fluorescent lamp ballasts are designed to operate fluorescent lamps and
therefore, the cost analysis accounts for the lamp-and-ballast system.
The analysis assumes a differing mixture of general service fluorescent
lamps (GSFL) and TLEDs operated by the ballasts. TLED prices are
expected to be affected by price learning and are expected to decline
significantly over the next 3 years. Therefore, to better represent the
total installed cost of the ballast and lamp systems, price learning
was applied to the lamps operated by the fluorescent lamp ballasts.
Because this proposed determination is not analyzing lamps, lamp
shipments and price information were not collected for this rulemaking.
Rather, price trend information for lamps was developed from the final
rule for the general service fluorescent lamps (GSFL) standards
rulemaking published in January 2015. 80 FR 4041 (January 26, 2015). As
discussed in this FLB NOPD TSD Appendix 8C, the GSFL price trends were
incorporated into the LCC analysis to account for learning in the lamp
manufacturing process. The distribution of lamps selected for use by
consumers is not expected to differ for ballasts at different
efficiency levels.
2. Installation Cost
Installation cost includes labor, overhead, and any miscellaneous
materials and parts needed to install the product. DOE used data from
RSMeans to estimate the baseline installation cost for fluorescent lamp
ballasts. For installation and repair costs, both NEMA and ULT found
the ones discussed in DOE's Framework document to be reasonable. (NEMA,
No. 12 at p. 11; ULT, No. 6 at p. 9) Philips also stated that it is
unlikely that installation costs would change for ballasts at different
efficiency levels. (Philips, No. 8 at p. 35) However, ULT cautioned
that if new ballasts required as part of a potential standard changed
in size, maintenance costs could change.
[[Page 56570]]
(ULT, Public Meeting Transcript, No. 5 at p. 96; ULT, No. 6 at p. 9)
DOE agrees and uses the same installation costs for ballasts at each
efficiency level. Per the engineering analysis, the ballasts at the
different efficiency levels are not expected to change in size at the
different efficiency levels and therefore would not affect installation
or maintenance costs as suggested by ULT. DOE found no evidence that
installation costs would be affected with increased efficiency levels.
3. Annual Energy Consumption
DOE determined the energy consumption for fluorescent lamp ballasts
at different efficiency levels using the approach described previously
in section IV.D of this document.
4. Energy Prices
DOE derived average annual electricity prices for 50 states plus
the District of Columbia using data from the EIA's Form EIA-861 annual
survey.\31\ EIA calculated average electric prices by dividing total
electric revenues by total kWh energy sales, using data aggregated by
customer class and by state. The NOPD analysis used the data for 2017,
with prices adjusted to 2018 dollars.
---------------------------------------------------------------------------
\31\ Available at https://www.eia.gov/electricity/data.php#sales.
---------------------------------------------------------------------------
To estimate energy prices in future years, DOE multiplied the
average state-level electricity prices by a projection of annual change
in regional electricity prices in the Annual Energy Outlook 2019
(AEO2019), which has an end year of 2050.\32\ The AEO includes price
projections by Census regions, which were used for the analyses
presented herein. To estimate future electricity prices, DOE uses the
price index for the regions corresponding to each state. To estimate
price trends after 2050, DOE used the average annual rate of change in
prices from 2040 through 2050.
---------------------------------------------------------------------------
\32\ U.S. Department of Energy--Energy Information
Administration. Annual Energy Outlook 2019 with Projections to 2050.
2019. Washington, DC. (AEO2019). Available at https://www.eia.gov/outlooks/aeo/.
---------------------------------------------------------------------------
Both ASAP and ULT stated that electricity prices can vary both
between utilities as well as a result of larger national trends like
distributed generation or Congressional requirements. ASAP suggested an
analysis that addressed uncertainty in the electricity market. (ASAP,
Public Meeting Transcript, No. 5 at p. 94; ULT, No. 6 at p. 6) DOE
accounted for considerable electricity price variability by using data
from 50 states plus the District of Columbia. Although this represents
a higher level of aggregation than utility-by-utility, it reflects the
considerable variability in electricity prices in the analysis and it
captures some of the policy and other trends alluded to by ASAP and ULT
insofar as the influx of distributed generation typically follows
state-level policies and legislation promoting such.
5. Maintenance and Repair Costs
Repair costs are associated with repairing or replacing product
components that have failed in an appliance; maintenance costs are
associated with maintaining the operation of the product. Typically,
small incremental increases in product efficiency produce no, or only
minor, changes in repair and maintenance costs compared to baseline
efficiency products. For this NOPD, DOE modeled ballasts as not being
repaired, and maintenance costs as lamp replacement costs only. Philips
agreed with DOE's proposal during the framework public meeting and in
written comments that ballasts are not repaired. (Philips, Public
Meeting Transcript, No. 5 at p. 95; Philips, No. 8 at p. 35) DOE agrees
and did not include ballast repair costs in the LCC analysis.
6. Product Lifetime
For fluorescent lamp ballasts, DOE used lifetime estimates from
manufacturer datasheets. In the Framework document, DOE estimated a
life of 50,000 hours for fluorescent lamp ballasts. Both NEMA and ULT
stated that the standard warranty period within the lighting industry
for fluorescent lamp ballasts is 3 to 5 years, depending on
application. (NEMA, No. 12 at p. 11; ULT, No. 6 at p. 9) Philips stated
they use 50,000 hours as useful life, but in certain circumstances
thermal effects can reduce this rated life value. Philips speculated
that, depending on the operating hours of the ballast, this translates
to 10-15 years as a reasonable estimate for FLB life. (Philips, No. 8
at p. 35) The number of years can vary in operation, and DOE used a
life value in total number of years rather than solely relying on
operating hours. For this analysis, DOE used a 12.5-year average
lifetime for the commercial sector, 11.4-year average lifetime for the
industrial sector, and 12.5-year average lifetime for the outdoor
sector. Combining DOE's estimate of 50,000 hours and the average
operating hours for fluorescent lamps in the commercial and industrial
sectors yielded average ballast lifetimes of 16.6 years and 11.4 years,
respectively. However, 16.6 years is significantly longer than the
lifetime of commercial ballasts used in the 2011 Ballast Rule. For that
final rule, DOE used 12.5 years, a value DOE found consistent with the
literature at the time of the analyses, and consistent with the comment
from Phillips. (Philips, No. 8 at p. 35) DOE has found no literature
confirming that the product lifetime would increase by 33 percent when
measured in years and focused instead on searching for evidence
contradicting the lifetime of 12.5 years. No such evidence was
identified. Thus, for the NOPD DOE assumed commercial ballasts would
have a 12.5-year average lifetime which, when multiplied by the average
commercial sector operating hours per year, yields a lifetime of
approximately 38,000 hours.
Replacement of fluorescent lamps have to be considered because it
is a cost that will be incurred by the consumer over the course of the
life of the fluorescent lamp ballast. GE stated that in contrast to
dimming incandescent lamps, dimming fluorescent lamps does not extend
lamp life. In fact, in some cases if not done properly, life can be
negatively affected. Overall, GE stated to not increase lamp life for
lamps operated on dimming ballasts compared to non-dimming ballasts.
(GE, Public Meeting Transcript, No. 5 at p. 95) Philips stated that
without knowing the extent of ballast modifications to meet a potential
new or amended standard, it was difficult to predict the effect on lamp
life. (Philips, No. 8 at p. 35) ASAP stated that the typical operating
life of a T8 fluorescent lamp is 20,000 hours and the advertised
lifespan range of TLED is 50,000 to 80,000 hours. (ASAP, No. 7 at p. 5)
DOE does not expect the fluorescent lamp life to extend as a result of
modifications to the ballasts. The life of the fluorescent lamps used
in the LCC analysis can be found in the engineering analysis. DOE used
a life of 50,000 hours for the TLEDs used in the analysis.
7. Discount Rates
In the calculation of LCC, DOE applies discount rates appropriate
to commercial, industrial, and residential consumers to estimate the
present value of future operating costs. DOE estimated a distribution
of discount rates for fluorescent lamp ballasts based on consumer
financing costs and the opportunity cost of consumer funds.
DOE applies weighted average discount rates calculated from
consumer debt and asset data, rather than marginal or implicit discount
rates.\33\ DOE notes
[[Page 56571]]
that the LCC does not analyze the product purchase decision, so the
implicit discount rate is not relevant in this model. The LCC estimates
NPV over the lifetime of the product, so the appropriate discount rate
will reflect the general opportunity cost of household or business
funds, taking this time scale into account. Given the long time frame
modeled in the LCC, the application of a marginal interest rate
associated with an initial source of funds is inaccurate. Regardless of
the method of purchase, consumers are expected to continue to rebalance
their debt and asset holdings over the LCC analysis period, based on
the restrictions consumers face in their debt payment requirements and
the relative size of the interest rates available on debts and assets.
DOE estimates the aggregate effect of this rebalancing using the
historical distribution of debts and assets.
---------------------------------------------------------------------------
\33\ The implicit discount rate is inferred from a consumer
purchase decision between two otherwise identical goods with
different first cost and operating cost. It is the interest rate
that equates the increment of first cost to the difference in net
present value of lifetime operating cost, incorporating the
influence of several factors: Transaction costs, risk premiums and
response to uncertainty, time preferences, and interest rates at
which a consumer is able to borrow or lend.
---------------------------------------------------------------------------
To establish residential discount rates for the LCC analysis, DOE
identified all relevant household debt or asset classes in order to
approximate a consumer's opportunity cost of funds related to appliance
energy cost savings. It estimated the average percentage shares of the
various types of debt and equity by household income group using data
from the Federal Reserve Board's Survey of Consumer Finances \34\ (SCF)
for 1995, 1998, 2001, 2004, 2007, 2010, 2013, and 2016. Using the SCF
and other sources, DOE developed a distribution of rates for each type
of debt and asset by income group to represent the rates that may apply
in the year in which amended standards would take effect. In the
Crystal Ball\TM\ analyses, for each of the 10,000 simulations, the
model selects an income group and then selects a discount rate from the
distribution for that group.
---------------------------------------------------------------------------
\34\ Board of Governors of the Federal Reserve System. Survey of
Consumer Finances. Available at http://www.federalreserve.gov/PUBS/oss/oss2/scfindex.html.
---------------------------------------------------------------------------
For commercial and industrial consumers, DOE used the cost of
capital to estimate the present value of cash flows to be derived from
a typical company project or investment. Most companies use both debt
and equity capital to fund investments, so the cost of capital is the
weighted-average cost to the firm of equity and debt financing. This
corporate finance approach is referred to as the weighted-average cost
of capital. DOE used currently available economic data in developing
discount rates. See chapter 8 of the NOPD TSD for details on the
development of consumer discount rates.
8. Energy Efficiency Distribution in the No-New-Standards Case
To accurately estimate the share of consumers that would be
affected by a potential energy conservation standard at a particular
efficiency level, DOE's LCC analysis considered the projected
distribution (market shares) of product efficiencies under the no-new-
standards case (i.e., the case without amended energy conservation
standards).
To estimate the energy efficiency distribution of fluorescent lamp
ballasts for 2023, DOE analyzed the distribution of ballasts in the
databases used in the engineering analysis. For the non-dimming
ballasts, the main source of information is the CCMS database. For non-
dimming ballasts, DOE relied on product offerings in manufacturer
catalogs. See chapter 8 of the NOPD TSD for the estimated efficiency
distributions.
9. Payback Period Analysis
The PBP is the amount of time it takes the consumer to recover the
additional installed cost of more-efficient products, compared to
baseline products, through energy cost savings. PBPs are expressed in
years. PBPs that exceed the life of the product mean that the increased
total installed cost is not recovered in reduced operating expenses.
The inputs to the PBP calculation for each efficiency level are the
change in total installed cost of the product and the change in the
first-year annual operating expenditures relative to the baseline. The
PBP calculation uses the same inputs as the LCC analysis, except that
discount rates are not needed.
