[Federal Register Volume 75, Number 226 (Wednesday, November 24, 2010)]
[Proposed Rules]
[Pages 71570-71596]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2010-28793]
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DEPARTMENT OF ENERGY
10 CFR Part 430
[Docket No. EERE-2009-BT-TP-0016]
RIN 1904-AB99
Energy Conservation Program: Test Procedures for Fluorescent Lamp
Ballasts
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Supplemental notice of proposed rulemaking.
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SUMMARY: The U.S. Department of Energy (DOE) proposes to revise its
test procedures for fluorescent lamp ballasts established under the
Energy Policy and Conservation Act. The proposed test method would
eliminate the use of photometric measurements in favor of purely
electrical measurements with the goal of reducing measurement
variation. Furthermore, this proposed test procedure would measure a
new metric, ballast luminous efficiency (BLE), which more directly
assesses the electrical losses in a ballast compared to the existing
ballast efficacy factor (BEF) metric. Rather than testing a ballast
with a resistive load as proposed in the March 24, 2010 notice of
proposed rulemaking (NOPR), the BLE test procedure would measure the
performance of a ballast while operating a fluorescent lamp.
DATES: DOE will accept comments, data, and information regarding this
supplemental notice of proposed rulemaking (SNOPR) no later than
December 27, 2010. See section V, ``Public Participation,'' of this
SNOPR for details.
ADDRESSES: Any comments submitted must identify the Fluorescent Lamp
Ballast Active Mode Test Procedure SNOPR, and provide the docket number
EERE-2009-BT-TP-0016 and/or Regulation Identifier Number (RIN) 1904-
AB99. Comments may be submitted using any of the following methods:
Federal eRulemaking Portal: http://www.regulations.gov. Follow the
instructions for submitting comments.
E-mail: [email protected]. Include the docket number
EERE-2009-BT-TP-0016 and/or RIN 1904-AB99 in the subject line of the
message.
Postal Mail: Ms. Brenda Edwards, U.S. Department of Energy,
Building Technologies Program, Mailstop EE-2J, 1000 Independence
Avenue, SW., Washington, DC 20585-0121. Please submit one signed paper
original.
Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of
Energy, Building Technologies Program, 6th Floor, 950 L'Enfant Plaza,
SW., Washington, DC 20024. Telephone: (202) 586-2945. Please submit one
signed paper original.
For detailed instructions on submitting comments and additional
information on the rulemaking process, see section V, ``Public
Participation,'' of this document.
Docket: For access to the docket to read background documents or
comments received, visit the U.S. Department of Energy, 6th Floor, 950
L'Enfant Plaza, SW., Washington, DC 20024, (202) 586-2945, between 9
a.m. and 4 p.m., Monday through Friday, except Federal holidays. Please
call Ms. Brenda Edwards at (202) 586-2945 for additional information
regarding visiting the Resource Room.
[[Page 71571]]
FOR FURTHER INFORMATION CONTACT: Ms. Linda Graves, U.S. Department of
Energy, Office of Energy Efficiency and Renewable Energy, Building
Technologies Program, EE-2J, 1000 Independence Avenue, SW., Washington,
DC 20585-0121. Telephone: (202) 586-1851. E-mail:
[email protected]. In the Office of General Counsel, contact Ms.
Elizabeth Kohl, U.S. Department of Energy, Office of the General
Counsel, GC-71, 1000 Independence Avenue, SW., Washington, DC 20585.
Telephone: (202) 586-7796. E-mail: [email protected].
For additional information on how to submit or review public
comments, contact Ms. Brenda Edwards, U.S. Department of Energy, Office
of Energy Efficiency and Renewable Energy, Building Technologies
Program, EE-2J, 1000 Independence Avenue, SW., Washington, DC 20585-
0121. Telephone: (202) 586-2945. E-mail: [email protected].
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Authority and Background
II. Summary of the Supplemental Notice of Proposed Rulemaking
III. Discussion
A. Existing Test Procedure
B. Metric
C. Test Procedures Considered
1. Resistor-based Ballast Efficiency Correlated to BEF
2. Lamp-based Ballast Efficiency Correlated to BEF
3. Improved Light-Output-Based Test Procedure
4. Relative System Efficacy
5. Dimming Ballast Test Procedure
D. Test Procedure Proposal
1. Test Conditions
2. Test Setup
3. Test Method
4. Calculations
5. Updates to Existing Test Procedure
6. Normative References for ANSI C82.2-2002
E. Burden To Conduct the Proposed Test Procedure
F. Impact on Measured Energy Efficiency
G. Scope of Applicability
H. Certification and Enforcement
IV. Procedural Issues and Regulatory Review
A. Executive Order 12866
B. National Environmental Policy Act
C. Regulatory Flexibility Act
D. Paperwork Reduction Act
E. Unfunded Mandates Reform Act of 1995
F. Treasury and General Government Appropriations Act, 1999
G. Executive Order 13132
H. Executive Order 12988
I. Treasury and General Government Appropriations Act, 2001
J. Executive Order 13211
K. Executive Order 12630
L. Section 32 of the Federal Energy Administration Act of 1974
V. Public Participation
A. Submission of Comments
B. Issues on Which DOE Seeks Comment
1. Impact of Ballast Output on Lamp Efficacy
2. Ballast Factor Calculation
3. Impact of Reference Lamp Measured Power Variation on Ballast
Factor
4. NVLAP Accreditation
VI. Approval of the Office of the Secretary
I. Authority and Background
Title III of the Energy Policy and Conservation Act (42 U.S.C. 6291
et seq.; EPCA) sets forth a variety of provisions designed to improve
energy efficiency. Part A of Title III (42 U.S.C. 6291-6309)
establishes the ``Energy Conservation Program for Consumer Products
Other Than Automobiles,'' which covers consumer products and certain
commercial products (all of which are referred to below as ``covered
products''), including fluorescent lamp ballasts (ballasts). (42 U.S.C.
6291(1), (2) and 6292(a)(13))
Under EPCA, the overall program consists essentially of the
following parts: Testing, labeling, certification and enforcement, and
Federal energy conservation standards. The testing requirements consist
of test procedures that manufacturers of covered products must use as
the basis for certifying to DOE that their products comply with energy
conservation standards and for representing the efficiency of their
products. Also, these test procedures must be used whenever testing is
required in an enforcement action to determine whether covered products
comply with EPCA standards.
Section 323 of EPCA (42 U.S.C. 6293) sets forth generally
applicable criteria and procedures for DOE's adoption and amendment of
test procedures. It states, for example, that ``[a]ny test procedures
prescribed or amended under this section shall be reasonably designed
to produce test results which measure energy efficiency, energy use, *
* * or estimated annual operating cost of a covered product during a
representative average use cycle or period of use, as determined by the
Secretary [of Energy], and shall not be unduly burdensome to conduct.''
(42 U.S.C. 6293(b)(3)) In addition, if DOE determines that a test
procedure amendment is warranted, it must publish proposed test
procedures and offer the public an opportunity to present oral and
written comments on them. (42 U.S.C. 6293(b)(2)) Finally, in any
rulemaking to amend a test procedure, DOE must determine ``to what
extent, if any, the proposed test procedure would alter the measured
energy efficiency * * * of any covered product as determined under the
existing test procedure.'' (42 U.S.C. 6293(e)(1)) If DOE determines
that the amended test procedure would alter the measured efficiency of
a covered product, DOE must amend the applicable energy conservation
standard accordingly. (42 U.S.C. 6293(e)(2))
As to fluorescent lamp ballasts specifically, DOE must ``prescribe
test procedures that are in accord with ANSI \1\ standard C82.2-1984
\2\ or other test procedures determined appropriate by the Secretary.''
(42 U.S.C. 6293(b)(5)) DOE's existing test procedures for ballasts,
adopted pursuant to these and the above-described provisions, appear at
10 CFR Part 430, Subpart B, Appendix Q.
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\1\ American National Standards Institute.
\2\ ``American National Standards for Fluorescent Lamp
Ballasts--Methods of Measurement.'' Approved October 21, 1983.
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The Energy Independence and Security Act of 2007 also amended EPCA
to require DOE to review test procedures for all covered products at
least once every seven years. DOE must either amend the test procedures
or publish notice in the Federal Register of any determination not to
amend a test procedure. (42 U.S.C. 6293(b)(1)(A)) To fulfill this
periodic review requirement, DOE invites comment on all aspects of the
existing test procedures for fluorescent lamp ballasts that appear at
Title 10 of the CFR part 430, subpart B, appendix Q (``Uniform Test
Method for Measuring the Energy Consumption of Fluorescent Lamp
Ballasts'').
In a separate rulemaking proceeding, DOE is considering amending
energy conservation standards for fluorescent lamp ballasts (docket
number EERE-2007-BT-STD-0016; hereinafter referred to as the
``fluorescent lamp ballast standards rulemaking''). DOE initiated that
rulemaking by publishing a Federal Register (FR) notice announcing a
public meeting and availability of the framework document (``Energy
Efficiency Program for Consumer Products: Public Meeting and
Availability of the Framework Document for Fluorescent Lamp Ballasts'')
on January 22, 2008. 73 FR 3653. On February 6, 2008, DOE held a public
meeting in Washington, DC to discuss the framework document for the
fluorescent lamp ballast energy conservation standards rulemaking
(hereinafter referred to as the ``2008 public meeting''). At that
meeting, attendees also discussed potential revisions to the test
procedure for active mode energy consumption relevant to this test
procedure rulemaking. On March 24, 2010, DOE published a notice of
public meeting and availability of the preliminary technical support
document
[[Page 71572]]
(TSD) for the fluorescent lamp ballast standards rulemaking. 75 FR
14319.
DOE also published a test procedure notice of proposed rulemaking
NOPR on March 24, 2010. 75 FR 14288. On April 26, 2010, DOE held a
joint public meeting to discuss the test procedure proposals in the
NOPR and the preliminary TSD for the fluorescent lamp ballast standards
rulemaking (hereafter ``NOPR public meeting''). All comments on the
fluorescent lamp ballast test procedure rulemaking are discussed in
section III of this proposed rulemaking.