EPCA, as amended, establishes a rebuttable presumption that a
standard is economically justified if the Secretary finds that the
additional cost to the consumer of purchasing a product complying with
an energy conservation standard level will be less than three times the
value of the first year's energy savings resulting from the standard,
as calculated under the applicable test procedure. (42 U.S.C.
6295(o)(2)(B)(iii)) For each considered efficiency level, DOE
determined the value of the first year's energy savings by calculating
the energy savings in accordance with the applicable DOE test
procedure, and multiplying those savings by the average energy price
projection for the year in which compliance with the amended standards
would be required.
F. Shipments Analysis
DOE uses projections of annual product shipments to calculate the
national impacts of potential amended energy conservation standards on
energy use, NPV, and future manufacturer cash flows.\35\ The shipments
model takes an accounting approach in tracking market shares of each
product class and the vintage of units in the stock. Stock accounting
uses product shipments as inputs to estimate the age distribution of
in-service product stocks for all years. The age distribution of in-
service product stocks is a key input to calculations of both the NES
and NPV, because operating costs for any year depend on the age
distribution of the stock. DOE received many comments on the shipments
and trends related to fluorescent lamp ballasts. Overall, the market is
declining; however, DOE received comments on the different rates of
decline.
---------------------------------------------------------------------------
\35\ DOE uses data on manufacturer shipments as a proxy for
national sales, as aggregate data on sales are lacking. In general,
one would expect a close correspondence between shipments and sales.
---------------------------------------------------------------------------
Philips stated that DOE should be working with NEMA in order to
obtain market shipment data and, if needed, Philips can work with NEMA
to supply the data. Philips also stated that they would provide data to
DOE during the interview process. (Philips, No. 8 at pp. 12-13) DOE did
receive data from NEMA in written comments that provided indexed values
of shipments for a recent set of years. (NEMA, No. 12, at p. 4) DOE
also used aggregated data gathered from manufacturers to calibrate the
current volume of shipments.
Philips suggested resources for projecting lighting shipments, not
just FLB shipments, from Strategies Unlimited, other DOE publications,
and NEMA. (Philips, No. 8 at p. 39) DOE reviewed the materials
suggested by Philips as well as other data sources to generate shipment
projections.
NEMA, Philips, and ULT provided in written comments a graph of
fluorescent lamp ballasts indexed to 2010 and shipments through 2014 as
a percentage of the index year. This figure indicates a declining
market for fluorescent lamp ballasts. (NEMA, No. 12 at pp. 4; Philips,
No. 8 at p. 39; ULT, No. 6 at pp. 3-4) NEMA attributes the decline to
solid-state lighting and expects the decline to continue into the
future. (NEMA, No. 12 at p. 11) NEMA and ULT speculated that based on
the data in the figure and certain fit functions that circa 2018 that
FLB shipments would end. (NEMA, Public Meeting Transcript, No. 5 at pp.
9-11; ULT, No. 6 at pp. 3-4) However, NEMA did speculate that although
an analysis of the data provided suggests an end of the
[[Page 56572]]
FLB market in 2018, it is probably not realistic. (NEMA, Public Meeting
Transcript, No. 5 at pp. 9-11) DOE agrees that the market for
fluorescent lamp ballasts is declining. DOE modeled a rapid decline in
shipment scenario #1 based on these data provided. NEMA suggested that
the ballast shipments curtailing in 2018 was based on 2010 to 2014
shipment data and a second degree polynomial fit standard S-curve shape
function. (NEMA, Public Meeting Transcript, No. 5 at p. 9) Shipment
scenario #1 was modeled as a similar S-curve shaped function with
shipments curtailing shortly after the start of the analysis period.
Philips stated that the submitted figure indicates the FLB market
is declining at a fast rate. Philips speculated that the market was
declining at a rate of about 20 percent per year. According to Philips,
LED technologies are competing with fluorescent light sources to
illuminate the same spaces and LED prices are decreasing whereas
fluorescent technologies are mature. This is one of the reasons for
declining FLB shipments. (Philips, No. 8 at pp. 16, 39) Philips also
commented that it has reduced the number of its factories manufacturing
fluorescent lamp ballasts from five to one. (Philips, Public Meeting
Transcript, No. 5 at p. 55) Lutron stated that FLB shipments are
declining at an accelerating rate and potential new amended standards
can only affect shipments. (Lutron, Public Meeting Transcript, No. 5 at
p. 41) DOE agrees that the market for fluorescent lamp ballasts is
declining. DOE modeled a rate of decline similar to the 20-percent rate
suggested by Philips in shipment scenario #2 based on the data
provided.
NEEA mentioned that 10 percent of lamps sales are T12 lamps.
Although T12 lamps are less efficient, as legacy products they can have
a significant life and sizeable volume of shipments. NEEA also stated
that ballasts have a longer life than fluorescent lamps. (NEEA, Public
Meeting Transcript, No. 5 at pp. 40-41) GE acknowledged that although
certain ballasts have long lives and there might be legacy products
still in operation, the lighting industry is currently at the trailing
end of those systems. (GE, Public Meeting Transcript, No.5 at p. 55)
ULT stated during the framework public meeting that the retrofit
market is very small and little retrofitting is occurring in the
market. (ULT, Public Meeting Transcript, No. 5 at pp. 105-106)
ULT stated that LED lighting penetration is increasing in the new
construction market, and ULT expected 90 to 95 percent penetration near
2017. Beyond new construction, rebates for fluorescent lamp ballasts
and FLB retrofit kits are virtually nonexistent as utilities and other
energy efficiency programs are incentivizing LED technologies. (ULT,
Public Meeting Transcript, No. 5 at pp. 104-106)
NEMA and ULT stated that there is no indication of growth in the
FLB market and every segment is declining. Both NEMA and ULT suggested
that new construction is moving to SSL and by the effective date of a
potential standard all new construction will utilize SSL. Rebates for
fluorescent systems have declined and in some markets disappeared. Both
NEMA and ULT expected these trends to continue through the analysis
period of the potential rule. (NEMA, No. 12 at p. 11; ULT, No. 6 at p.
9) DOE agrees and has modeled all shipment scenarios as declining
markets.
CA IOUs stated that it is generally accepted that the LED market is
growing quickly as LED performance improves and prices come down, and
that as a result, LEDs are generally expected to expand into most
applications in the coming years. (CA IOUs, No. 10 at p. 11) DOE agrees
and has modeled all shipment scenarios as declining markets.
ASAP stated that the widespread installation of UL Type A TLEDs
could create an extended ``hybrid'' phase where an LED light source is
driven by a ballast designed for a fluorescent light source. (ASAP, No.
7 at p. 5) DOE agrees that this could be a possibility. Shipment
scenarios #3 and #4 differ in rates of decline partially to address
this aspect of the use of UL Type A TLEDs, which are designed to
operate on existing fluorescent lamp ballasts.
1. Shipment Scenarios Modeled
DOE agrees with the commenters that FLB shipments are declining.
DOE modeled four different no-new-standards shipment scenarios. These
scenarios include the following:
(1) Scenario #1--declining shipments that all terminate in 2024.
This scenario is based on the data supplied by NEMA and others
depicting the decline between 2010 and 2014. The scenario also assumes
that all new construction migrates to other light sources than
fluorescent technology.
(2) Scenario #2--declining shipments that all terminate in 2040.
This scenario is based on comments from manufacturers during the
interview process and written comments of a reduction in shipments of
10 to 20 percent per year. This scenario assumes that most new
construction is utilizing other light sources besides fluorescent
technology.
(3) Scenario #3--declining shipments that approach zero near the
end of the analysis period. This scenario is based on data of shipments
of other lighting technologies publicly available. The rate of decline
is less compared to the previous scenarios partially also to address
comments received about UL Type A TLEDs operating on fluorescent lamp
ballasts.
(4) Scenario #4--declining shipments that terminate near the end of
the analysis period. This scenario is based on a slower decline rate in
the initial part of the analysis period.
DOE presents in this proposed determination the results of analysis
for each of the shipment scenarios, but shipment scenario #3 is the
Reference Case. This scenario is consistent with other estimates of
fluorescent technology in the analysis period.
Beyond the no-new-standards case, DOE also received comments about
potential standards-induced changes to shipments and thus the effects
on NIA. CA IOUs stated that DOE should account for additional energy
savings resulting from an accelerated shift to LED lighting induced by
more stringent standards for fluorescent lamp ballasts. (CA IOUs, No.
10 at p. 11) Philips also commented that it would be worthwhile to
consider the effect of a new ballast energy efficiency rule if ballast
declines continued at a faster rate. (Philips, No. 8 at p. 39) Philips
speculated that if the incremental ballast price from ballast
modifications necessary for compliance to a potential new and amended
standard does not pay back within 2 years using the incremental energy
savings, customers will choose something else and in reality it will
lead to greater LED adoption. (Philips, No. 8 at pp. 36-37)
Lutron stated that FLB shipments are declining at an accelerating
rate and potential new amended standards can only affect shipments.
(Lutron, Public Meeting Transcript, No. 5 at p. 41) CA IOUs stated that
first costs can still be a barrier to LED adoption and if potential new
energy efficiency standards for fluorescent lamp ballasts increase the
costs for the ballasts, the result will likely accelerate the shift
towards more efficient LEDs. (CA IOUs, No. 10 at p. 11) NEEA stated
during the framework public meeting that shipment rates of different
technologies will depend on the price relationship of the different
technologies. (NEEA, Public Meeting Transcript, No. 5 at pp. 99-101)
[[Page 56573]]
DOE agrees that there is a possibility that standards could induce
consumers to opt for different technologies other than fluorescent lamp
ballasts. Utilizing the shipments model, DOE modeled within the NIA
model a potential standards-induced shift to SSL.
2. Dimming Ballasts
NEMA and manufacturers stated that the dimming ballast market was
small, not growing, and possibly that dimming ballasts would not be
shipped by the start of the analysis period. In contrast, ASAP, SCE,
and CA IOUs speculated growth in the dimming ballast market. (CA IOUs,
Public Meeting Transcript, No. 5 at pp. 24, 106)
NEMA stated that dimmable linear fluorescent lamp ballasts are
roughly 2 percent of the overall FLB market. NEMA speculated that this
small portion did not represent significant energy savings potential.
Dimming ballast shipments have been declining for the last 5 years,
according to NEMA and Lutron. (Lutron, No. 9 at p. 2; NEMA, No. 12 at
pp. 3-4, 11) NEMA believes that dimming ballast shipments will continue
to decline into the future like all other linear FLB shipments.
Finally, Lutron and NEMA speculated that standards on dimming ballasts
may reduce shipments of ballasts. (Lutron, No. 9 at p. 2; NEMA, No. 12
at pp. 3-4, 11)
GE stated that other than in California, that most retrofits of FLB
systems do not include dimming ballasts. GE discussed during the
framework public meeting that California was considering modifying the
requirements of dimming ballasts in retrofit applications in Title 24
because of claims of negative effects on the retrofit market. (GE,
Public Meeting Transcript, No. 5 at pp. 25-26)
Lutron commented during the public meeting that the requirements in
California's Title 24 had changed and the adoption of dimming ballasts
in retrofit applications is unknown at this time. (Lutron, Public
Meeting Transcript, No. 5 at pp. 27-28) During the public meeting,
Lutron stated that they believe it is prudent for DOE to assume that
all dimming ballasts that are going to be available after the rule
becomes effective are already in the market. (Lutron, Public Meeting
Transcript, No. 5 at p. 104) In contrast, during the framework public
meeting, CA IOUs stated that they expected the absolute number or the
percentage of dimming FLB shipments to increase. (CA IOUs, Public
Meeting Transcript, No. 5 at p. 106)
ULT commented that although California's Title 24 required the
installation of dimming ballasts, sites were installing TLEDs to not
trigger the energy code. ULT stated that as a result, there would be
probably fewer dimming systems than compared to previous analysis.