As mentioned in the NOPR, DOE has also completed a standby mode and
off mode test procedure. The Energy Independence and Security Act of
2007 (Pub. L. 110-140) amended EPCA to require that, for each covered
product for which DOE's current test procedures do not fully account
for standby mode and off mode energy consumption, DOE amend the test
procedures to include standby mode and off mode energy consumption into
the overall energy efficiency, energy consumption, or other energy
descriptor for that product. If an integrated test procedure is
technically infeasible, DOE must prescribe a separate standby mode and
off mode energy use test procedure, if technically feasible. (42 U.S.C.
6295(gg)(2)(A)) DOE published a final rule addressing standby mode and
off mode energy consumption for fluorescent lamp ballasts in the
Federal Register on October 22, 2009. 74 FR 54445. This supplemental
notice of proposed rulemaking does not propose any changes to the
measurement of standby and off mode energy consumption for fluorescent
lamp ballasts.
II. Summary of the Supplemental Notice of Proposed Rulemaking
In this supplemental notice of proposed rulemaking (SNOPR), DOE
proposes to modify the current procedures for fluorescent lamp ballasts
to reduce measurement variation and reduce testing burden. The proposed
method would eliminate photometric measurements and propose the use of
electrical measurements of a lamp-and-ballast system. In addition, this
test procedure measures a new metric, ballast luminous efficiency
(BLE), which more directly assesses the electrical losses in a ballast
compared to the existing ballast efficacy factor (BEF) metric. The
SNOPR proposal also describes a new method for calculating the ballast
factor (BF) of a system. DOE also outlines the scope of applicability
of the test procedure and proposes a minor update of the existing test
procedure in appendix Q. The following paragraphs summarize these
proposed changes.
In the NOPR, DOE proposed a resistor-based ballast efficiency
measurement that would then be correlated to BEF. In response to
comments received citing the limitations of a resistor-based
measurement, DOE proposes in this SNOPR to measure ballast input power
and lamp arc power using only electrical measurements of a lamp-and-
ballast system. Variation in the measured power of a reference lamp is
minimized by the calculation of ballast luminous efficiency, where BLE
is equal to total lamp arc power divided by ballast input power. To
account for the increase in lamp efficacy associated with high-
frequency lamp operation versus low-frequency, DOE is also proposing an
adjustment to the BLE of low-frequency systems. DOE is proposing that
low-frequency BLE be multiplied by 0.9 to account for the approximately
10% increase in lighting efficacy associated with high-frequency lamp
operation. DOE also proposes a method for calculating the ballast
factor (BF) of a ballast by dividing the measured lamp arc power on the
test ballast by the measured lamp arc power on a reference ballast.
Ballast factor is under consideration in the fluorescent lamp ballast
standards rulemaking as criteria for defining product classes. In cases
where reference ballast operating conditions are unavailable, the SNOPR
provides a reference lamp power (specific to the ballast type) from an
ANSI standard or from empirical results. Particular lamp and ballast
pairings are specified for both the BLE and BF measurements.
In the preliminary technical support document for the fluorescent
lamp ballast standards rulemaking, DOE makes a preliminary
determination of the scope of coverage. Today's proposed test procedure
includes specific provisions for the testing of ballasts identified in
the preliminary determination of scope. If the scope of coverage
changes in later stages of the fluorescent lamp ballast standards
rulemaking, DOE will add or remove provisions from the test procedure
so that it is consistent with the final scope of coverage of standards.
See section III.G for further detail.
In any rulemaking to amend a test procedure, DOE must determine
``to what extent, if any, the proposed test procedure would alter the
measured energy efficiency * * * of any covered product as determined
under the existing test procedure.'' (42 U.S.C. 6293(e)(1)) If DOE
determines that the amended test procedure would alter the measured
efficiency of a covered product, DOE must amend the applicable energy
conservation standard accordingly. (42 U.S.C. 6293(e)(2)) The proposed
test procedure will describe the efficiency of a ballast in terms of a
new metric, BLE. To ensure that the standards developed in the ongoing
fluorescent lamp ballast standards rulemaking account for any changes
to the test procedure, DOE is developing the standards based on the
measured BLE generated by the active mode test procedure proposed in
this rulemaking. As a result, DOE proposes that use of any revised test
procedure, to be published as Appendix Q1 of 10 CFR part 430 Subpart B,
would be required concurrent with the compliance date of any amended
fluorescent lamp ballast standards. DOE is required by a consent decree
to issue any amended fluorescent lamp ballast standards by June 30,
2011.
As described in the NOPR, DOE notes that ballasts that operate one
or two 40 or 34 watt (W) 4-foot T12 medium bipin lamps (F40T12 and
F34T12), two 75 W or 60 W 8-foot T12 single pin slimline lamps (F96T12
and F96T12/ES); and two 110 W and 95 W 8-foot T12 recessed double
contact high output lamps (F96T12HO and F96T12HO/ES) are covered by
existing energy conservation standards. 10 CFR 430.32(m). Until use of
any amended test procedure to be published at Appendix Q1 is required,
manufacturers should continue testing these ballasts using the existing
test procedure to determine compliance with existing standards. In the
NOPR, DOE proposed to make minor updates to the existing test
procedure, published at Appendix Q to Subpart B of part 430. The SNOPR
does not affect this proposal. DOE would update the reference to ANSI
C82.2-1984 in the existing test procedure (appendix Q) to ANSI C82.2-
2002.\3\ Because DOE does not believe the updated standard will impose
increased testing burden or alter the measured BEF of fluorescent lamp
ballasts, DOE proposes that use of the amendments to Appendix Q be
required upon the effective date of any test procedure final rule, 30
days after publication. In addition, the test procedures for any
ballasts that operate in standby mode are also located in Appendix Q.
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\3\ ``American National Standards for Lamp Ballasts--Method of
Measurement of Fluorescent Lamp Ballasts,'' approved June 6, 2002.
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III. Discussion
A. Existing Test Procedure
The existing ballast test procedure (in Appendix Q to subpart B of
10 CFR part
[[Page 71573]]
430) determines the energy efficiency of a fluorescent lamp ballast
based on light output measurements and ballast input power. The metric
used is called ballast efficacy factor. BEF is the relative light
output divided by the power input of a fluorescent lamp ballast, as
measured under test conditions specified in ANSI standard C82.2-1984,
or as may be prescribed by the Secretary. (42 U.S.C. 6291(29)(C))
The BEF metric uses light output of the lamp-and-ballast system
instead of ballast electrical output power in its calculation of the
efficiency of a ballast. To measure relative light output, ANSI C82.2-
1984 directs the user to measure the photocell output \4\ of the test
ballast operating a reference lamp and the light output of a reference
ballast operating the same reference lamp. Dividing photocell output of
the test ballast system by the photocell output of the reference
ballast system yields relative light output or ballast factor.
Concurrent with measuring relative light output, the user is directed
to measure ballast input power. BEF is then calculated by dividing
relative light output by input power and multiplying by 100. A ballast
that produces more light than another ballast with the same input power
will have a larger BEF.
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\4\ The photocell output of a light source is measured in units
of watts. Photocell output (watts) is one method of measuring the
light output of a light source. Through the remainder of this
document, DOE refers to the output of a fluorescent lamp as ``light
output,'' even though the existing test procedure indicates
measuring the light with photocell output.
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The National Electrical Manufacturers Association (NEMA) commented
that BEF measurements would vary by plus or minus five percent and that
this variation is unacceptable when trying to differentiate between
products that vary in efficiency by three to five percent. (NEMA, No.
15 at p. 13) For BEF, the variation in measured power of the reference
lamps (rated power 2.5%) plus the variation in the
photometric measurement system itself leads to the plus or minus 5%
variation. Given the variation observed in BEF measurement, NEMA also
does not believe a thousandths place digit in a BEF measurement
discussed in the proposed rule has any statistical validity. In
contrast, NEMA noted that for the ballast efficiency (BE) measurement
proposed in the NOPR, the power analyzer equipment introduces plus or
minus 1.5% variation into the measurement and the current transducer
and wiring capacitances contribute 1% for a total of plus or minus 2.5%
variation (NEMA, Public Meeting Transcript, No. 12 at p. 15-16, 22-25).
DOE agrees that photometric based BEF measurements are more variable
than electrical measurement based BE measurements. In this test
procedure SNOPR, DOE is proposing a methodology that uses electrical
measurements of a lamp and ballast system to measure BLE. The BLE
metric includes a modification to the BE metric discussed in the NOPR
to account for changes in lamp efficacy as a result of differences in
lamp operating frequency.
B. Metric
In the NOPR, DOE proposed a resistor-based ballast efficiency
measurement that would then be correlated to BEF, for consistency with
the standards set forth at 42 U.S.C. 6295(g)(5) and (8). At the NOPR
public meeting, the Appliance Standards Awareness Project (ASAP) and
Earthjustice commented that they did not believe DOE was required to
regulate ballasts using the BEF metric. (ASAP, Public Meeting
Transcript, No. 12 at p. 98-99 \5\; Earthjustice, Public Meeting
Transcript, No. 12 at p. 100)
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\5\ A notation in the form ``ASAP, Public Meeting Transcript,
No. 12 at p. 98-99'' identifies a statement made in a public meeting
that DOE has received and has included in the docket of this
rulemaking. This particular notation refers to a comment: (1)
Submitted during the public meeting on April 26, 2010; (2) in
document number 12 in the docket of this rulemaking; and (3)
appearing on pages 98 through 99 of the transcript.
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In response to these comments, DOE is proposing a new metric to
describe the efficiency of a ballast called ballast luminous efficiency
(BLE). EPCA does not require DOE to set standards for fluorescent lamp
ballasts using the BEF metric and grants DOE the authority to use test
procedures for measuring energy efficiency that it determines are
appropriate. (42 U.S.C. 6291, 6295(g), and 6293(b)(5)) The BLE metric
and test procedure are based on the NEMA lamp-based ballast efficiency
(BE) test procedure considered in the test procedure NOPR. Similar to
the procedure considered in the NOPR, the BLE test procedure measures
ballast input power and lamp arc power of a lamp-and-ballast system.
The only difference between the BE procedure considered in the NOPR and
the proposed BLE test procedure is the proposed adjustment to the BLE
of low-frequency systems to account for the increase in lamp efficacy
associated with high-frequency lamp operation versus low-frequency.
Specifically, DOE is proposing that low-frequency BLE be multiplied by
0.9 to account for the approximately 10% increase in lighting efficacy
associated with high-frequency lamp operation. DOE also proposes a
method for calculating the ballast factor (BF) of a system by dividing
the measured lamp arc power on the test ballast by the measured lamp
arc power on a reference ballast. In cases where reference ballast
operating conditions are unavailable, the SNOPR provides a reference
lamp power (specific to the ballast type and operating frequency) from
an ANSI standard or from empirical results. The ballast factor
measurement is described in more detail in section III.D.4. Particular
lamp and ballast pairings are specified for both the BLE and BF
measurements.
DOE is proposing the BLE test procedure because it reduces
measurement variation and testing burden compared to the existing test
procedure. In contrast to BEF and RSE, the BLE metric can be used to
compare the efficiency across many different types of ballasts. DOE
also believes the use of a lamp-and-ballast system allows the ballast
to operate at its natural operating point and will more accurately
assess ballast performance than when the ballast test load is a
resistor. Furthermore, a resistive load can only model the effective
resistance of a lamp operated at a particular ballast factor, requiring
multiple ballast factor specific resistors to be specified and
increasing the testing cost to manufacturers. DOE also believes that
the use of electrical measurements and the calculation of BLE reduce
the impact of lamp manufacturing variation on the efficiency descriptor
compared to the existing test procedure.
C. Test Procedures Considered
In the NOPR, DOE proposed a resistor-based ballast efficiency
measurement correlated to BEF. DOE also provided descriptions of
alternative test procedures it considered in the course of developing
its proposal. Interested parties commented on the proposed methodology
and the three alternative methods considered. The following sections
discuss DOE's responses to interested party comments.
1. Resistor-Based Ballast Efficiency Correlated to BEF
In the NOPR, DOE proposed a test procedure to measure a resistor-
based BE, which would then be correlated to BEF. This procedure used
precision resistive loads to simulate the effective resistance of a
fluorescent lamp as the ballast load. In response, DOE received many
comments suggesting performance measurements of a lamp-and-ballast
system will provide more realistic data than a resistor and ballast
system while still reducing measurement variation compared to the
existing method. These
[[Page 71574]]
comments are discussed in additional detail in section III.C.2.
Discussed in the following paragraphs are comments DOE received on the
proposed transfer equations, the ballasts selected for testing, and
ballasts that do not operate resistors.
NEMA commented that it supports the BE method but prefers the
ballast to be paired with reference lamps rather than precision
resistors. NEMA and Osram Sylvania (OSI) commented that the ballast
needs to be paired with a resistor matched to the ballast factor of the
ballast for it to operate at its design point. A test procedure that
requires multiple ballast factor specific resistors would be very
expensive considering each resistive load bank costs 1000 to 2000
dollars and is only available on a custom order basis. (NEMA, No. 15 at
p. 5, 11; NEMA, Public Meeting Transcript, No. 12 at p. 21-22, 38-39,
105; OSI, Public Meeting Transcript, No. 12 at p. 80)
DOE agrees that specifying multiple ballast-factor specific
resistors would be burdensome and that the actual performance of a
ballast is better measured while it is operating the natural lamp load.
In this SNOPR, DOE proposes a procedure which is applicable to all
ballasts and uses lamp loads in the measurement of ballast luminous
efficiency.
DOE also received several comments in response to its proposed
transfer equations between BE and BEF. The Northwest Energy Efficiency
Alliance and the Northwest Power Conservation Council (NEEA and NPCC)
commented that the transfer equations between BE and BEF may be error
prone and may not attribute the correct BEF to a ballast. (NEEA & NPCC,
Public Meeting Transcript, No. 12 at p. 86-87, 89, 167-168; NEEA &
NPCC, No. 16 at p. 4-5) NEMA commented that a lighting designer might
prefer BE to be correlated to BEF in order to compare lighting
efficacy. NEMA also added that it does not believe small errors in the
transfer equation to be an issue, because lighting designers do not
require as high a level of accuracy when specifying a system. (NEMA,
No. 15 at p. 9) Philips commented that the approach with the transfer
equations is essentially to average the BEF values at a particular BE
value and to plot a line through these points. Philips noted that the
average BEF helps to account for the wide variation in BEF values.
(Philips, Public Meeting Transcript, No. 12 at p. 87-91) Philips also
indicated general agreement with the transfer equations for the
ballasts that operate four foot medium bipin lamps. (Philips, Public
Meeting Transcript, No. 12 at p. 94-95) OSI commented that the test
data used to develop the transfer equations could bias the results if
the BEF or BE values happened to test on the high or low end of the
expected distribution of data. (OSI, Public Meeting Transcript, No. 12
at p. 166-167) NEMA commented that a percentage shift in the transfer
equation between BE and BEF based on ballast factor would not
necessarily be the same for all ballast types. In addition, NEMA
commented that instant start ballasts should generally be more
efficient than programmed start ballasts and the transfer equations
should be consistent with this difference. (NEMA, Public Meeting
Transcript, No. 12 at p. 21, 25-26) DOE appreciates the comments on the
transfer equations. Because DOE is proposing a test procedure for BLE
without correlation to another metric, however, DOE does not need to
develop transfer equations or scaling relationships between equations.
In response to the test data presented in the fluorescent lamp
ballast standards rulemaking, NEEA and NPCC commented that they
understood DOE tested only normal BF ballasts and used scaling
relationships to derive the BE and BEF for the high and low BF
ballasts. (NEEA & NPCC, No. 32 at p. 4) DOE did test ballasts of all
ballast factors, including low and high BF models. However, DOE tested
low and high BF models using a resistor load that corresponded to a
lamp driven by a normal BF ballast in an effort to reduce the inventory
of resistors required for testing and reduce measurement burden.
Because the ballast operates differently when attached to a resistor
that does not properly match the ballasts' impedance, DOE developed
separate transfer equations to correlate BE to BEF for different bins
of BF (high, normal, and low \6\). In this SNOPR, however, DOE is
proposing a test procedure based on a lamp-and-ballast system that does
not employ resistive loads.
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\6\ High ballast factor: BF >= 1.10; Normal ballast factor: 0.78
> BF > 1.10; Low ballast factor: BF <= 0.78.
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In its testing for development of the resistor-based BE test method
for the NOPR, DOE observed that some ballasts did not operate
resistors. NEMA commented that its round robin testing for its own
investigation of the resistor-based BE test procedure showed that some
ballasts do not start or operate correctly with resistor loads. NEMA
commented that in some cases, the ballast senses the resistor is a non-
lamp load and will shut down or fail to start entirely. Some labs
overcome this issue by starting the ballast without this resistive load
connected and then introducing the resistor after a short time (as
short as 500 milliseconds). This setup can require program controllers
which add parasitic capacitance and inductance. (NEMA, No. 15 at p. 5,
8) NEMA and General Electric (GE) also commented that the issue of some
ballasts not operating resistors can be resolved by changing the
procedure to involve lamp loads rather than resistors. NEMA noted that
ballasts are designed to operate lamps, not resistors, and that using a
lamp load will ensure a ballast starts and operates properly. (NEMA,
Public Meeting Transcript, No. 12 at p. 39, 96-97; GE, Public Meeting
Transcript, No. 12 at p. 97-98; NEMA, No. 15 at p. 6) Finally, the CA
Utilities commented that they did not support the use of different test
procedures for ballasts that do and do not operate resistors. (CA
Utilities, No. 13 at p. 2-3) DOE agrees that a change of test procedure
to involve lamp loads rather than resistive loads will resolve the
issue of some ballasts not operating resistors properly and will
provide a procedure applicable to all ballasts.
2. Lamp-Based Ballast Efficiency Correlated to BEF
In the NOPR, DOE considered a lamp-based BE measurement that would
then be correlated to BEF using transfer equations. DOE defined this
lamp-based BE as lamp arc power divided by ballast input power such
that cathode heating power was included in the input but not in the
output. This procedure is based largely on the BE test procedure
described in the NEMA Alternative Test Procedure Handout, available at
http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/fl_ballast_tp_nema.pdf. In this SNOPR, DOE is proposing a
variation of lamp-based BE called ballast luminous efficiency (BLE).
BLE is equal to lamp arc power divided by input power and then
multiplied by an adjustment factor based on high- or low-frequency lamp
operation. This adjustment factor accounts for the decreased lighting
efficacy of low-frequency lamp operation. DOE references the BLE
procedure in the responses to comments that follow on the lamp-based BE
procedure, and provides more detail on the BLE procedure in section
III.D. As discussed in the following paragraphs, DOE received comments
suggesting a ballast should be tested with a lamp load (not a
resistor), as well as comments on the potential drawbacks and benefits
of the BE metric compared to BEF, a new method for the measurement of
ballast factor, and the
[[Page 71575]]
validity of the lamp-based BE procedure for ballasts other than
instant- and programmed-start ballasts with full cathode cutout.
DOE received several comments suggesting that BE is better measured
with a lamp-and-ballast system rather than a resistor and ballast
system. NEMA commented in the NOPR public meeting that it supports the
adoption of the lamp-based BE test procedure. NEMA commented that the
lamp-based BE procedure is simple, repeatable (testing variation of
2.5 percent), and can be used to generate a stand-alone BE
value or combined with a transfer equation to calculate BEF. NEMA also
indicated that the procedure provides a clear description of ballast
performance while minimizing the effects of reference lamps on the
ballast and lamp system. (NEMA, No. 15 at p. 2, 7, 14; NEMA, Public
Meeting Transcript, No. 12 at p. 20-21, 165-166; NEMA, Public Meeting
Transcript, No. 12 at p. 38) NEMA commented that the ballast should
operate a reference lamp when lamp arc power and ballast input power
are measured. (NEMA, No. 15 at p. 14) Finally, OSI commented that
ballast design laboratories are familiar with electrical efficiency
testing, and typically make these measurements rather than photometric
measurements when designing ballasts. (OSI, Public Meeting Transcript,
No. 12 at p. 60).