(ULT, Public Meeting Transcript, No. 5 at pp. 29-31)
ASAP stated that the revised California Title 24 would dramatically
alter the market for fluorescent lamp ballasts within California,
resulting in greater sales of ballasts capable of dimming below 50
percent full light output. ASAP expected the change in California to
affect other states and that dimming ballasts will be in greater
demand. (ASAP, No. 7 at p. 2)
Utility rebates for most fluorescent lamp ballasts have
disappeared, but SCE did state that some rebates still exist for
dimming ballasts as they related to demand response. (SCE, Public
Meeting Transcript, No. 5 at pp. 109-110)
CA IOUs stated during the framework public meeting that the dimming
ballast requirements within California's Title 24 is having a major
effect on the dimming ballast market within California. The 2016
version of Title 24 essentially requires new construction to use linear
fluorescent and that the ballast be a dimming ballast. Title 24
installation of dimming ballast requirements also apply to retrofit
applications. (CA IOUs, Public Meeting Transcript, No. 5 at pp. 23-24)
NEEA also added during the framework public meeting that the four
states in the Pacific Northwest might have dimming ballast requirements
similar to Title 24 by the time any potential rule goes into effect.
(NEEA, Public Meeting Transcript, No. 5 at p. 24) NEMA stated that they
would review its data to see if it could determine any effects on
dimming ballast shipments as a result of the Title 24 requirements.
(NEMA, Public Meeting Transcript, No. 5 at p. 25)
As stated earlier, DOE agrees with commenters that the overall FLB
market is declining. Although dimming ballasts may be a smaller portion
of the entire FLB market, DOE does not have enough information to
indicate a significantly different rate of decline for dimming ballasts
compared to the larger FLB market. DOE modeled the same rate of decline
for dimming ballasts as other similar non-dimming fluorescent lamp
ballasts operating the same type and quantity of lamps in each of the
four different scenarios.
GE speculated that if a potential new standard resulted in a very
expensive fluorescent dimming ballast, it would accelerate new
construction use of LEDs if they wanted a system that dims. (GE, Public
Meeting Transcript, No. 5 at p. 101) Lutron speculated that setting
efficiency standards too aggressively will only hasten the decline of
dimming ballasts. (Lutron, No. 9 at p. 3) DOE agrees that potential
standards could induce a shift from dimming fluorescent lamp ballasts
to solid-state lighting. As part of the NIA analysis, DOE included a
secondary analysis of a standards-induced shift from dimming ballasts
to SSL.
3. Tubular LEDs
During the framework public meeting, SCE stated that many lighting
customers are focused on inexpensive solutions and often consider
retrofitting options rather than replacing the entire system.
Specifically, replacing fluorescent lamps with TLEDs is an option that
many customers consider. (SCE, Public Meeting Transcript, No. 5 at p.
39) CA IOUs agreed with other commenters that LED products are
increasing across many applications, but fluorescent lighting is still
prevalent across many sectors. Many manufacturers offer UL Type A TLEDs
that are designed to operate on existing fluorescent lamp ballasts and
thus the potential need for fluorescent lamp ballasts to exist. (CA
IOUs, No. 10 at pp. 1-2)
DOE agrees that TLEDs are currently desired as a low-cost initial
energy option and that the use of TLEDs is growing. DOE included in the
NIA analysis a greater penetration of UL Type A TLEDs through the
course of the analysis period.
GE views the retrofitting of fluorescent luminaires with TLEDs as a
short-term solution while the larger new installation market moves to
dedicated LED systems. In 10 or 15 years, more dedicated LED systems
will be installed and fewer TLEDs will be retrofitting fluorescent
luminaires. (GE, Public Meeting Transcript, No. 5 at p. 39) ASAP also
speculates that if TLEDs have lifetimes equal or longer than the
lifetimes of the fluorescent lamp ballasts that operate them, the TLEDs
could disrupt the normal fluorescent maintenance and replacement cycle.
Currently ballast failure in a fluorescent luminaire can present a
cost-effective opportunity for luminaire replacement with a LED
luminaire. However, if the fluorescent lamps have been replaced with
TLEDs and the ballast fails at a later point, this might no longer
present a cost-effective opportunity to convert the fixture to a
dedicated LED luminaire. ASAP cautioned that this might increase the
volume of UL Type A TLEDs that operate on a fluorescent lamp ballast.
(ASAP, No. 7 at p. 5)
ASAP stated that the widespread installation of TLEDs could create
an
[[Page 56574]]
extended ``hybrid'' phase where a LED light source is driven by a
ballast designed for a fluorescent light source. (ASAP, No. 7 at p. 5)
Philips stated that retrofit jobs using TLEDs to replace linear
fluorescent lamps is a big trend, noting that the prevalence of TLEDs
operating on fluorescent lamp ballasts is growing rapidly. (Philips,
No. 8 at pp. 12, 38)
DOE agrees that the use of UL Type A TLEDs can achieve early energy
savings that might prolong the conversion of the lighting system to
other technologies. DOE also agrees that this might encourage sites
using UL Type A TLEDs to replace a failed fluorescent lamp ballast with
another fluorescent lamp ballast to continue the life of the lighting
system. Shipment scenarios #3 and #4 incorporate the prolonged
shipments of fluorescent lamp ballasts to service systems modified to
use UL Type A TLEDs.
Lutron did not believe that there was a scenario where a consumer
would purchase a TLED and a fluorescent lamp ballast in a new system.
(Lutron, Public Meeting Transcript, No. 5 at p. 84) DOE disagrees with
Lutron. DOE's research indicates at least a few UL Type A TLED
manufacturers provide warranties for UL Type A TLEDs that are directly
related to the installation of a new ballast. However, DOE stipulates
that this is rare combination and that the major benefit of UL Type A
TLEDs is that this type TLED can operate on the existing fluorescent
lamp ballasts, thus reducing initial costs of installation.
DOE seeks comment whether the shipment scenarios under various
policy scenarios are reasonable and likely to occur. DOE seeks comment
and information on whether dimming ballasts should have a different
rate of decline than the similar non-dimming fluorescent lamp ballasts.
DOE seeks comments on which shipment scenario most accurately
characterizes future dimming FLB shipments. DOE seeks comments on which
of the four scenarios best characterize future shipments of fluorescent
lamp ballasts. See section VII.C for a list of issues on which DOE
seeks comment. Chapter 9 of the NOPD TSD provides details on DOE's
shipments analysis for fluorescent lamp ballasts.
G. National Impact Analysis
The NIA assesses the NES and the NPV from a national perspective of
total consumer costs and savings that would be expected to result from
amended standards at specific efficiency levels.\36\ (``Consumer'' in
this context refers to consumers of the product being regulated.) DOE
calculates the NES and NPV for the potential standard levels considered
based on projections of annual product shipments, along with the annual
energy consumption and total installed cost data from the energy use
and LCC analyses. For the present analysis, DOE projected the energy
savings, operating cost savings, product costs, and NPV of consumer
benefits over the lifetime of fluorescent lamp ballasts sold from 2023
through 2052.
---------------------------------------------------------------------------
\36\ The NIA accounts for impacts in the 50 states and
Washington, D.C.
---------------------------------------------------------------------------
DOE evaluates the effects of amended standards by comparing a case
without such standards with standards-case projections. The no-new-
standards case characterizes energy use and consumer costs for each
product class in the absence of amended energy conservation standards.
For this projection, DOE considers historical trends in efficiency and
various forces that are likely to affect the mix of efficiencies over
time. DOE compares the no-new-standards case with projections
characterizing the market for each product class if DOE adopted amended
standards at specific energy efficiency levels (i.e., the ELs or
standards cases) for that class. For the standards cases, DOE considers
how a given standard would likely affect the market shares of products
with efficiencies greater than the standard.
DOE uses a spreadsheet model to calculate the energy savings and
the national consumer costs and savings from each EL. Interested
parties can review DOE's analyses by changing various input quantities
within the spreadsheet. The NIA spreadsheet model uses typical values
(as opposed to probability distributions) as inputs.
Table IV.13 summarizes the inputs and methods DOE used for the NIA
analysis for the NOPD. Discussion of these inputs and methods follows
the table. See chapter 10 of the NOPD TSD for details.
Table IV.13--Summary of Inputs and Methods for the National Impact
Analysis
------------------------------------------------------------------------
Inputs Method
------------------------------------------------------------------------
Shipments.................... Annual shipments from shipments model.
Modeled Compliance Date of 2023.
Standard.
Efficiency Trends............ No-new-standards case. Standards cases.
Annual Energy Consumption per Annual weighted-average values are a
Unit. function of energy use at each EL.
Total Installed Cost per Unit Annual weighted-average values are a
function of cost at each EL.
Incorporates projection of future
product prices based on historical data.
Annual Energy Cost per Unit.. Annual weighted-average values as a
function of the annual energy
consumption per unit and energy prices.
Repair and Maintenance Cost Annual values do not change with
per Unit. efficiency level.
Energy Prices................ AEO2019 projections (to 2050) and
extrapolation through 2061.
Energy Site-to-Source and FFC A time-series conversion factor based on
Conversion. AEO2019 and/or the NEMS model.
Discount Rate................ 3 percent and 7 percent.
Present Year................. 2018.
------------------------------------------------------------------------
ULT stated that the NIA should rely on input from manufacturers.
(ULT, No. 6, at p. 10) Input from manufacturers as well as others was
captured via the comment process, and DOE considered the comments in
the development of the inputs that affect the NIA. Interviews were
conducted with manufacturers as part of the preliminary analysis
process, and DOE incorporated aggregated feedback during these
interviews into the inputs that feed the NIA.
During the framework public meeting, CA IOUs requested that DOE
provide interim values for statewide energy savings and unit savings
within the model. (CA IOUs, Public Meeting Transcript, No. 5 at pp.
111-112) NEMA also requested modifications to the typical NIA models
during the framework public meeting. NEMA
[[Page 56575]]
stated that for other rules, the NIA model is locked and certain inputs
cannot be modified or model elements are not readily understandable in
the TSD. (NEMA, Public Meeting Transcript, No. 5 at pp. 116-118) DOE
acknowledges these requests. The LCC provides unit-level savings. DOE
also provides detail as to how the model works and how it can be
modified in chapter 10 and appendix 10A of the NOPD TSD.
1. Product Efficiency Trends
A key component of the NIA is the trend in energy efficiency
projected for the no-new-standards case and each of the standards
cases. Section IV.E.8 of this document describes how DOE developed an
energy efficiency distribution for the no-new-standards case (which
yields a shipment-weighted average efficiency) for each of the
considered product classes for the year of anticipated compliance with
an amended standard.
For the standards cases, DOE used a ``roll-up'' scenario to
establish the shipment-weighted efficiency for the year that standards
are assumed to become effective (2023). In this scenario, the market
shares of products in the no-new-standards case that do not meet the
standard under consideration would ``roll up'' to meet the amended
standard level, and the market share of products above the standard
would remain unchanged.
ASAP recommended analyzing the TLED market to evaluate its effect
on the overall energy savings over time. (ASAP, No. 7 at p. 5) DOE
includes a change in UL Type A TLED penetration over time in this
analysis. As the mixture of lamps operated by the ballast changes to
include differing amount of UL Type A TLEDs, the NES is affected.
CA IOUs suggested accounting for energy savings from standards-
induced shifts away from fluorescent lamp ballasts. CA IOUs raised a
concern if the analysis only examined fluorescent lamp ballasts and not
the energy savings of potential shifts to other lighting technologies.
(CA IOUs, Public Meeting Transcript, No. 5 at pp. 103-104; CA IOUs, No.