NEEA and NPCC commented that they prefer the usage of fluorescent
lamps as the load for a ballast when testing for ballast efficiency
compared to the usage of resistive loads. (NEEA & NPCC, No. 16 at p. 5;
NEEA & NPCC, No. 32 at p. 4 \7\) NEMA and GE also recommended that
lamps be utilized as the load for testing the BE of a ballast. They
also noted that lamps respond to the current supplied by a ballast, are
readily available and inexpensive to procure, and provide a natural
operating load for the ballast. (NEMA, Public Meeting Transcript, No.
12 at p. 22, GE, Public Meeting Transcript, No. 12 at p. 103; NEMA, No.
15 at p. 6-7) Philips agreed that the ballast should operate a lamp for
the measurement of BE. (Philips, Public Meeting Transcript, No. 12 at
p. 39) NEMA also commented that by correctly matching the lamp
impedance to the ballast, the maximum power transfer from the ballast
to the lamp occurs and the ballast operates at its design point and
design efficiency. (NEMA, No. 15 at p. 6) Reference lamps are
standardized and well characterized and can be procured from any lamp
manufacturer. (NEMA, No. 15 at p. 6) Philips and GE commented that the
lamp load should be a reference lamp to keep the ballast near its
designed operating point. The reference lamp provides a common
electrical operating point. (Philips, Public Meeting Transcript, No. 12
at p. 64; GE, Public Meeting Transcript, No. 12 at p. 63, 80) The CA
Utilities agreed, commenting that if DOE adopts a BE based test
procedure, it should use reference lamps as the ballast load. (CA
Utilities, No. 13 at p. 2)
---------------------------------------------------------------------------
\7\ This written comment was submitted to the docket of the
fluorescent lamp ballast standards rulemaking [Docket No. EERE-2007-
BT-STD-0016; RIN 1904-AB50].
---------------------------------------------------------------------------
DOE agrees that electrical measurements of ballast performance are
more realistic while the ballast is operating a lamp load compared to a
purely resistive load. Though a resistive load provides a constant and
repeatable operating point, a precision resistor is more expensive than
a lamp, does not change impedance in response to ballasts of different
ballast factor, and does not always provide the proper operating point
for the ballast. DOE also understands that electrical measurements are
commonly used in ballast design labs to ascertain performance. In this
SNOPR, DOE is proposing ballast performance measurements based on a
reference lamp-and-ballast system as the new test procedure for
fluorescent lamp ballasts based on the NEMA Test Procedure Handout and
comments from Philips and GE.
Philips and GE also commented that BE would be a more appropriate
metric than BEF, because BE is a metric that allows for the comparison
of all ballast systems, including different numbers of lamps or lamp
type, using a common basis for the metric. (Philips, Public Meeting
Transcript, No. 12 at p. 71; GE, Public Meeting Transcript, No. 12 at
p. 74) GE also commented that BE is a useful metric for original
equipment manufacturers when deciding which products to combine into
their lighting systems. (GE, Public Meeting Transcript, No. 12 at p.
74-75) NEEA and NPCC commented, however, that a lighting designer may
be more interested in meeting a lumen per unit area requirement than
achieving a one or two percent difference in ballast efficiency. (NEEA
& NPCC, Public Meeting Transcript, No. 12 at p. 73) NEEA and NPCC
commented that ballasts are not useful except as part of a lighting
system, suggesting that for a lighting product, lighting output per
unit power input is the metric that matters. Because ballasts of
increased electrical efficiency do not always produce the same amount
of light, NEEA and NPCC gave first preference to an improved light-
output-based test procedure, followed by a lamp-based BE metric without
correlation to BEF, and finally the resistor-based BE test procedure
with multiple ballast-factor specific resistors specified for each
lamp. NEEA and NPCC also commented that lamp operating frequency has a
large impact on light output. (NEEA & NPCC, No. 16 at p. 2, 5) In its
written comments, NEMA stated that BEF could be calculated from BE
using the reference arc power listed in ANSI C78.81-2010. NEMA also
noted that its method of correlating BE to BEF would allow
manufacturers to express the performance of the ballast in terms of BEF
to engineers and lighting consultants while still using an electrical
measurement for indicating compliance with energy conservation
standards. (NEMA, No. 15 at p. 9)
The CA Utilities commented that the existing test procedure is more
appropriate than the lamp-based BE measurement because it measures the
two most important parameters to ballast consumers: Input power and
light output. The CA Utilities commented that ballasts with the same BE
may produce more or less light from the same lamp depending on the
frequency at which they operate the lamp. Furthermore, the CA Utilities
commented that for high-frequency ballasts, variations in frequency,
crest factor, and wave shape can affect lamp efficacy. However, if DOE
proposes a BE test procedure, the CA Utilities commented that they
encourage DOE to keep the standards in terms of BE and not correlate to
BEF. (CA Utilities, No. 13 at p. 1-3)
DOE believes BLE is the best metric for assessing the performance
of a ballast. BLE provides for wide comparability among all types of
ballasts and can distinguish between the efficacy of high- and low-
frequency lamp operation. For ballast customers who prefer the BEF
metric, DOE agrees that manufacturers could provide a BEF value
calculated from the BLE measurement using the technique suggested by
NEMA. As explained in the paragraphs that follow, DOE proposes a
modification to the measurement of BE (resulting in the BLE metric) in
this SNOPR to address the concerns of the CA Utilities and NEEA and
NPCC on the impact of lamp operating frequency on light output. More
detail on the BLE metric proposed in this SNOPR is provided in section
III.D.
To account for the change in lighting efficacy as a result of lamp
operating frequency, DOE has developed a modification to the metric
measured in
[[Page 71576]]
the NEMA Alternative Test Procedure Handout that DOE calls BLE. Under
this metric, the lamp arc power for ballasts that operate lamps at low
frequency will be multiplied by 0.9. This adjustment factor compensates
for the reduced lamp efficacy that results from low-frequency
operation. Figure III.1 shows lamp efficacy increases with increased
operating frequency up to about 20 kHz, after which, lamp efficacy is
close to constant.\8\ DOE believes it is reasonable to assume a fixed
adjustment factor for all high-frequency ballasts, as most high-
frequency ballasts operate at greater than 20 kHz. DOE believes the
impact of lamp current crest factor (LCCF) and waveform to have a
minimal impact on efficacy compared to the difference between low and
high frequency operation. Lamp current crest factor is limited by ANSI
standards and does not affect lamp efficacy significantly. DOE also
believes the difference in waveform has a minimal impact on lamp
efficacy because the limitations on lamp current crest factor and power
factor constrain the variety of waveforms present in the market. DOE
seeks comment and data on the impact of LCCF and waveform on lamp
efficacy and on its decision to adjust BLE for low-frequency ballasts
by a factor of 0.9.
---------------------------------------------------------------------------
\8\ Rea, Mark S., ed. The IESNA Lighting Handbook: Reference &
Application, 9th Edition. 2000. The Illuminating Engineering Society
of America: New York, New York.
[GRAPHIC] [TIFF OMITTED] TP24NO10.375
DOE received comment that the term ballast efficiency already has
an accepted meaning in industry. NEMA commented that ballast efficiency
can be defined as a purely electrical measurement that documents the
true efficiency of a ballast by dividing total ballast output power by
ballast input power. NEMA commented that ballast efficiency by itself
does not account for the reduced system efficiency associated with
ballasts that employ cathode heating and suggested measuring a metric
defined as lamp arc power divided by ballast input power. (NEMA, No. 15
at p. 15; Philips, Public Meeting Transcript, No. 12 at p. 71-72)
Philips commented that while cathode heating does increase lamp column
efficacy, it does not offset the added energy required to heat the lamp
electrodes. (Philips, Public Meeting Transcript, No. 12 at p. 44-46) In
the NOPR, DOE defined ballast efficiency as lamp arc power divided by
ballast input power, but in the SNOPR, DOE is proposing the metric
ballast luminous efficiency (BLE), which is defined as lamp arc power
divided by ballast input power multiplied by an adjustment factor for
low-frequency operation. The alternative nomenclature BLE also
indicates that the metric is slightly different than a true ballast
efficiency measurement. DOE believes the BLE procedure accurately
accounts for the diminished system efficacy associated with lamp
cathode heating by only including lamp arc power (not cathode heating)
in the ballast output measurement.
GE and NEMA commented that the impact of lamp to lamp variation is
minimized with the lamp-based BE test procedure because variations in
lamp measured power will impact ballast input power and ballast output
power in such a way that the ratio of ballast efficiency is mostly
unaffected. (GE, Public Meeting Transcript, No. 12 at p. 62-63; NEMA,
No. 15 at p. 6) DOE agrees that the metric of lamp arc power divided by
ballast input power is mostly unaffected by lamp to lamp variation.
Because variations in lamp power affect both the numerator and
denominator, the calculation of BE (as defined in the NOPR) or BLE (as
defined in this SNOPR) minimizes the impact. This is in contrast to the
existing light-output based test procedure where variations in lamp
measured power have significant impact on ballast input power but not
relative light output.
NEMA commented that the lamp-based BE measurement would be
preferable to the resistor-based BE measurement proposed in the NOPR
because it would allow for measurement of ballast performance at steady
state. The resistor-based BE method involves measurement of ballast
performance within one minute of energizing the ballast, and the
resistor then needs to rest for one minute so that an increase in
temperature would not impact its resistance. NEMA commented that unlike
resistors, lamps do not have a duty cycle requirement necessitating
them to be run for long periods of time without deviation from the
desired operating point. (NEMA, No. 15 at p. 6) GE commented that the
lamp-based BE test procedure measures ballast performance at steady-
state, in contrast to the resistor-based test procedure proposed in the
NOPR. NEMA and GE
[[Page 71577]]
commented that certain ballast components such as magnetics and diodes
operate at higher efficiency once they have reached a steady state
temperature. Testing at steady state therefore captures the in-practice
performance of a ballast. (GE, Public Meeting Transcript, No. 12 at p.
82-83; NEMA, No. 15 at p. 6) Philips agreed that measurement of the
ballast performance is more realistic at steady state than within one
minute of energizing. (Philips, Public Meeting Transcript, No. 12 at p.
163)
DOE agrees that the lamp-based BE test procedure is simpler and
more representative of ballast performance than the resistor-based
method. Because a lamp does not have a short duty cycle, the lamp-and-
ballast system can be operated for a long enough time to reach steady
state and the ballast measurement can be representative of typical
operation. In this SNOPR, DOE is proposing a BLE test procedure in
which, like the BE method, the performance of a ballast is measured at
steady state while operating a lamp load.
The lamp-based BE test procedure would define particular lamp and
ballasts pairings for testing ballast performance. In its written
comments, NEMA recommended that instant-start ballasts and programmed-
rapid-start ballasts with cathode cut-out should be tested with a full
wattage load. (NEMA, No. 15 at p. 6-7) In this SNOPR, DOE is proposing
to pair ballasts with the most common wattage lamp for testing purposes
(see section III.D.2 for additional detail). In the case of instant-
start ballasts and programmed-rapid-start ballasts (with or without
full cathode cut-out), DOE is proposing that these ballasts operate
full-wattage lamps which are also the most common wattage in these
groupings. Some ballasts, such as rapid start T12 ballasts, are paired
with reduced wattage or energy saver lamps as this will be the most
common pairing. The proposal for lamp-and-ballast pairing in this SNOPR
is the same as discussed in the test procedure NOPR.
GE also commented on the transfer equations for BE to BEF, stating
that fitting a line of best fit to tested BEF and BE data would be a
reasonable method of developing a transfer equation between the two
metrics. (GE, Public Meeting Transcript, No. 12 at p. 64-65) GE
commented that separate empirically derived transfer equations would
likely be needed for ballasts that either employ or do not employ
cathode heating. (GE, Public Meeting Transcript, No. 12 at p. 65-66) At
the NOPR public meeting, Philips commented that it developed
correlations between BE and BEF for instant start ballasts and ballasts
with cathode cutout when using the lamp-based BE test procedure.
(Philips, Public Meeting Transcript, No. 12 at p. 36) NEMA commented
that separate transfer equations for ballasts of different ballast
factor would be unnecessary with a lamp-based BE test procedure. (NEMA,
No. 15 at p. 6) The CA Utilities commented that they did not agree with
using the same transfer equations for converting BE to BEF for high and
low frequency ballasts because of the change in lamp efficacy. A high-
and low-frequency ballast with the same BE would not have the same BEF.
(CA Utilities, No. 13 at p. 2) In its written comments, NEMA stated
that BEF could be calculated from BE using the reference arc power
listed in ANSI C78.81-2010 \9\. NEMA suggested multiplying BE by 100,
dividing by number of lamps, and dividing by the ANSI reference lamp
arc power. Philips commented that this technique is based on the
assumption that light output is directly proportional to arc power for
all ballast types over the ballast factor range from 0.75 to 1.15. NEMA
provided test data that supports this claim. NEMA also commented that
the calculation favors ballasts with less cathode heating, which is
consistent with the goal of promoting energy efficient systems. (NEMA,
No. 29 at p. 3; NEMA, No. 15 at p. 15-16; Philips, Public Meeting
Transcript, No. 12 at p. 51-53)
---------------------------------------------------------------------------
\9\ American National Standard for Electric Lamps--Double-Capped
Fluorescent Lamps--Dimensional and Electrical Characteristics,
Approved January 14, 2010.
---------------------------------------------------------------------------
In the SNOPR, DOE is proposing to measure BLE directly without
correlation to another metric. To convert the existing standards from
BEF to BLE, however, DOE used the NEMA suggested calculation (rather
than empirical correlations) to convert the existing BEF energy
conservation standards to BLE standards. DOE used different conversion
equations to assign the associated BLE for high- or low-frequency
ballasts, in agreement with the CA Utilities' comment.
To convert from BEF to BLE, DOE multiplied the BEF values by the
corresponding reference lamp arc power listed in Table III.2 and the
number of lamps operated by the ballast. As described in section
III.D.4, these reference arc powers originate from ANSI C78.81-2010 or
IEC 60081 Ed 5.0, the results of empirical analysis performed by DOE,
or scaling from a similar lamp type (as described in the next
paragraph). For example, for ballasts that operate two F34T12 lamps,
DOE multiplied 1.35 (BEF) by two (number of lamps) and 29.81 (high-
frequency reference lamp arc power based on empirical testing) which
resulted in a BLE of 80.5%. To convert the same BEF to a low-frequency
equivalent BLE, DOE multiplied 1.35 by two (number of lamps), 32 (low-
frequency reference lamp arc power), and 0.9 (lamp operating frequency
adjustment factor) which resulted in a BLE of 77.8%. Table III.1 lists
the existing standards and their corresponding values in BLE using the
methodology described in this paragraph.
DOE did not have high-frequency ANSI reference specifications or
empirical data for F40T12 or F96T12 lamps. To estimate high-frequency
lamp arc powers for the F40T12 lamp, DOE scaled the low-frequency ANSI-
based F40T12 reference power using the ratio of high-frequency to low-
frequency reference powers for the F34T12 lamp. For the F96T12 lamp,
DOE used the same methodology using the ratio of high- to low-frequency
reference power for the F96T12/ES lamp to scale the low-frequency ANSI-
based F96T12 reference power to high-frequency.
Table III.1--Existing BEF Standards and Corresponding BLE Conversion
----------------------------------------------------------------------------------------------------------------
Ballast Total Ballast
Ballasts that operate: input nominal efficacy BLE Low- BLE High-
voltage lamp watts factor frequency frequency
----------------------------------------------------------------------------------------------------------------
One F40T12 lamp..................................... 120/277 40 2.29 80.4 83.2
Two F40T12 lamps.................................... 120/277 80 1.17 82.1 85.0
Two F96T12 lamps.................................... 120/277 150 0.63 85.1 89.7
Two F96T12HO lamps.................................. 120/277 220 0.39 74.4 78.0
One F34T12 lamp..................................... 120/277 34 2.61 75.2 77.8
[[Page 71578]]
Two F34T12 lamps.................................... 120/277 68 1.35 77.8 80.5
Two F96T12/ES lamps................................. 120/277 120 0.77 83.9 88.4
Two F96T12/HO/ES lamps.............................. 120/277 190 0.42 68.0 71.3
----------------------------------------------------------------------------------------------------------------
While DOE is proposing the BLE metric in this SNOPR, DOE also
proposes a method for calculating ballast factor of a ballast by
dividing the measured lamp arc power on the test ballast by the
measured lamp arc power on a reference ballast. In some cases, when
reference ballast operating conditions are unavailable, the SNOPR
provides a reference lamp power from an ANSI standard or from empirical
results. As described in the preliminary analysis of the fluorescent
lamp ballast standards rulemaking, DOE is considering categorizing
ballasts into different groups (product classes) based on ballast
factor. These product classes could then be subject to different energy
conservation standards. DOE could use the ballast factor measurement in
this test procedure to assign a ballast to a particular product class.
See section III.D.4 for additional detail on the ballast factor
calculation.
In commenting on the lamp-based BE procedure, which is similar to
the suggested lamp-based BE test procedure outlined in the NEMA
Alternative Test Procedure Handout, Philips indicated that the NEMA
procedure was only valid for instant-start ballasts and programmed-
start ballasts with full cathode cutout. Philips stated that NEMA had
not completed enough due diligence for ballasts with cathode heating to
make a proposal. Philips indicated that the existing light output based
procedure could be used for ballasts without cathode heating. Philips
also commented that DOE could make the assumption in the test procedure
to include cathode heating as ballast losses and account for this
difference in the energy conservation standard. (Philips, Public
Meeting Transcript, No. 12 at p. 36, 38, 47, 65, 71-72) Then, in
written comments, NEMA provided supplemental information suggesting a
modification to the test setup to support ballasts that employ cathode
heating. NEMA indicated that two 1,000 ohm resistors should be placed
in parallel with both sets of lamp pins, generating a midpoint from
which to measure the lamp discharge voltage. NEMA also noted that the
resistors are of high enough impedance not to affect the lamp operating
characteristics and low enough impedance not to affect the measurement
system. (NEMA, No. 15 at p. 7) In response to the original NEMA
proposal that was applicable only to ballasts without cathode heating,
NEEA and NPCC commented that they do not support a test procedure that
is only applicable to certain ballasts. (NEEA & NPCC, No. 16 at p. 3-4)
NEEA and NPCC commented that the existing test procedure for BEF
applies equally well to all ballast types, which is not the case for
the lamp-based BE alternative, the NOPR resistor-based BE proposal, or
the procedure as outlined in the NEMA Alternative Test Procedure
Handout. GE commented that the use of more than one test procedure for
ballasts subject to the same energy conservation standard was not
desirable. (GE, Public Meeting Transcript, No. 12 at p. 97-98)
DOE agrees that the test procedure for fluorescent lamp ballasts
should be applicable to all ballasts subject to the same standards. DOE
believes that the test setup with resistors in parallel with the lamp
pins would allow for repeatable BE measurements, as well as BLE
measurements, for rapid- and programmed-start ballast regardless of the
level of cathode heating. Rather than require the ballast to be tested
to determine the level of cathode heating, DOE would use the voltage
divider for all rapid- and programmed-start ballasts. The voltage
divider would provide a position in the circuit to measure the lamp arc
voltage assuming the arc begins near the center of the ballast. This is
in contrast to a setup without the divider when lamp arc voltage would
vary depending on the position of the hotspot on each electrode. As a
result, DOE believes that NEMA's suggested test setup augments the BE
procedure, and the proposed BLE procedure, such that both procedures
are applicable to all ballasts.
3. Improved Light-Output-Based Test Procedure
In the NOPR, DOE considered improving the existing light-output
based test procedure to reduce measurement variation. The measurement
variation in the existing procedure can be attributed to operating
conditions, variation in measured power of reference lamps,
inconsistent output power measurements in determining ballast factor,
and ambient temperature. DOE invited comment on the clarified
methodologies and tighter tolerances for temperature and reference lamp
measured power.