10 at p. 11) Lutron stated that FLB shipments are declining at an
accelerating rate and potential new amended standards can only affect
shipments. (Lutron, Public Meeting Transcript, No. 5 at p. 41) Also
during the framework public meeting, NEEA discussed the possibility of
setting a potential standard for dimming ballasts that would eliminate
some of the dimming ballasts. NEEA suggested that consumers would
switch to LED options. NEEA suggested that there should be a scenario
that examines consumers switching to LED systems. (NEEA, Public Meeting
Transcript, No. 5 at p. 102)
DOE has included within the NIA model a standards-induced shift
scenario in which if EL 1 is selected 25 percent of the consumers would
migrate to a new LED technology. If EL 2 is selected 50 percent of the
consumers would migrate to a new LED technology, and if EL 3 is
selected 75 percent of the consumers would migrate to a new LED
technology. Within the NIA model, the percentage of customers migrating
away is not fixed and can be changed by the user.
Philips speculated that if the incremental ballast price from
ballast modifications necessary for compliance to a potential new,
amended standard does not pay back within 2 years using the incremental
energy savings, customers will choose something else, and in reality it
will lead to additional LED adoption. (Philips, No. 8 at pp. 36-37) CA
IOUs stated that first costs can still be a barrier to LED adoption,
and if potential new energy efficiency standards for fluorescent lamp
ballasts increase the costs for the ballasts, the result will likely
accelerate the shift towards more efficient LEDs. (CA IOUs, No. 10 at
p. 11)
Within DOEs standard-induced shift away from a FLB scenario, DOE
modeled the shift to occur at different increments at each EL and not
at a specific PBP or specific increase in FLB price. The PBPs vary for
all of the product classes and ballasts. The potential cost
differential between the baseline ballast and a more efficient EL
ballast vary across the products classes as well.
NEEA stated that although LED replacements of traditional lighting
are more expensive than traditional lighting systems, the prices will
reduce over time. (NEEA, Public Meeting Transcript, No. 5 at p. 99)
However, NEEA also stated that the price of FLB systems is known,
whereas the price of LED systems in the future is a much bigger
variable. (NEEA, Public Meeting Transcript, No. 5 at pp. 101-102)
Philips concurred that although LED prices were initially higher, they
have reduced and they will be lower cost in the future. (Philips,
Public Meeting Transcript, No. 5 at pp. 102-103)
DOE agrees that the potential LED options may have a greater
initial cost than a potential compliant fluorescent lamp ballast.
Within the standards-induced shift away from the FLB scenario, DOE
assumed an equal mixture of TLEDs (UL Type B and C), LED retrofit kits,
and new LED luminaires. DOE researched public pricing for each of these
devices and developed and aggregate price for the potential LED option.
DOE also developed an aggregate device efficacy for the potential
option. Using DOE forecasts for future efficacy improvements circa
2023, DOE modeled the efficacy for the LED option in 2023. Using the
engineering analysis and system light output, DOE reverse-engineered
the input power and price for the LED option. For more information on
the methodology refer to the Appendix 10D of chapter 10 of the NOPD
TSD.
DOE seeks comment on the percentage of customers to model in a
standards-induced shift that would migrate away from FLB technology.
DOE seeks comments on the specific incremental cost in fluorescent lamp
ballasts that could trigger a standards-induced shift away from
fluorescent lamp ballasts. DOE seeks comment on the approach for input
power and price for LED devices considered in a standards-induced
shift. See section VII.C for a list of issues on which DOE seeks
comment.
DOE seeks comment on any potential impediments that would prevent
users of fluorescent lamp ballasts from switching to LED lighting to
garner additional energy savings. DOE seeks comment on the expected
effect of potential standards on the rate at which FLB consumers
transition to non-FLB technology. See section VII.C for a list of
issues on which DOE seeks comment. Chapter 10 of the NOPD TSD provides
details on DOE's NIA for fluorescent lamp ballasts.
2. National Energy Savings
The NES analysis involves a comparison of national energy
consumption of the considered products between each potential standards
case (EL) and the case with no new or amended energy conservation
standards. DOE calculated the national energy consumption by
multiplying the number of units (stock) of each product (by vintage or
age) by the unit energy consumption (also by vintage). DOE calculated
annual NES based on the difference in national energy consumption for
the no-new-standards case and for each higher efficiency standard case.
DOE estimated energy consumption and savings based on site energy and
converted the electricity consumption and savings to source energy
(i.e., the energy consumed by power plants to generate site
electricity) using annual conversion factors derived from AEO2019.
Cumulative energy
[[Page 56576]]
savings are the sum of the NES for each year over the timeframe of the
analysis.
In 2011, in response to the recommendations of a committee on
``Point-of-Use and Full-Fuel-Cycle Measurement Approaches to Energy
Efficiency Standards'' appointed by the National Academy of Sciences,
DOE announced its intention to use FFC measures of energy use and
greenhouse gas and other emissions in the NIA and emissions analyses
included in future energy conservation standards rulemakings. 76 FR
51281 (Aug. 18, 2011). After evaluating the approaches discussed in the
August 18, 2011 notice, DOE published a statement of amended policy in
which DOE explained its determination that EIA's National Energy
Modeling System (NEMS) is the most appropriate tool for its FFC
analysis and its intention to use NEMS for that purpose. 77 FR 49701
(Aug. 17, 2012). NEMS is a public domain, multi-sector, partial
equilibrium model of the U.S. energy sector \37\ that EIA uses to
prepare its AEO. The FFC factors incorporate losses in production, and
delivery in the case of natural gas, (including fugitive emissions) and
additional energy used to produce and deliver the various fuels used by
power plants. The approach used for deriving FFC measures of energy use
and emissions is described in appendix 10B of the NOPD TSD.
---------------------------------------------------------------------------
\37\ For more information on NEMS, refer to The National Energy
Modeling System: An Overview 2009, DOE/EIA-0581(2009), October 2009.
Available at https://www.eia.gov/analysis/pdfpages/0581(2009)index.php.
---------------------------------------------------------------------------
ULT stated that the NIA model needs to include a declining market
for fluorescent lamp ballasts. (ULT, No. 6 at p. 10) DOE agrees with
ULT and has included declining shipment scenarios within the shipment
analysis (chapter 10 of the NOPD TSD). The shipments analysis serves as
part of the basis of the NIA model, and thus the NIA model includes a
declining shipments scenario for fluorescent lamp ballasts.
NEMA and ULT stated that the NIA model should include the energy
reduction from the natural shift to solid-state lighting. (NEMA, No. 12
at p. 12; ULT, No. 6 at p. 10) As stated previously, the preliminary
analysis shipment model includes a declining market scenario that
includes a shift to solid-state lighting. This decline of fluorescent
lamps ballasts in transition to SSL is in the absence of standards (a
natural shift). This decline occurs in the no-new-standards case. The
NIA model characterizes the energy usage of the fluorescent lamp
ballast and compares the energy usage in both a no-new-standards and a
standards scenario. However, DOE has included within the NIA model a
scenario in which potential standards accelerate the shift away from
fluorescent lamp ballasts to SSL (standards-induced shift).
Both NEMA and ULT suggested that the NIA model should focus on the
effects of potential standards on drawing resources from lighting
manufacturers from other technologies (i.e., SSL) to comply with
potential standards. (NEMA, No. 12 at p. 12; ULT, No. 6 at p. 10) DOE
has not analyzed the potential effects of standards on resources and
investments of manufacturers as part of the NIA. The MIA assesses the
investments manufacturers must make to comply with potential standards
(see section IV.H).
During the framework public meeting, Lutron inquired whether DOE
could take credit for energy savings resulting from dimming ballast
standards across the country. California's Title 20 already contains a
dimming standard, and therefore Lutron suggested that DOE should only
include energy saving projections from the rest of the country and not
in California. (Lutron, Public Meeting Transcript, No. 5 at pp. 27-28)
The NIA model uses inputs from the shipments analysis factors in
distributions of different values of efficiency of ballasts. Therefore,
the ballasts that comply with California's Title 20 are incorporated
into the shipments model and thus the NIA model. If a potential
standard shifts ballasts to the California Title 20 values, any related
savings (or lack of savings because of already compliant ballasts)
would be captured by the NIA model.
3. Net Present Value Analysis
The inputs for determining the NPV of the total costs and benefits
experienced by consumers are (1) total annual installed cost, (2) total
annual operating costs (energy costs and repair and maintenance costs),
and (3) a discount factor to calculate the present value of costs and
savings. DOE calculates net savings each year as the difference between
the no-new-standards case and each standards case in terms of total
savings in operating costs versus total increases in installed costs.
DOE calculates operating cost savings over the lifetime of each product
shipped during the projection period.
DOE developed FLB price trends based on historical pricing
information for electronic ballasts. DOE applied the same trends to
project prices for each product class at each considered efficiency
level. By 2052, which is the end date of the projection period, the
average FLB price is projected to drop 8.2 percent relative to 2016.
DOE's projection of product prices is described in appendix 8C of the
NOPD TSD.
The operating cost savings are energy cost savings, which are
calculated using the estimated energy savings in each year and the
projected price of the appropriate form of energy. To estimate energy
prices in future years, DOE multiplied the average regional energy
prices by the projection of annual national-average residential energy
price changes in the Reference Case from AEO2019, which has an end year
of 2050.
In calculating the NPV, DOE multiplies the net savings in future
years by a discount factor to determine their present value. For this
NOPD, DOE estimated the NPV of consumer benefits using both a 3-percent
and a 7-percent real discount rate. DOE uses these discount rates in
accordance with guidance provided by the Office of Management and
Budget (OMB) to Federal agencies on the development of regulatory
analysis.\38\ The discount rates for the determination of NPV are in
contrast to the discount rates used in the LCC analysis, which are
designed to reflect a consumer's perspective. The 7-percent real value
is an estimate of the average before-tax rate of return to private
capital in the U.S. economy. The 3-percent real value represents the
``social rate of time preference,'' which is the rate at which society
discounts future consumption flows to their present value.
---------------------------------------------------------------------------
\38\ United States Office of Management and Budget. Circular A-
4: Regulatory Analysis. September 17, 2003. Section E. Available at
https://obamawhitehouse.archives.gov/omb/memoranda_m03-21/.
---------------------------------------------------------------------------
H. Manufacturer Impact Analysis
DOE performed an MIA to estimate the financial impacts of potential
amended energy conservation standards on manufacturers of fluorescent
lamp ballasts. DOE relied on GRIM, an industry cash flow model with
inputs specific to this rulemaking. The key GRIM inputs include data on
the industry cost structure, unit production costs, product shipments,
manufacturer markups, and investments in research and development (R&D)
and manufacturing capital required to produce compliant products. The
key GRIM outputs are the industry net present value (INPV), which is
the sum of industry annual cash flows over the analysis period,
discounted using the industry-weighted average cost of capital, and the
impact to domestic manufacturing employment. The GRIM calculates cash
flows using standard accounting principles and compares
[[Page 56577]]
changes in INPV between the no-new-standards case and each standards
case. The difference in INPV between the no-new-standards case and a
standards case represents the financial impact of the amended energy
conservation standard on manufacturers. To capture the uncertainty
relating to manufacturer pricing strategies following amended
standards, the GRIM estimates a range of possible impacts under
different markup scenarios.
DOE created initial estimates for the industry financial inputs
used in the GRIM (e.g., tax rate; working capital rate; net property
plant and equipment expenses; selling, general, and administrative
(SG&A) expenses; R&D expenses; depreciation expenses; capital
expenditures; and industry discount rate) based on publicly available
sources, such as company filings of form 10-K from the SEC or corporate
annual reports.\39\ DOE then further calibrated these initial estimates
during manufacturer interviews to arrive at the final estimates used in
the GRIM.
---------------------------------------------------------------------------
\39\ 10-Ks are collected from the SEC's EDGAR database: https://www.sec.gov/edgar.shtml or from annual financial reports collected
from individual company websites.
---------------------------------------------------------------------------
The GRIM uses several factors to determine a series of annual cash
flows starting with the announcement of potential standards and
extending over a 30-year period following the compliance date of
potential standards. These factors include annual expected revenues,
costs of sales, SG&A and R&D expenses, taxes, and capital expenditures.