The CA Utilities commented that they supported the improvements to
the existing test procedure presented in the NOPR to reduce measurement
variation, including tightening reference lamp tolerance, requiring
uniform operating conditions, taking measurements at constant voltage
(consistent with the general service fluorescent lamps test procedure
listed in 10 CFR part 430 appendix R to subpart B), using only one
approach for calculating BF, and testing universal voltage commercial
ballasts at 277V and residential universal voltage ballasts at 120V.
(CA Utilities, No. 13 at p. 2) NEEA and NPCC also supported the
improvements to the existing test procedure with the exception of the
ambient temperature specification, which they believed would be
extraordinarily costly. NEEA and NPCC preferred the improved light-
output-based method to all other test procedure proposals. (NEEA &
NPCC, No. 16 at p. 1-3) NEEA and NPCC also commented that DOE should
test the proposed changes with a large sample size so that statistics
such as standard deviation can be computed. NEEA and NPCC commented
that this data is needed to judge the existing test procedure against
the proposed amendment and alternatives. (NEEA & NPCC, No. 16 at p. 3)
General Electric (GE), Philips, and NEMA agreed that controlling a
photometric laboratory to 25 [deg]C 0.5 [deg]C is a
significant undertaking and would require upgrades of the air
conditioning and air handling controls and could require some
specialized equipment. (GE, Public Meeting Transcript, No. 12 at p. 59,
105; Philips, Public Meeting Transcript, No. 12 at p. 60-61; NEMA, No.
15 at p. 7) Philips and NEMA also commented that decreasing the
tolerance on reference lamps would significantly increase the burden in
identifying reference lamps compared to the already difficult process
of meeting
[[Page 71579]]
the current specification. (Philips, Public Meeting Transcript, No. 12
at p. 60-61; NEMA, No. 15 at p. 7-8) NEEA and NPCC disagreed with NEMA
on the issue of reference lamp variation, commenting that while the
process of identifying reference lamps is tedious, they did not see any
reason why this technique introduced unmanageable variation into the
test process. (NEEA & NPCC, No. 16 at p. 2) GE commented that the BEF
metric is based heavily on the input power to the ballast. However, a
vast majority of the input power is dependent on the lamp, and the
ballast manufacturer has no control over this lamp power. As a result,
input power and BEF will vary in response to the measured power of the
lamp, potentially making high performance ballasts look less efficient.
Furthermore, the BEF test procedure, as defined, contains some latitude
that permits variation between test laboratories. (GE, Public Meeting
Transcript, No. 12 at p. 35-36)
DOE agrees that a tighter tolerance on ambient temperature would be
more burdensome to manufacturers, though it would decrease measurement
variation. DOE also believes that tightening the tolerance on reference
lamp measured power would increase the burden for lamp identification
because fewer lamps would meet the more stringent specification. While
DOE agrees with NEEA and NPCC that the process of identifying reference
lamps can be accurately carried out at any test laboratory, because a
reference lamp can vary in measured power up to plus or minus 2.5% of
the rated lamp power (existing requirements) or up to 1% in the
improved light output based test procedure, the permitted variation in
measured power introduces variation into the BEF metric. The same
ballast paired with reference lamps of different measured power will
measure different ballast input power, impacting the value of BEF. All
other procedural improvements and clarifications including requiring
uniform operating conditions, taking measurements at constant voltage,
using only one approach for calculating BF, and testing universal
voltage commercial ballasts at 277V and residential universal voltage
ballasts and cold-temperature sign ballasts at 120V would reduce
testing variation without appreciably increasing testing burden. DOE
does not plan to investigate the improved light output based test
procedure through testing because it believes BLE to be a better metric
and test procedure. DOE believes its proposal of BLE is less burdensome
than an improved light-output based method, potentially reduces
measurement variation to a greater extent, and generates a
straightforward descriptor of electrical losses. The BLE measurement
and calculation also minimize the impact of lamp measured power
variation. Therefore, DOE believes there is minimal benefit to
requiring a tighter tolerance on reference lamp power variation in the
context of the proposed test procedure.
Because discrepancies may exist in BEF test data from different
sources, NEEA and NPCC suggested that any changes to the existing test
procedure should place ballasts both above and below the mean values,
not systematically generate tested performance above the mean. (NEEA &
NPCC, No. 16 at p. 6) GE commented that the discrepancies in data could
signify a compliance problem and that manufacturers should notify DOE
of observed instances of non-compliance. GE also indicated that
manufacturers may shop around at different laboratories to find an
improvement in ratings. (GE, Public Meeting Transcript, No. 12 at p.
35, 172-173) Philips commented that variation in test data between
different sources should be expected given the variation in the
underlying measurement technique. (Philips, Public Meeting Transcript,
No. 12 at p. 162-164, 173-174)
DOE understands that the existing test procedure has some latitude
in its definition in that several slightly different setups (lamp
operating conditions, reference lamps) and conditions are permitted.
Even the improved light-output-based procedure with its procedural
clarifications still allows a ballast to be tested with reference lamps
of slightly different measured power. These light-output-based
procedures and the BEF metric could allow for a systematic bias as GE
indicated at the NOPR public meeting. DOE believes that the proposal in
today's SNOPR of BLE limits the impact of reference lamp measured power
on the efficiency descriptor for fluorescent lamp ballasts and provides
a clearly defined procedure that limits procedural variations from test
facility to test facility. The BLE metric is more robust to changes in
reference lamp measured power because variations in lamp power
generally have a proportional effect on both the input power and lamp
arc power measurements (numerator and denominator, respectively).
Philips commented that BEF can only be used to compare ballasts of
similar light output. For example, T5 standard output and T8 ballasts
cannot be compared using BEF because of their different system lumen
outputs. (Philips, Public Meeting Transcript, No. 12 at p. 50, 70-71)
DOE agrees that BEF cannot be used to compare ballasts that are part of
systems with different light output. The measurement of ballast
luminous efficiency proposed in this SNOPR can be used to compare
ballasts that are part of systems with different light output.
4. Relative System Efficacy
In the NOPR, DOE considered a test procedure to measure the
relative system efficacy of fluorescent lamp ballasts. RSE is intended
to normalize the existing metric of BEF to rated lamp efficacy to make
it more comparable across different lamp-and-ballast systems. DOE
received comment from some interested parties regarding potential
problems and benefits resulting from the use of RSE.
The CA Utilities supported the normalization of BEF to RSE to allow
better comparison between ballasts that operate different numbers of
lamps. The CA Utilities recommended measuring BE, converting to BEF,
and finally converting to RSE or measuring BEF directly using light
output based measurements. The CA Utilities also commented that RSE is
more useful than BEF for designing and implementing rebate programs.
(CA Utilities, No. 13 at p. 3; CA Utilities, Public Meeting Transcript,
No. 12 at p. 41, 53-54, 67-68) Lutron and NEMA commented that if RSE is
based on photometric measurements, then RSE will suffer from the same
variation as the existing test procedure. (Lutron, Public Meeting
Transcript, No. 12 at p. 51, 54; NEMA, No. 15 at p. 14) Philips
commented that though RSE may allow for greater comparability of losses
among the product classes considered in the preliminary analysis, these
different categories of ballasts may need to be subject to different
standards. As the ballast operates increased wattage loads, efficiency
generally increases. As a result, RSE would not automatically reduce
the number of product classes. (Philips, Public Meeting Transcript, No.
34 at p. 54-55) NEEA and NPCC disagreed with the use of RSE, commenting
that the utility of RSE may be minimal to the lighting designer. The
lighting designer is interested in room cavity ratio, fixture
efficiency, fixture spacing, and other factors for meeting a lumen per
unit area requirement and not for a one or two percent efficiency
difference in the ballast. (NEEA & NPCC, Public Meeting Transcript, No.
12 at p. 72-73) Philips and NEMA commented that a lighting designer
might prefer BEF to RSE because BEF can be used directly to convert to
[[Page 71580]]
system lumen output while RSE must first be converted to BEF. (Philips,
Public Meeting Transcript, No. 12 at p. 73; NEMA, No. 15 at p. 13) The
CA Utilities commented that a more understandable efficiency metric
will help lighting designers with less expertise make better decisions
when specifying the ballasts for their lighting systems. (CA Utilities,
Public Meeting Transcript, No. 12 at p. 76)
Philips and NEMA commented that while RSE does give a set of
numbers that are easier to understand and can be compared for ballasts
operating the same lamp type, test data cannot be compared for
different lamp types. (Philips, Public Meeting Transcript, No. 12 at p.
54; NEMA, No. 15 at p. 8, 14) NEMA also commented that another problem
with RSE is that the four foot MBP lamp is referenced at 60 Hz.
Therefore, the rated wattage of 32.5 watts (W) only corresponds to a
low-frequency ballast operating at ballast factor of one. A high-
frequency ballast operating at ballast factor of one will require less
than 32.5 W. Because RSE is defined as BEF divided by one hundred and
multiplied by the total rated lamp power of the system, RSE normalizes
low- and high-frequency four foot MBP T8 systems with the same factor.
(NEMA, Public Meeting Transcript, No. 12 at p. 55) Philips commented
that because of the difference in the rated lamp power used to
normalize the values, comparison of four foot T8 high-frequency
ballasts to four foot T5 high-frequency ballasts is inappropriate.
(Philips, Public Meeting Transcript, No. 12 at p. 68-69, 101)
Though RSE could be modified such that BEF is normalized with a
rated power at the appropriate frequency, DOE believes that BLE has
many advantages to RSE. The BLE metric is measured directly with
electrical measurements and can be used to compare the efficiency of
ballasts that operate different numbers of lamps and different types of
lamps. The straightforward definition of BLE and its wide range of
comparability should help inexperienced lighting designers select more
efficient ballasts for their lighting systems to the same or greater
extent than the use of RSE.