In general, energy conservation standards can affect manufacturer cash
flow in three distinct ways: (1) Creating a need for increased
investment, (2) raising production costs per unit, and (3) altering
revenue due to higher per-unit prices and changes in sales volumes.
The GRIM spreadsheet uses inputs to arrive at a series of annual
cash flows, beginning in 2019 (the reference year of the analysis) and
continuing to 2052. DOE calculated INPVs by summing the stream of
annual discounted cash flows during this period. DOE used a real
discount rate of 9.6 percent for FLB manufacturers. This initial
discount rate estimate was derived using the capital asset pricing
model in conjunction with publicly available information (e.g., 10-year
treasury rates of return and company specific betas). DOE then
confirmed this initial estimate during manufacturer interviews.
Additional details about the GRIM, the discount rate, and other
financial parameters can be found in chapter 11 of the NOPD TSD.
1. Manufacturer Production Costs
Manufacturing more efficient fluorescent lamp ballasts is typically
more expensive because of the use of more complex components, which are
typically more costly than baseline components. The changes in the MPCs
of covered products can affect the revenues, gross margins, and cash
flow of the industry. Typically, DOE develops MPCs for the covered
products using reverse-engineering. These costs are used as an input to
the LCC analysis and NIA. However, because ballasts are difficult to
reverse-engineer, DOE directly derived end-user prices in the
engineering analysis and then used the end-user prices in conjunction
with markups to calculate the MPCs of fluorescent lamp ballasts. See
section IV.C for a further explanation of product price determination.
To determine MPCs of fluorescent lamp ballasts from the wholesale
prices calculated in the engineering analysis, DOE divided the
wholesale prices by the wholesaler markup to calculate the MSP. DOE
then divided the MSP by the manufacturer markup to get the MPCs. DOE
determined the wholesaler markup to be 1.23 and the manufacturer markup
to be 1.40 for all fluorescent lamp ballasts. Markups are further
described in section IV.H.4.
2. Shipments Projections
The GRIM estimates manufacturer revenues based on total unit
shipment projections and the distribution of those shipments by EL.
Changes in sales volumes and efficiency mix over time can significantly
affect manufacturer finances. For this analysis, the GRIM uses the
NIA's annual shipment projections from shipments scenario #3 (reference
case, see section IV.F.1) starting in 2019 (the reference year) and
ending in 2052 (the end year of the analysis period). See chapter 9 of
the NOPD TSD for additional details.
3. Product and Capital Conversion Costs
Potential amended energy conservation standards could cause
manufacturers to incur conversion costs to bring their production
facilities and equipment designs into compliance. DOE evaluated the
level of conversion-related expenditures that would be needed to comply
with each considered EL in each product class. For the MIA, DOE
classified these conversion costs into two major groups: (1) Product
conversion costs; and (2) capital conversion costs. Product conversion
costs are investments in research, development, testing, marketing, and
other non-capitalized costs necessary to make product designs comply
with amended energy conservation standards. Capital conversion costs
are investments in property, plant, and equipment necessary to adapt or
change existing production facilities such that new compliant product
designs can be fabricated and assembled.
To evaluate the level of capital conversion costs manufacturers
would likely incur to comply with the analyzed energy conservation
standards DOE used data submitted during manufacturer interviews and
data from the 2011 FL Ballast Rule to estimate costs to update
manufacturer production lines by product class. DOE then estimated the
number of production lines currently in existence and the number of
production lines that would be required to be updated at each analyzed
EL using DOE's public Compliance Certification Database. DOE then
multiplied these numbers together (i.e., capital conversion costs per
production line and number of production lines that would need to be
updated) to get the final estimated capital conversion costs for each
product class at each analyzed EL.
To evaluate the level of product conversion costs manufacturers
would likely incur to comply with the analyzed energy conservation
standards, DOE used data submitted during manufacturer interviews and
data from the 2011 FL Ballast Rule to estimate per model R&D and
testing and certification costs for each product class and EL. DOE then
estimated the number of models that would need to be redesigned for
each product class at each analyzed EL. DOE then multiplied these
numbers together to get the final estimated product conversion costs
for each product class at each analyzed EL.
In general, DOE assumes all conversion-related investments occur
between the year of publication of the final rule and the year by which
manufacturers must comply with the potential amended standards. The
conversion cost figures used in the GRIM can be found in Table V.7 and
section V.C of this document. For additional information on the
estimated capital and product conversion costs, see chapter 11 of the
NOPD TSD.
4. Markup Scenarios
To calculate the MPCs used in the GRIM, DOE divided the wholesaler
prices calculated in the engineering analysis by the wholesaler markup
and the manufacturer markup. The wholesaler markup was calculated in
the 2011 FL Ballast Rule by reviewing SEC 10-K reports of electrical
wholesalers. DOE also coordinated with
[[Page 56578]]
the National Association of Electrical Distributors by contacting two
representative electrical wholesalers, who confirmed that DOE's
calculated markups were consistent with their actual ballast markups.
DOE continued to use a wholesaler markup of 1.23 in this analysis.
The manufacturer markup accounts for the non-production costs
(i.e., SG&A, R&D, and interest) along with profit. Modifying the
manufacturer markup in the standards case yields different sets of
impacts on manufacturers. For the MIA, DOE modeled two standards-case
markup scenarios to represent uncertainty regarding the potential
impacts on prices and profitability for manufacturers following the
implementation of analyzed energy conservation standards: (1) A
preservation of gross margin percentage markup scenario; and (2) a
preservation of operating profit markup scenario. These scenarios lead
to different manufacturer markup values that, when applied to the MPCs,
result in varying revenue and cash flow impacts.
Under the preservation of gross margin percentage scenario, DOE
applied a single uniform ``gross margin percentage'' markup across all
ELs, which assumes that manufacturers would be able to maintain the
same amount of profit as a percentage of revenues at all ELs within a
product class. To calculate the preservation of gross margin markup,
DOE took the manufacturer markup used in the 2011 FL Ballast Rule and
compared it to the manufacturer markups calculated by examining the SEC
10-Ks of all publicly traded FLB manufacturers and confirmed this with
manufacturers during interviews. DOE determined that the manufacturer
markup used in the 2011 FL Ballast Rule was consistent with the current
SEC 10-Ks of the publicly traded FLB manufacturers and most
manufacturers agreed during manufacturer interviews. Therefore, DOE
used 1.40 as the manufacturer markup in the preservation of gross
margin markup scenario. DOE assumes that this markup scenario
represents an upper bound to industry profitability under analyzed
energy conservation standards.
Under the preservation of operating profit markup scenario, DOE
modeled a situation in which manufacturers are not able to increase
operating profit in proportion to increases in manufacturer production
costs. Under this scenario, as the cost of production increases,
manufacturers are generally required to reduce the manufacturer markups
to maintain cost competitive offerings in the market. Therefore, gross
margin (as a percentage) shrinks in the standards cases in this markup
scenario. This markup scenario represents an upper bound of industry
impacts (lower profitability) under amended energy conservation
standards.
A comparison of industry financial impacts under the two
manufacturer markup scenarios is presented in section V.C.1 of this
document.
5. Manufacturer Interviews
DOE interviewed manufacturers of fluorescent lamp ballasts and
asked them to describe their major concerns regarding a potential
rulemaking to amend the standards for FLBs. Manufacturer interviews are
conducted under non-disclosure agreements (NDAs), so DOE does not
document these discussions in the same way that it does public comments
and DOE's responses throughout the rest of this document. Manufacturers
identified two major areas of concern regarding potential FLB
standards: (1) Shift to SSL (i.e., LEDs) and (2) limited investment in
fluorescent lamp ballasts.
a. Shift to Solid-State Lighting
Manufacturers stated that the market is moving from fluorescent
lighting to LED lighting. As a result, shipments for fluorescent lamp
ballasts are declining. This trend is expected to continue in the
future absent amended energy conservation standards. Some manufacturers
expected sales in 2020 could decline by more than half compared to
2016. Given this market-driven move in the no-new-standards case from
fluorescent lighting to LED lighting, manufacturers commented that an
amended energy conservation would accelerate this transition.
Specifically, manufacturers stated that consumers of fluorescent lamp
ballasts are very price sensitive and any increase in consumer price as
a result of potential amended energy conservation standards would
significantly reduce FLB shipments.
DOE is aware that consumers of fluorescent lamp ballasts are
shifting to purchase all-LED systems. DOE accounts for this in the
Reference Case by adjusting shipments of fluorescent lamp ballasts
downward during the analysis period. Amended energy conservation
standards could accelerate the transition to LED lighting, and DOE
accounts for this potential accelerated decline by analyzing an
alternate shipment scenario in which there is a standards-induced shift
to SSL. (See section IV.F for further information.)
b. Limited Investment in Fluorescent Lamp Ballasts
Manufacturers commented that fluorescent lamp ballasts are a mature
technology and increases in efficiency can only be achieved at high
expense to the industry. Under potential amended energy conservation
standards, manufacturers stated that they might discontinue non-
compliant products instead of redesigning them, because investments in
fluorescent lamp ballasts would not be cost-effective. Therefore, any
amended energy conservation standards could result in reduced product
offerings. This would impact consumers in the replacement markets,
particularly in those instances in which there is a preference to
replace ballasts with exactly the same one. The LCC analysis takes into
account such effects on consumers; see section IV.E for further
details.
6. Discussion of MIA Comments
DOE received several comments related to assessing the manufacturer
impacts of potential amended standards for fluorescent lamp ballasts.
NEMA, Lutron, and ULT commented that manufacturers are unlikely to
develop or redesign new fluorescent lamp ballasts if energy
conservation standards result in the elimination of products from the
market. They added that setting efficiency limits will only hasten the
existing decline of this product category. (NEMA, No. 12 at p. 11;
Lutron, No. 9 at p. 3; ULT, No. 6 at p. 10) Similarly, Philips
commented that even though a new ballast could be designed and
produced, DOE needs to be very cognizant of the costs associated with
design, approbation, marketing, and implementation of that new, revised
design into luminaires and there might not be a positive business case.
(Philips, No. 8 at p. 15)
The MIA takes conversion costs and the shipment volumes into
account when analyzing the impacts on manufacturers. Thus, the results
of the MIA present the impacts of redesigning all non-compliant
products to comply with the analyzed standard level even if that is not
the path that manufacturers will choose.
In addition, NEMA pointed out that fluorescent lamp ballasts have
been subject to four energy conservation standards since the early
1990s, including a rulemaking completed in 2011, which NEMA stated had
a significant negative impact on manufacturers' INPV. NEMA commented
that because of a declining demand for these products, another
rulemaking could have a negative
[[Page 56579]]
impact on INPV. (NEMA, No. 12 at p. 8) Philips and ULT commented that
they used to run five and four FLB factories, respectively, and now
they are running one factory each as a result of declining sales.
(Philips, Public Meeting Transcript, No. 5 at p. 55; ULT, Public
Meeting Transcript, No. 5 at p. 56)
In those instances in which DOE proposes amended standards, it
analyzes the benefits and burdens of each standard independently and
weighs the potential burdens on the industry as one of the factors in
determining a final standard. In this notice DOE is proposing a
determination to not amend standards for fluorescent lamp ballasts. See
section V.D for further details.
V. Analytical Results and Conclusions
The following section addresses the results from DOE's analyses
with respect to the considered energy conservation standards for
fluorescent lamp ballasts. It addresses the ELs examined by DOE and the
projected impacts of each of these levels. Additional details regarding
DOE's analyses are contained in the NOPD TSD supporting this document.
A. Economic Impacts on Individual Consumers
DOE analyzed the cost effectiveness (i.e., the savings in operating
costs throughout the estimated average life of FLBs compared to any
increase in the price of, or in the initial charges for, or maintenance
expenses of, the FLBs which are likely to result from the imposition of
a standard at the EL) by considering the LCC and PBP at each EL. These
analyses are discussed in the following sections. DOE usually evaluates
the LCC impacts of potential standards on identifiable subgroups of
consumers that may be affected disproportionately by a national
standard. However, given the tentative conclusion discussed in section
V.D, DOE did not conduct a consumer subgroup analysis for this proposed
determination.
1. Life-Cycle Cost and Payback Period
In general, higher-efficiency products can affect consumers in two
ways: (1) Purchase price increases and (2) annual operating costs
decrease. Inputs used for calculating the LCC and PBP include total
installed costs (i.e., product price plus installation costs), and
operating costs (i.e., annual energy use, energy prices, energy price
trends, repair costs, and maintenance costs). The LCC calculation also
uses product lifetime and a discount rate. Chapter 8 of the NOPD TSD
provides detailed information on the LCC and PBP analyses.
Table V.1 shows the average LCC and PBP results for the ELs
considered for fluorescent lamp ballasts in this analysis.
Table V.1--Average LCC and PBP Results by Efficiency Level
------------------------------------------------------------------------
LCC savings Simple payback
Efficiency level 2018$ period years
------------------------------------------------------------------------
EL 1.................................... 0 12
EL 2.................................... 1 10
EL 3.................................... 2 10
------------------------------------------------------------------------
2. Rebuttable Presumption Payback
As discussed in section IV.E.9, EPCA establishes a rebuttable
presumption that an energy conservation standard is economically
justified if the increased purchase cost for a product that meets the
standard is less than three times the value of the first-year energy
savings resulting from the standard. In calculating a rebuttable
presumption PBP for each of the considered ELs, DOE used discrete
values, and, as required by EPCA, based the energy use calculation on
the DOE test procedure for fluorescent lamp ballasts. In contrast, the
PBPs presented in section V.A.1 were calculated using distributions
that reflect the range of energy use in the field. See chapter 8 of the
NOPD TSD for more information on the rebuttable presumption payback
analysis.
B. National Impact Analysis
This section presents DOE's estimates of the NES and the NPV of
consumer benefits that would result from each of the ELs considered as
potential amended standards.
1. Significance of Energy Savings
To estimate the energy savings attributable to potential amended
standards for fluorescent lamp ballasts, DOE compared their energy
consumption under the no-new-standards case to their anticipated energy
consumption under each EL. The savings are measured over the entire
lifetime of products purchased in the 30-year period that begins in the
year of anticipated compliance with amended standards (2023-2052).
Table V.2 presents DOE's projections of the NES for each EL considered
for fluorescent lamp ballasts. The savings were calculated using the
approach described in section IV.G of this document.
Table V.2--Cumulative National Energy Savings for Fluorescent Lamp Ballasts; 30 Years of Shipments
[2023-2052]
----------------------------------------------------------------------------------------------------------------
Efficiency level
Shipment scenario Energy type -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
quads
----------------------------------------------------------------------------------------------------------------
1..................................... Site Energy............. 0.000 0.000 0.000
Source Energy........... 0.000 0.000 0.000
FFC Energy.............. 0.000 0.000 0.000
2..................................... Site Energy............. 0.006 0.019 0.025
Source Energy........... 0.017 0.051 0.066
FFC Energy.............. 0.018 0.054 0.069
3 (Reference Case).................... Site Energy............. 0.018 0.055 0.069
[[Page 56580]]
Source Energy........... 0.049 0.145 0.183
FFC Energy.............. 0.051 0.152 0.192
4..................................... Site Energy............. 0.037 0.110 0.137
Source Energy........... 0.098 0.292 0.365
FFC Energy.............. 0.102 0.306 0.382
----------------------------------------------------------------------------------------------------------------
OMB Circular A-4 \40\ requires agencies to present analytical
results, including separate schedules of the monetized benefits and
costs that show the type and timing of benefits and costs. Circular A-4
also directs agencies to consider the variability of key elements
underlying the estimates of benefits and costs. For this proposed
determination, DOE undertook a sensitivity analysis using 9 years,
rather than 30 years, of product shipments. The choice of a 9-year
period is a proxy for the timeline in EPCA for the review of certain
energy conservation standards and potential revision of and compliance
with such revised standards.\41\ The review timeframe established in
EPCA is generally not synchronized with the product lifetime, product
manufacturing cycles, or other factors specific to fluorescent lamp
ballasts. Thus, such results are presented for informational purposes
only and are not indicative of any change in DOE's analytical
methodology. The NES sensitivity analysis results based on a 9-year
analytical period are presented in Table V.3. The impacts are counted
over the lifetime of fluorescent lamp ballasts purchased in 2023-2031.
---------------------------------------------------------------------------
\40\ U.S. Office of Management and Budget. Circular A-4:
Regulatory Analysis. September 17, 2003. Available at https://obamawhitehouse.archives.gov/omb/circulars_a004_a-4/.
\41\ Section 325(m) of EPCA requires DOE to review its standards
at least once every 6 years, and requires, for certain products, a
3-year period after any new standard is promulgated before
compliance is required, except that in no case may any new standards
be required within 6 years of the compliance date of the previous
standards. If DOE makes a determination that amended standards are
not needed, it must conduct a subsequent review within 3 years
following such a determination. As DOE is evaluating the need to
amend the standards, the sensitivity analysis is based on the review
timeframe associated with amended standards. While adding a 6-year
review to the 3-year compliance period adds up to 9 years, DOE notes
that it may undertake reviews at any time within the 6-year period
and that the 3-year compliance date may yield to the 6-year
backstop. A 9-year analysis period may not be appropriate given the
variability that occurs in the timing of standards reviews and the
fact that for some products, the compliance period is 5 years rather
than 3 years.
Table V.3--Cumulative National Energy Savings for Fluorescent Lamp Ballasts; 9 Years of Shipments
[2023-2031]
----------------------------------------------------------------------------------------------------------------
Efficiency level
Shipment scenario Energy type -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
quads
----------------------------------------------------------------------------------------------------------------
1..................................... Site Energy............. 0.000 0.000 0.000
Source Energy........... 0.000 0.000 0.000
FFC Energy.............. 0.000 0.000 0.000
2..................................... Site Energy............. 0.006 0.018 0.023
Source Energy........... 0.016 0.047 0.061
FFC Energy.............. 0.017 0.049 0.064
3 (Reference Case).................... Site Energy............. 0.012 0.036 0.047
Source Energy........... 0.032 0.097 0.124
FFC Energy.............. 0.034 0.101 0.130
4..................................... Site Energy............. 0.022 0.065 0.084
Source Energy........... 0.058 0.175 0.224
FFC Energy.............. 0.061 0.183 0.235
----------------------------------------------------------------------------------------------------------------
2. Net Present Value of Consumer Costs and Benefits
DOE estimated the cumulative NPV of the total costs and savings for
consumers that would result from the ELs considered for fluorescent
lamp ballasts. In accordance with OMB's guidelines on regulatory
analysis,\42\ DOE calculated NPV using both a 7-percent and a 3-percent
real discount rate. Table V.4 shows the consumer NPV results with
impacts counted over the lifetime of products purchased in 2023-2052.
---------------------------------------------------------------------------
\42\ U.S. Office of Management and Budget. Circular A-4:
Regulatory Analysis. September 17, 2003. Available at https://obamawhitehouse.archives.gov/omb/circulars_a004_a-4/.
[[Page 56581]]
Table V.4--Cumulative Net Present Value of Consumer Benefits for Fluorescent Lamp Ballasts; 30 Years of
Shipments
[2023-2052]
----------------------------------------------------------------------------------------------------------------
Efficiency level
Shipment scenario Discount rate (percent) -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
Billion 2018$
----------------------------------------------------------------------------------------------------------------
1..................................... 3....................... (0.000) 0.000 0.000
7....................... (0.000) (0.000) (0.000)
2..................................... 3....................... (0.050) (0.013) (0.031)
7....................... (0.053) (0.054) (0.080)
3 (Reference Case).................... 3....................... (0.146) (0.075) (0.159)
7....................... (0.133) (0.149) (0.228)
4..................................... 3....................... (0.293) (0.165) (0.350)
7....................... (0.256) (0.293) (0.453)
----------------------------------------------------------------------------------------------------------------
The NPV results based on the aforementioned 9-year analytical
period are presented in Table V.5. The impacts are counted over the
lifetime of products purchased in 2023-2031. As mentioned previously,
such results are presented for informational purposes only and are not
indicative of any change in DOE's analytical methodology or decision
criteria.
Table V.5--Cumulative Net Present Value of Consumer Benefits for Fluorescent Lamp Ballasts; 9 Years of Shipments
[2023-2031]
----------------------------------------------------------------------------------------------------------------
Efficiency level
Shipment scenario Discount rate (percent) -----------------------------------------------
1 2 3
----------------------------------------------------------------------------------------------------------------
Billion 2018$
----------------------------------------------------------------------------------------------------------------
1..................................... 3....................... (0.000) 0.000 0.000
7....................... (0.000) (0.000) (0.000)
2..................................... 3....................... (0.046) (0.010) (0.025)
7....................... (0.050) (0.051) (0.074)
3 (Reference Case).................... 3....................... (0.096) (0.030) (0.066)
7....................... (0.101) (0.106) (0.157)
4..................................... 3....................... (0.173) (0.058) (0.128)
7....................... (0.180) (0.192) (0.285)
----------------------------------------------------------------------------------------------------------------
C. Economic Impacts on Manufacturers
DOE performed an MIA to estimate the impact of analyzed energy
conservation standards on manufacturers of fluorescent lamp ballasts.
The following section describes the expected impacts on fluorescent
lamp manufacturers at each EL. Chapter 11 of the NOPD TSD explains the
analysis in further detail.
1. Industry Cash Flow Analysis Results
In this section, DOE provides the results from the MIA, which
examines changes in the industry that would result from the analyzed
standards. The following tables illustrate the estimated financial
impacts (represented by changes in INPV) of potential amended energy
conservation standards on manufacturers of fluorescent lamp ballasts,
as well as the conversion costs that DOE estimates manufacturers of
fluorescent lamp ballasts would incur at each EL.
To evaluate the range of cash-flow impacts on the FLB industry, DOE
modeled two markup scenarios that correspond to the range of
anticipated market responses to potential standards. Each scenario
results in a unique set of cash flows and corresponding industry values
at each EL. In the following discussion, the INPV results refer to the
difference in industry value between the no-new-standards case and the
standards case that result from the sum of discounted cash flows from
the reference year (2019) through the end of the analysis period
(2052).
To assess the upper (less severe) end of the range of potential
impacts on FLB manufacturers, DOE modeled a preservation of gross
margin markup scenario. This scenario assumes that in the standards
case, manufacturers would be able to pass along all the higher
production costs required for more efficient products to their
consumers. To assess the lower (more severe) end of the range of
potential impacts, DOE modeled a preservation of operating profit
markup scenario. The preservation of operating profit markup scenario
assumes that in the standards cases, manufacturers would be able to
earn the same operating margin in absolute dollars as they would in the
no-new-standards case. This represents the lower bound of industry
profitability in the standards cases.
Table V.6 and Table V.7 present the results of the industry cash
flow analysis for FLB manufacturers under the preservation of gross
margin and preservation of operating profit markup scenarios. See
chapter 11 of the NOPD TSD for results of the complete industry cash
flow analysis by product class.