5. Dimming Ballast Test Procedure
In the NOPR, DOE requested comment on potential test procedures for
dimming ballasts in the event they were added to the scope of coverage
in the fluorescent lamp ballast standards rulemaking. Philips commented
that testing a dimming ballast at full light output may be misleading
because a dimming ballast may have a different efficiency at reduced
light levels than at full light output. Furthermore, a practicable
method of characterizing the overall efficiency of a dimming ballast
had not yet been identified. (Philips, Public Meeting Transcript, No.
12 at p. 122-124) NEMA also commented in response to the energy
conservation standard that it has not conducted sufficient analysis to
determine the appropriate light level at which to test dimming ballasts
and that testing at multiple light levels would be burdensome. (NEMA,
No. 29 at p. 2 \10\) In written comments in response to the test
procedure NOPR, NEMA indicated that testing a dimming ballast at full
light output was acceptable so long as energy conservation standards
were adjusted appropriately--similar to standards for programmed start
versus instant start ballasts. (NEMA, No. 15 at p. 4-5) Because DOE is
not currently considering dimming ballasts in the scope of coverage in
the energy conservation standard, DOE is also not developing a test
procedure for these ballasts. If the scope of coverage later includes
dimming ballasts, DOE would consider NEMA's comment in development of a
dimming ballast test procedure.
---------------------------------------------------------------------------
\10\ This written comment was submitted to the docket of the
fluorescent lamp ballast standards rulemaking [Docket No. EERE-2007-
BT-STD-0016; RIN 1904-AB50).
---------------------------------------------------------------------------
D. Test Procedure Proposal
DOE is proposing a test procedure for the measurement of ballast
luminous efficiency (BLE) using electrical measurements of a lamp-and-
ballast system. This proposal is based on a test procedure developed by
NEMA and considered in the NOPR to measure lamp-based BE and correlate
the result to BEF. The proposal includes a calculation of ballast
factor without photometric measurements and a repeatable method of
measuring lamp arc power for systems with cathode heating. The proposed
method also includes a modification to the calculation of the BE
efficiency metric to incorporate an element of system efficacy.
In sections 1 through 4 that follow, DOE discusses the language
proposed for a new appendix Q1 to subpart B of 10 CFR part 430
(hereafter ``appendix Q1''). The new appendix Q1 would contain the new
test procedure for the measurement of BLE that would be used for
demonstrating compliance with any future amended standards. DOE
proposes that use of the test procedure would be required upon the
effective date of any amended energy conservation standards for
fluorescent lamp ballasts. In section 5, DOE describes an update to the
existing test procedure in appendix Q to subpart B of 10 CFR part 430.
The change to appendix Q updates an industry reference from ANSI C82.2-
1984 to the current ANSI C82.2-2002. DOE would retain the existing BEF
test procedure for compliance with existing standards. In section 6,
DOE discusses proposed amendments regarding references to ANSI C82.2-
2002.
1. Test Conditions
The test conditions required in the SNOPR are unchanged from the
NOPR proposal. DOE proposes that testing be conducted at 25 degrees
Celsius 2.0 degrees and in a draft-free environment
according to ANSI C78.375-1997 \11\. These conditions provide for
mostly uniform electrical operating characteristics for the lamp-and-
ballast system. In addition, DOE proposes that ballasts be tested using
the electrical supply characteristics found in section 4 of ANSI C82.2-
2002 with the following changes: (1) Ballasts capable of operating at a
single voltage would be tested at the rated ballast input voltage; (2)
users of universal voltage ballasts would disregard the input voltage
directions in section 4.1 of ANSI C82.2-2002 that indicate a ballast
capable of operating at multiple voltages should be tested at both the
lowest and highest USA design center voltage; and (3) manufacturers use
particular revisions to the normative references associated with ANSI
C82.2-2002 (see section III.D.6 for additional detail). Instead of
testing universal voltage ballasts at the voltages indicated in ANSI
C82.2-2002, DOE believes that testing ballasts at a single voltage is
more appropriate and less burdensome. DOE believes 277 V is the most
common input voltage for commercial ballasts and that 120 V is the most
common for residential ballasts and commercial cold-temperature outdoor
sign ballasts. Therefore, DOE proposes that all universal voltage
commercial ballasts be tested at 277 V and that universal voltage
residential and commercial cold-temperature outdoor sign ballasts be
tested at 120 V.
---------------------------------------------------------------------------
\11\ ``American National Standard for Fluorescent Lamps--Guide
for Electrical Measurements,'' approved September 25, 1997.
---------------------------------------------------------------------------
2. Test Setup
For the BLE measurements, DOE proposes in this SNOPR that the
fluorescent lamp (ballast load) be mounted in a standard strip fixture
with lamps facing upward to minimize self-heating according to ANSI
C82.1-
[[Page 71581]]
2004 \12\ and C78.81-2010. The fluorescent lamp should be seasoned for
at least twelve hours and be tested to be electrically stable and meet
reference lamp conditions as defined in ANSI C82.13-2005.\13\ The
ballast can be placed on the test bench and the fixture should be
electrically connected to the ballast case and to earth ground. The
ballast wire lengths would be as specified in the manufacturer's
catalog and not bundled or coiled to minimize capacitive and inductive
effects. If the wire lengths supplied by the manufacturer are of
insufficient length to reach both ends of lamp, additional wire may be
added. The minimal additional wire length necessary would be added, and
the additional wire would be the same wire gauge as the wire supplied
with the ballast. If no wiring is provided with the ballast, DOE
proposes 18 American wire gauge (AWG) or thicker wire should be used.
The wires would be separated from each other and ground to prevent
parasitic capacitance for all wires used in the apparatus, including
those wires from the ballast to the lamps and from the lamps to the
measuring devices. The test fixture would be wired with 18 AWG solid
conductor wire. All wires in the fixture would be kept loose and not
bundled or taped to the fixture metal, representing common wiring
setups in practice. The ballast under test may be connected to the
fixture through a terminal strip mounted on the side of the fixture or
may be directly connected. The ballast would be wired to the lamps in
the fixture according to the manufacturer's wiring instructions.
---------------------------------------------------------------------------
\12\ ``American National Standards for Lamp Ballast--Line
Frequency Fluorescent Lamp Ballast,'' approved November 19, 2004.
\13\ ``American National Standard for Lamp Ballasts--
Definitions--for Fluorescent Lamps and Ballasts,'' approved July 23,
2002.
---------------------------------------------------------------------------
As previously proposed in the NOPR, instrumentation for current,
voltage, and power measurements would be selected in accordance with
ANSI C78.375-1997 \14\ Section 9, which specifies that instruments
should be ``of the true RMS type, essentially free from wave form
errors, and suitable for the frequency of operation.'' DOE would
further specify instrument performance within the guidelines of the
ANSI C78.375-1997 and ANSI C82.2-2002. Specifically, lamp arc current
would be measured using a galvanically isolated current probe/monitor
with frequency response between 40 Hertz (Hz) and 20 MHz. In addition,
lamp arc voltage and input voltage would be measured directly by a
power analyzer with a maximum 100 picofarad (pF) capacitance to ground
and with frequency response between 40 Hz and 1 MHz. Coaxial cables
would not be used due to the excessive capacitance associated with this
wiring. The input current may be measured either with the internal
shunt of a power analyzer or with an external current transducer
specifically calibrated with the power analyzer.
---------------------------------------------------------------------------
\14\ ``American National Standard for Fluorescent Lamps--Guide
for Electrical Measurements,'' approved September 25, 1997.
---------------------------------------------------------------------------
For the lamp arc current measurement, the galvanically isolated
current probe must be calibrated with the power analyzer. Furthermore,
the current transducer ratio must be set in the analyzer to match the
transducer to the analyzer. The output from non-invasive current
transducers is usually a low voltage signal, so the actual current to
voltage ratio to the power analyzer must consider the losses in
addition to the transducer ratio. Therefore, the full current to
voltage ratio (transducer ratio) includes the voltage divider effect
between the transducer and the power analyzer input. Assuming both the
power analyzer and non-invasive current transducer are properly
calibrated, the actual current to voltage ratio to use to fully correct
the measurement is as described in equation 1.
[GRAPHIC] [TIFF OMITTED] TP24NO10.376
Iin = Current through the current transducer
Vout = Voltage out of the transducer
Rin = Power analyzer impedance
Rs = Current transducer output impedance
The test setup would be different depending on the ballast starting
method. As discussed in section III.C.2 and depicted in Figure III.2,
rapid- and programmed-start ballast test setups would include two 1000
ohm resistors placed in parallel with both sets of lamp pins. This
voltage divider provides a midpoint from which to measure the lamp arc
voltage, minimizing the impact of cathode heating. Instant-start
ballasts would not employ a voltage divider, but would require a jumper
wire or an adapter to connect to lamps with two pins per electrode.
[[Page 71582]]
[GRAPHIC] [TIFF OMITTED] TP24NO10.377
DOE proposes that the power analyzer voltage leads be attached to
the wires leading to and from the main power source for input voltage
measurements and that the current probe be placed around the same wires
for input current. The power analyzer should have at least one channel
per lamp plus one additional channel for the ballast input power
measurement. Figure III.3 shows the instrumentation placement for the
lamp arc power measurement for programmed- and rapid-start ballasts
with full cathode cutout, and Figure III.4 and Figure III.5 show the
placement for instant-start ballasts.
[GRAPHIC] [TIFF OMITTED] TP24NO10.378
[[Page 71583]]
[GRAPHIC] [TIFF OMITTED] TP24NO10.379
[GRAPHIC] [TIFF OMITTED] TP24NO10.380
As discussed in the NOPR, DOE proposes that the ballasts be tested
with the most common wattage lamp operated by the ballast. In many
cases, a ballast can operate several reduced wattage lamps in addition
to the most common variety. For example, ballasts designed to operate
four-foot MBP T8 lamps can operate 32 W, 30 W, 28 W, and 25 W lamps. To
test every lamp-and-ballast combination would impose a significant
burden on manufacturers. Thus, to mitigate the testing burden on
manufacturers, the proposed test procedure would require only one lamp-
and-ballast combination to be tested in each product class. Therefore,
DOE proposes a test procedure based on the ballast operating the most
common lamp wattage, resulting in a ballast luminous efficiency that
represents the way the product is primarily used in the market. Table
III.2 indicates the nominal lamp wattage that would be paired with a
ballast for testing.