[[Page 56582]]
Table V.6--Manufacturer Impact Analysis for Fluorescent Lamp Ballast--Preservation of Gross Margin Markup
Scenario
----------------------------------------------------------------------------------------------------------------
No-new-
Units standards case EL 1 EL 2 EL 3
----------------------------------------------------------------------------------------------------------------
INPV.......................... 2018$ millions.. 489.3 436.9 389.1 381.5
Change in INPV................ 2018$ millions.. .............. (52.4) (100.2) (107.8)
%............... .............. (10.7) (20.5) (22.0)
Product Conversion Costs...... 2018$ millions.. .............. 68.8 132.2 146.7
Capital Conversion Costs...... 2018$ millions.. .............. 17.8 33.8 36.4
Total Conversion Costs........ 2018$ millions.. .............. 86.6 166.0 183.1
----------------------------------------------------------------------------------------------------------------
Table V.7--Manufacturer Impact Analysis for Fluorescent Lamp Ballast--Preservation of Operating Profit Markup
Scenario
----------------------------------------------------------------------------------------------------------------
No-new-
Units standards case EL 1 EL 2 EL 3
----------------------------------------------------------------------------------------------------------------
INPV.......................... 2018$ millions.. 489.3 430.9 375.6 363.3
Change in INPV................ 2018$ millions.. .............. (58.4) (113.7) (126.0)
%............... .............. (11.9) (23.2) (25.8)
Product Conversion Costs...... 2018$ millions.. .............. 68.8 132.2 146.7
Capital Conversion Costs...... 2018$ millions.. .............. 17.8 33.8 36.4
Total Conversion Costs........ 2018$ millions.. .............. 86.6 166.0 183.1
----------------------------------------------------------------------------------------------------------------
2. Direct Impacts on Employment
DOE typically presents quantitative estimates of the potential
changes in production employment that could result from the analyzed
energy conservation standard levels. However, for this proposed
determination, DOE determined that no manufacturers have domestic FLB
production. Further, DOE has tentatively determined that amended energy
conservation standards are not needed. Therefore, the proposed
determination would not have a significant impact on domestic
employment in the FLB industry.
3. Impacts on Manufacturing Capacity
DOE does not anticipate any significant capacity constraints at any
of the analyzed energy conservation standards. The more efficient
components are currently being used in existing FLB models and
worldwide supply would most likely be able to meet the increase in
demand given the 3-year compliance period for any potential energy
conservation standards.
4. Impacts on Subgroups of Manufacturers
Using average cost assumptions to develop an industry cash-flow
estimate may not be adequate for assessing differential impacts among
manufacturer subgroups. Small manufacturers, niche equipment
manufacturers, and manufacturers exhibiting cost structures
substantially different from the industry average could be affected
disproportionately. DOE only identified one manufacturer subgroup for
fluorescent lamp ballasts, small manufacturers. Given the tentative
conclusion discussed in section V.D, DOE did not conduct a manufacturer
subgroup analysis on small business manufacturers for this proposed
determination.
5. Cumulative Regulatory Burden
One aspect of assessing manufacturer burden involves looking at the
cumulative impact of multiple DOE standards and the product-specific
regulatory actions of other Federal agencies that affect the
manufacturers of a covered product. While any one regulation may not
impose a significant burden on manufacturers, the combined effects of
several existing or impending regulations may have serious consequences
for some manufacturers, groups of manufacturers, or an entire industry.
Assessing the impact of a single regulation may overlook this
cumulative regulatory burden. In addition to energy conservation
standards, other regulations can significantly affect manufacturers'
financial operations. Multiple regulations affecting the same
manufacturer can strain profits and lead companies to abandon product
lines or markets with lower expected future returns than competing
products. For these reasons, DOE typically conducts an analysis of
cumulative regulatory burden as part of its rulemakings pertaining to
appliance efficiency. However, given the tentative conclusion discussed
in section V.D, DOE did not conduct a cumulative regulatory burden
analysis.
D. Proposed Determination
As required by EPCA, this notice analyzes whether amended standards
for fluorescent lamp ballasts would result in significant conservation
of energy, be technologically feasible, and be cost effective. (42
U.S.C. 6295(m)(1)(A) and (n)(2)) In addition to these criteria, DOE
also estimated the impact on manufacturers. The criteria considered
under 42 U.S.C. 6295(m)(1)(A) and the additional analysis are discussed
below. Because an analysis of potential cost effectiveness and energy
savings first require an evaluation of the relevant technology, DOE
first discusses the technological feasibility of amended standards. DOE
then addresses the cost effectiveness and energy savings associated
with potential amended standards.
1. Technological Feasibility
EPCA mandates that DOE consider whether amended energy conservation
standards for fluorescent lamp ballasts would be technologically
feasible. (42 U.S.C. 6295(m)(1)(A) and (n)(2)(B)) DOE has tentatively
determined that there are technology options that would improve the
efficiency of fluorescent lamp ballasts. These technology options are
being used in commercially available fluorescent lamp ballasts and
therefore are technologically feasible. (See section IV.A.3 for further
information.) Hence, DOE has tentatively determined that
[[Page 56583]]
amended energy conservation standards for fluorescent lamp ballasts are
technologically feasible.
2. Cost Effectiveness
EPCA requires DOE to consider whether energy conservation standards
for fluorescent lamp ballasts would be cost effective through an
evaluation of the savings in operating costs throughout the estimated
average life of the covered product compared to any increase in the
price of, or in the initial charges for, or maintenance expenses of,
the covered products which are likely to result from the imposition of
the standard. (42 U.S.C. 6295(m)(1)(A), (n)(2)(C), and
(o)(2)(B)(i)(II)) DOE conducted an LCC analysis to estimate the net
costs/benefits to users from increased efficiency in the considered
fluorescent lamp ballasts. (See results in Table V.1.) DOE then
aggregated the results from the LCC analysis to estimate the NPV of the
total costs and benefits experienced by the Nation. (See results in
Table V.4 and Table V.5.) As noted, the inputs for determining the NPV
are (1) total annual installed cost, (2) total annual operating costs
(energy costs and repair and maintenance costs), and (3) a discount
factor to calculate the present value of costs and savings.
DOE first considered the most efficient level, EL 3 (max tech),
which would result in negative NPV at the 3-percent and 7-percent
discount rates. On the basis of negative NPV, DOE tentatively
determined that EL 3 is not cost effective.
DOE then considered the next most efficient level, EL 2, which
would result in negative NPV at a 3-percent and 7-percent discount
rate. On the basis of negative NPV, DOE tentatively determined that EL
2 is not cost effective.
DOE then considered the next most efficient level, EL 1, which
would result in negative NPV at both a 3-percent and 7-percent discount
rate. On the basis of negative NPV, DOE tentatively determined that EL
1 is not cost effective.
3. Significant Conservation of Energy
EPCA also mandates that DOE consider whether amended energy
conservation standards for fluorescent lamp ballasts would result in
result in significant conservation of energy. (42 U.S.C. 6295(m)(1)(A)
and (n)(2)(A)) DOE estimates that amended standards for fluorescent
lamp ballasts would result in site energy savings of 0.018 quads at EL
1 and 0.069 quads at max tech levels over a 30-year analysis period
(2023-2052). (See results in Table V.2.) However, as provided in the
prior section, DOE has tentatively determined that amended standards at
the evaluated ELs would not be cost effective.
4. Other Analysis
In this analysis, DOE also conducted an MIA to estimate the impact
of potential energy conservation standards on manufacturers of
fluorescent lamp ballasts. (See results in Table V.6 and Table V.7.)
Each EL for all applicable product classes is estimated to result in
FLB manufacturers experiencing a loss in INPV.
5. Summary
In this proposed determination, based on the consideration of cost
effectiveness and the initial determination that amended standards
would not be cost effective, DOE has tentatively determined that energy
conservation standards for fluorescent lamp ballasts do not need to be
amended. DOE will consider all comments received on this proposed
determination in issuing any final determination.
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Order 12866
This proposed determination has been determined to be not
significant for purposes of Executive Order 12866, ``Regulatory
Planning and Review,'' 58 FR 51735 (Oct. 4, 1993). As a result, the OMB
did not review this proposed determination.
B. Review Under Executive Orders 13771 and 13777
On January 30, 2017, the President issued Executive Order (E.O.)
13771, ``Reducing Regulation and Controlling Regulatory Costs.'' E.O.
13771 stated the policy of the executive branch is to be prudent and
financially responsible in the expenditure of funds, from both public
and private sources. E.O. 13771 stated it is essential to manage the
costs associated with the governmental imposition of private
expenditures required to comply with Federal regulations.
Additionally, on February 24, 2017, the President issued E.O.
13777, ``Enforcing the Regulatory Reform Agenda.'' E.O. 13777 required
the head of each agency to designate an agency official as its
Regulatory Reform Officer (RRO). Each RRO oversees the implementation
of regulatory reform initiatives and policies to ensure that agencies
effectively carry out regulatory reforms, consistent with applicable
law. Further, E.O. 13777 requires the establishment of a regulatory
task force at each agency. The regulatory task force is required to
make recommendations to the agency head regarding the repeal,
replacement, or modification of existing regulations, consistent with
applicable law. At a minimum, each regulatory reform task force must
attempt to identify regulations that:
(1) Eliminate jobs, or inhibit job creation;
(2) Are outdated, unnecessary, or ineffective;
(3) Impose costs that exceed benefits;
(4) Create a serious inconsistency or otherwise interfere with
regulatory reform initiatives and policies;
(5) Are inconsistent with the requirements of Information Quality
Act, or the guidance issued pursuant to that Act, in particular those
regulations that rely in whole or in part on data, information, or
methods that are not publicly available or that are insufficiently
transparent to meet the standard for reproducibility; or
(6) Derive from or implement Executive Orders or other Presidential
directives that have been subsequently rescinded or substantially
modified.
DOE initially concludes that this rulemaking is consistent with the
directives set forth in these executive orders.
As discussed in this document, DOE is proposing not to amend energy
conservation standards for fluorescent lamp ballasts. Therefore, if
finalized as proposed, this proposed determination is expected to be an
E.O. 13771 other action.
C. Review Under the Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires
preparation of an initial regulatory flexibility analysis (IRFA) 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 (Aug. 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 rulemaking process. 68 FR 7990. DOE has made its
procedures and policies available on the Office of the General
Counsel's website (http://energy.gov/gc/office-general-counsel).
DOE reviewed this proposed determination under the provisions of
the Regulatory Flexibility Act and the policies and procedures
published on February 19, 2003. Because DOE is
[[Page 56584]]
proposing not to amend standards for fluorescent lamp ballasts, if
adopted, the determination would not amend any energy conservation
standards. On the basis of the foregoing, DOE certifies that the
proposed determination, if adopted, would have no significant economic
impact on a substantial number of small entities. Accordingly, DOE has
not prepared an IRFA for this proposed determination. DOE will transmit
this 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. Review Under the Paperwork Reduction Act
Manufacturers of fluorescent lamp ballasts must certify to DOE that
their products comply with any applicable energy conservation
standards. In certifying compliance, manufacturers must test their
products according to the DOE test procedures for fluorescent lamp
ballasts, including any amendments adopted for those test procedures.
DOE has established regulations for the certification and recordkeeping
requirements for all covered consumer products and commercial
equipment, including fluorescent lamp ballasts. 76 FR 12422 (March 7,
2011); 80 FR 5099 (Jan. 30, 2015). 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 approved by OMB under OMB control number
1910-1400. Public reporting burden for the certification is estimated
to average 35 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.
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. Review Under the National Environmental Policy Act of 1969
DOE is analyzing this proposed action in accordance with the
National Environmental Policy Act (NEPA) and DOE's NEPA implementing
regulations (10 CFR part 1021). DOE's regulations include a categorical
exclusion for actions which are interpretations or rulings with respect
to existing regulations. 10 CFR part 1021, subpart D, Appendix A4. DOE
anticipates that this action qualifies for categorical exclusion A4
because it is an interpretation or ruling in regards to an existing
regulation and otherwise meets the requirements for application of a
categorical exclusion. See 10 CFR 1021.410. DOE will complete its NEPA
review before issuing the final action.
F. Review Under Executive Order 13132
Executive Order 13132, ``Federalism,'' 64 FR 43255 (Aug. 10, 1999),
imposes certain requirements on Federal 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 determination and has tentatively 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 this
proposed determination. 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) Therefore, no further action is required by Executive
Order 13132.
G. Review Under 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,'' 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.
61 FR 4729 (Feb. 7, 1996). Regarding the review required by section
3(a), section 3(b) of Executive Order 12988 specifically requires that
Executive agencies make every reasonable effort to ensure that the
regulation: (1) Clearly specifies the preemptive effect, if any, (2)
clearly specifies any effect on existing Federal law or regulation, (3)
provides a clear legal standard for affected conduct while promoting
simplification and burden reduction, (4) specifies the retroactive
effect, if any, (5) adequately defines key terms, and (6) addresses
other important issues affecting clarity and general draftsmanship
under any guidelines issued by the Attorney General. Section 3(c) of
Executive Order 12988 requires Executive agencies to review regulations
in light of applicable standards in section 3(a) and section 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, this proposed determination meets
the relevant standards of Executive Order 12988.
H. Review Under the Unfunded Mandates Reform Act of 1995
Title II of the Unfunded Mandates Reform Act of 1995 (UMRA)
requires each Federal agency to assess the effects of Federal
regulatory actions on State, local, and Tribal governments and the
private sector. Public Law 104-4, sec. 201 (codified at 2 U.S.C. 1531).
For a proposed regulatory action likely to result in a rule that may
cause the expenditure 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 a written statement that estimates the
resulting costs, benefits, and other effects on the national economy.
(2 U.S.C. 1532(a) and (b)) The UMRA also requires a Federal agency to
develop an effective process to permit timely input by elected officers
of State, local, and Tribal governments on a proposed ``significant
intergovernmental mandate,'' and requires an agency plan for giving
notice and opportunity for timely input to potentially affected small
governments before establishing any requirements 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. DOE's policy statement is also available at
http://energy.gov/sites/prod/files/gcprod/documents/umra_97.pdf.
[[Page 56585]]
This proposed determination does not contain a Federal
intergovernmental mandate, nor is it expected to require expenditures
of $100 million or more in any one year by the private sector. As a
result, the analytical requirements of UMRA do not apply.
I. Review Under the Treasury and General Government Appropriations Act,
1999
Section 654 of the Treasury and General Government Appropriations
Act, 1999 (Pub. L. 105-277) requires Federal agencies to issue a Family
Policymaking Assessment for any rule that may affect family well-being.
This proposed determination would not have any impact on the autonomy
or integrity of the family as an institution. Accordingly, DOE has
concluded that it is not necessary to prepare a Family Policymaking
Assessment.
J. Review Under 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 proposed
determination would not result in any takings that might require
compensation under the Fifth Amendment to the U.S. Constitution.
K. Review Under the Treasury and General Government Appropriations Act,
2001
Section 515 of the Treasury and General Government Appropriations
Act, 2001 (44 U.S.C. 3516 note) provides for Federal agencies to review
most disseminations of information to the public under information
quality 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 this NOPD under the OMB and DOE
guidelines and has concluded that it is consistent with applicable
policies in those guidelines.
L. Review Under 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 OIRA
at 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 promulgates 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 Executive Order; and (2) is
likely to have a significant adverse effect on the supply,
distribution, or use of energy, or (3) is designated by the
Administrator of OIRA as a significant energy action. For any proposed
significant energy action, the agency must give a detailed statement of
any adverse effects on energy supply, distribution, or use should the
proposal be implemented, and of reasonable alternatives to the action
and their expected benefits on energy supply, distribution, and use.
Because this proposed determination does not propose amended energy
conservation standards for fluorescent lamp ballasts, it is not a
significant energy action, nor has it been designated as such by the
Administrator at OIRA. Accordingly, DOE has not prepared a Statement of
Energy Effects.
M. Information Quality
On December 16, 2004, OMB, in consultation with the Office of
Science and Technology Policy (OSTP), issued its Final Information
Quality Bulletin for Peer Review (the Bulletin). 70 FR 2664 (Jan. 14,
2005). The Bulletin establishes that certain scientific information
shall be peer reviewed by qualified specialists before it is
disseminated by the Federal Government, including influential
scientific information related to agency regulatory actions. The
purpose of the bulletin is to enhance the quality and credibility of
the Government's scientific information. Under the Bulletin, the energy
conservation standards rulemaking analyses are ``influential scientific
information,'' which the Bulletin defines as ``scientific information
the agency reasonably can determine will have, or does have, a clear
and substantial impact on important public policies or private sector
decisions.'' Id. at 70 FR 2667.
In response to OMB's Bulletin, DOE conducted formal peer reviews of
the energy conservation standards development process and the analyses
that are typically used and has prepared a report describing that peer
review.\43\ Generation of this report involved a rigorous, formal, and
documented evaluation using objective criteria and qualified and
independent reviewers to make a judgment as to the technical/
scientific/business merit, the actual or anticipated results, and the
productivity and management effectiveness of programs and/or projects.
DOE has determined that the peer-reviewed analytical process continues
to reflect current practice, and the Department followed that process
for developing its determination in the case of the present action.
---------------------------------------------------------------------------
\43\ ``Energy Conservation Standards Rulemaking Peer Review
Report.'' 2007. Available at http://energy.gov/eere/buildings/downloads/energy-conservation-standards-rulemaking-peer-review-report-0.
---------------------------------------------------------------------------
VII. Public Participation
A. Participation in the Webinar
The time and date of the webinar are listed in the DATES section at
the beginning of this document. If no participants register for the
webinar then it will be cancelled. Webinar registration information,
participant instructions, and information about the capabilities
available to webinar participants will be published on DOE's website:
https://www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=3. Participants are responsible for ensuring
their systems are compatible with the webinar software.
Additionally, you may request an in-person meeting to be held prior
to the close of the request period provided in the DATES section of
this document. Requests for an in-person meeting may be made by
contacting Appliance and Equipment Standards Program staff at (202)
287-1445 or by email: [email protected].
B. Submission of Comments
DOE will accept comments, data, and information regarding this
proposed determination no later than the date provided in the DATES
section at the beginning of this proposed determination. Interested
parties may submit comments, data, and other information using any of
the methods described in the ADDRESSES section at the beginning of this
document.
Submitting comments via http://www.regulations.gov. The http://www.regulations.gov web page will require you to provide your name and
contact information. Your contact information will be viewable to DOE
Building Technologies staff only. Your contact information will not be
publicly viewable except for your first and last names, organization
name (if any), and submitter representative name (if any). If your
comment is not processed properly because of technical difficulties,
DOE will use this information to contact you. If DOE cannot read your
comment due to technical difficulties and cannot contact you for
clarification, DOE may not be able to consider your comment.
However, your contact information will be publicly viewable if you
include it in the comment itself or in any documents attached to your
comment.
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Any information that you do not want to be publicly viewable should not
be included in your comment, nor in any document attached to your
comment. Otherwise, persons viewing comments will see only first and
last names, organization names, correspondence containing comments, and
any documents submitted with the comments.
Do not submit to http://www.regulations.gov information for which
disclosure is restricted by statute, such as trade secrets and
commercial or financial information (hereinafter referred to as
Confidential Business Information (CBI)). Comments submitted through
http://www.regulations.gov cannot be claimed as CBI. Comments received
through the website will waive any CBI claims for the information
submitted. For information on submitting CBI, see the Confidential
Business Information section.
DOE processes submissions made through http://www.regulations.gov
before posting. Normally, comments will be posted within a few days of
being submitted. However, if large volumes of comments are being
processed simultaneously, your comment may not be viewable for up to
several weeks. Please keep the comment tracking number that http://www.regulations.gov provides after you have successfully uploaded your
comment.
Submitting comments via email, hand delivery/courier, or postal
mail. Comments and documents submitted via email, hand delivery/
courier, or postal mail also will be posted to http://www.regulations.gov. If you do not want your personal contact
information to be publicly viewable, do not include it in your comment
or any accompanying documents. Instead, provide your contact
information in a cover letter. Include your first and last names, email
address, telephone number, and optional mailing address. The cover
letter will not be publicly viewable as long as it does not include any
comments.
Include contact information each time you submit comments, data,
documents, and other information to DOE. If you submit via postal mail
or hand delivery/courier, please provide all items on a CD, if
feasible, in which case it is not necessary to submit printed copies.
No telefacsimiles (faxes) will be accepted.
Comments, data, and other information submitted to DOE
electronically should be provided in PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file format. Provide documents that
are not secured, that are written in English, and that are free of any
defects or viruses. Documents should not contain special characters or
any form of encryption and, if possible, they should carry the
electronic signature of the author.
Campaign form letters. Please submit campaign form letters by the
originating organization in batches of between 50 to 500 form letters
per PDF or as one form letter with a list of supporters' names compiled
into one or more PDFs. This reduces comment processing and posting
time.
Confidential Business Information. Pursuant 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 via
email, postal mail, or hand delivery/courier two well-marked copies:
one copy of the document marked ``confidential'' including all the
information believed to be confidential, and one copy of the document
marked ``non-confidential'' with the information believed to be
confidential deleted. Submit these documents via email or on a CD, if
feasible. DOE will make its own determination about 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 that would result from
public disclosure, (6) when such information might lose its
confidential character due to the passage of time, and (7) why
disclosure of the information would be contrary to the public interest.
It is DOE's policy that all comments may be included in the public
docket, without change and as received, including any personal
information provided in the comments (except information deemed to be
exempt from public disclosure).
C. Issues on Which DOE Seeks Comment
Although DOE welcomes comments on any aspect of this proposal, DOE
is particularly interested in receiving comments and views of
interested parties concerning the following issues:
(1) DOE seeks comment on its evaluation of the efficiency of
dimming ballasts as BLE at full light output. See section IV.A.2.
(2) DOE seeks comment on the ELs under consideration for the
representative and non-representative product classes, including the
max tech levels. See section IV.B.5 and IV.B.6.
(3) DOE seeks comment on the methodology and results for estimating
end-user prices for fluorescent lamp ballasts in this analysis. See
section IV.C.
(4) DOE seeks comment on the methods to improve DOE's energy-use
analysis, as well as any data supporting alternate operating hour
estimates or assumptions regarding dimming of fluorescent lamp
ballasts. See section IV.E.
(5) DOE seeks comment on the type, prevalence, and operating hour
reductions related to the use of lighting controls used separately in
commercial, industrial, and residential sectors. See section IV.E.
(6) DOE seeks comment on the assumptions and methodology for
estimating annual operating hours. See section IV.E.
(7) DOE seeks comment whether the shipment scenarios under various
policy scenarios are reasonable and likely to occur. See section IV.F.
(8) DOE seeks comment and information on whether dimming ballasts
should have a different rate of decline than the similar non-dimming
fluorescent lamp ballasts. See section IV.F.
(9) DOE seeks comments on which shipment scenario accurately
characterizes future dimming FLB shipments. See section IV.F.
(10) DOE seeks comments on which of the four scenarios best
characterize future shipments of fluorescent lamp ballasts. See section
IV.F.
(11) DOE seeks comment on the percentage of customers to model in a
standards-induced shift that would migrate away from FLB technology.
See section IV.G.1.
(12) DOE seeks comments on the specific incremental cost in
fluorescent lamp ballasts that could trigger a standards-induced shift
away from fluorescent lamp ballasts. See section IV.G.1.
(13) DOE seeks comment on the approach for determining input power
and price for LED devices considered in a standards-induced shift. See
section IV.G.1.
(14) DOE seeks comment on the impediments that prevent users of
fluorescent lamp ballasts from switching to LED lighting. See section
IV.G.
(15) DOE seeks comment on the expected effect of potential
standards on
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the rate at which FLB consumers transition to non-FLB technology. See
section IV.G.
VIII. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of this notice of
proposed determination.
Signed in Washington, DC, on October 1, 2019.
Daniel R Simmons,
Assistant Secretary, Energy Efficiency and Renewable Energy.
[FR Doc. 2019-22537 Filed 10-21-19; 8:45 am]
BILLING CODE 6450-01-P