Table III.2--Ballast and Lamp Pairings
----------------------------------------------------------------------------------------------------------------
Reference lamp arc
Nominal power
Ballast type lamp Lamp diameter and base -----------------------
wattage Low- High-
frequency frequency
----------------------------------------------------------------------------------------------------------------
Ballasts that operate one, two, three, 32 T8 MBP......................... 30.8 29
four, five, or six straight-shaped lamps 34 T12 MBP........................ 32 *29.81
(commonly referred to as 4-foot medium
bipin lamps) with medium bipin bases, a
nominal overall length of 48 inches, a
rated wattage of 25 W or more, and an
input voltage at or between 120 V and 277
V.
Ballasts that operate one, two, three, 32 T8 MBP......................... 30.8 29
four, five, or six U-shaped lamps 34 T12 MBP........................ 32 *29.81
(commonly referred to as 2-foot U-shaped
lamps) with medium bipin bases, a nominal
overall length between 22 and 25 inches, a
rated wattage of 25 W or more, and an
input voltage at or between 120 V and 277
V.
Ballasts that operate one or two rapid- 86 T8 HO RDC...................... N/A 86
start lamps (commonly referred to as 8- 95 T12 HO RDC..................... 90 *84.88
foot high output lamps) with recessed
double contact bases, a nominal overall
length of 96 inches and an input voltage
at or between 120 V and 277 V.
Ballasts that operate one or two instant- 59 T8 slimline SP................. 60.1 57
start lamps (commonly referred to as 8- 60 T12 slimline SP................ 60.5 *56.91
foot slimline lamps) with single pin
bases, a nominal overall length of 96
inches, a rated wattage of 52 W or more,
and an input voltage at or between 120 V
and 277 V.
[[Page 71584]]
Ballasts that operate one or two straight- 28 T5 SO Mini-BP.................. N/A 27.8
shaped lamps (commonly referred to as 4-
foot miniature bipin standard output
lamps) with miniature bipin bases, a
nominal length between 45 and 48 inches, a
rated wattage of 26 W or more, and an
input voltage at or between 120 V and 277
V.
Ballasts that operate one, two, three, or 54 T5 HO Mini-BP.................. N/A 53.8
four straight-shaped lamps (commonly
referred to as 4-foot miniature bipin high
output lamps) with miniature bipin bases,
a nominal length between 45 and 48 inches,
a rated wattage of 49 W or more, and an
input voltage at or between 120 V and 277
V.
Ballasts that operate one, two, three, or 32 T8 MBP......................... 30.8 29
four straight-shaped lamps (commonly 34 T12 MBP........................ 32 *29.81
referred to as 4-foot medium bipin lamps)
with medium bipin bases, a nominal overall
length of 48 inches, a rated wattage of 25
W or more, an input voltage at or between
120 V and 277 V, a power factor of less
than 0.90, and that are designed and
labeled for use in residential
applications.
Ballasts that operate one, two, three, 86 T8 HO RDC...................... N/A 86
four, five, or six rapid-start lamps 110 T12 HO RDC..................... 106 *100.03
(commonly referred to as 8-foot high
output lamps) with recessed double contact
bases, a nominal overall length of 96
inches, an input voltage at or between 120
V and 277 V, and that operate at ambient
temperatures of 20 [deg]F or less and are
used in outdoor signs.
----------------------------------------------------------------------------------------------------------------
MBP, Mini-BP, RDC, and SP represent medium bipin, miniature bipin, recessed double contact, and single pin,
respectively.
* Empirically derived.
DOE also found that ballasts are capable of operating fewer than
the maximum number of lamps they are designed to operate. For example,
a ballast designed to operate four lamps can also operate two or three
lamps. However, DOE understands that ballasts are typically paired with
the maximum number of lamps they are designed to operate. As discussed
in the NOPR, DOE proposes to test fluorescent lamp ballasts only while
operating the maximum number of lamps for which they are designed to
operate. DOE believes this proposal both reduces testing burden and
assesses the performance of the ballast in its primary and most common
configuration.
3. Test Method
Once the lamp-and-ballast system is connected and attached to the
measurement instrumentation, DOE proposes that the ballast operate a
fluorescent lamp for a minimum of fifteen minutes to a maximum of one
hour until stability is reached. DOE notes that the NEMA Test Procedure
Handout indicated stability should be determined in accordance with
ANSI C78.375-1997. DOE found the specifications in this standard to be
unclear. To further specify the determination of stabilization, DOE
proposes that measurements of lamp arc voltage, lamp arc current, lamp
arc power be taken every one second during the stabilization period.
Once the percent difference between the minimum and maximum values for
voltage, current, and power do not exceed one percent over a four
minute moving window, the system would be considered stable. Allowing
the lamp and ballast system to reach its steady state operating point
will provide a more accurate assessment of ballast performance in the
field. If the system does not stabilize, a new ballast sample would be
selected and the test would be repeated.
After the system has stabilized, DOE proposes that the measured
input parameters be voltage (RMS \15\), current (RMS), power, and power
factor measured in accordance with ANSI C82.2-2002. The measured output
parameters would include lamp arc voltage, current, and power. Lamp arc
current and voltage measurements would be taken at the specified
locations according to the test setup. Frequency of the output waveform
delivered to the lamp by the ballast should also be measured.
---------------------------------------------------------------------------
\15\ Root mean square (RMS) voltage is a statistical measure of
the magnitude of a voltage signal. RMS voltage is equal to the
square root of the mean of all squared instantaneous voltages over
one complete cycle of the voltage signal.
---------------------------------------------------------------------------
4. Calculations
As described in Equation 2 below, ballast luminous efficiency is
equal to total lamp arc power, divided by ballast input power,
multiplied by 100, and then multiplied by 0.9 for ballasts that operate
lamps at low-frequency.
[GRAPHIC] [TIFF OMITTED] TP24NO10.381
The symbol [beta] is equal to 0.9 for low-frequency ballasts and is
equal to 1.0 for high-frequency ballasts.
DOE is also proposing a method of calculating ballast factor to
potentially be used in the fluorescent lamp ballast standards
rulemaking to assign a ballast to a particular product class. The
method specifies dividing the measured lamp arc power on the test
ballast by the measured lamp arc power on a reference ballast. The
reference lamp arc power will be the measured power determined during
reference lamp identification in accordance with ANSI C78.375-2010,
ANSI C78.81-2010, and ANSI C82.3-2002. Reference lamp measured power
can change over time which could impact the BF calculation. Increasing
the frequency of the reference lamp measurement could lead to increased
ballast factor calculation accuracy with slightly increased testing
burden. DOE proposes that the reference lamp arc
[[Page 71585]]
power should be measured once every 24 hours for ballast factor
calculation. DOE invites comment on the frequency at which the
reference lamp power should be measured on the reference ballast.
Some lamp types do not have reference ballast operating conditions
defined for both high- and low-frequency operation. In these cases, DOE
has provided reference ballast lamp arc powers based on lamp operating
conditions in ANSI C78.81-2010 or IEC 60081 Ed 5.0, or as derived by
DOE. DOE empirically derived high-frequency F34T12, F96T12/ES,
F96T12HO/ES, and F96T12HO lamp arc wattage by measuring lamp current
and voltage when the lamp emanated the equivalent lumen output to the
low-frequency light output at ANSI reference conditions.
As discussed in section III.C.2, NEMA provided evidence in its
written comments that light output is directly proportional to lamp arc
power for the ballast factor range of 0.75 to 1.15. Outside this range,
the relationship starts to become nonlinear, but DOE believes the
assumption of a linear relationship to still be reasonable for the
purpose of assigning ballast factor for classification purposes. DOE
notes that the method of measuring ballast factor using fixed reference
ballast lamp arc powers may be more susceptible to reference lamp
measured power variation than a method that measures lamp arc power on
both the test and reference ballast. This is because a measured value
(tested lamp arc power) is being compared to a constant value
(reference lamp arc power from ANSI C78.81-2010 or IEC 60081 Ed. 5.0)
rather than to another measured value using the same lamp. This
variation will not impact the measured BLE value, but could affect the
standard to which the ballast is subject. DOE invites comment on the
impact of variation in the proposed ballast factor calculation for
certain lamp and ballast systems at certain operating frequencies.
5. Updates to Existing Test Procedure
DOE is not changing the proposed updates to the existing test
procedure from the NOPR in this SNOPR. DOE would update the references
to ANSI standards for the existing light-output-based test procedure.
NEMA commented that DOE should use the latest versions of ANSI C82.2,
C82.11, and C82.1 at the time of finalized rulemaking. (NEMA, No. 15 at
p. 4, Philips, Public Meeting Transcript, No. 12 at p. 36-37) DOE would
use the most recent versions of these standards, namely ANSI C82.2-
2002, ANSI C82.11-2002,\16\ and ANSI C82.1-2004. The amendments to the
existing test procedure in Appendix Q to Subpart B of 10 CFR part 430
would be effective 30 days after publication of any test procedure
final rule.
---------------------------------------------------------------------------
\16\ ``American National Standards for Lamp Ballasts--High
Frequency Lamp Ballasts--Supplements,'' approved January 17, 2002.
---------------------------------------------------------------------------
6. Normative References for ANSI C82.2-2002
DOE is not changing its proposals regarding the specification of
normative references to be used with ANSI C82.2-2002 from the NOPR in
this SNOPR. DOE is proposing amendments to the fluorescent lamp ballast
test procedure that would incorporate references to ANSI C82.2-2002
into appendix Q and appendix Q1. In examining the ANSI standard, DOE
found that within ANSI C82.2-2002, there are references to other ANSI
standards. In particular, section 2 of ANSI C82.2-2002 states that
``when American National Standards referred to in this document [ANSI
C82.2-2002] are superseded by a revision approved by the American
National Standards Institute, Inc. the revision shall apply.''
Revisions to these normative standards could potentially impact
compliance with energy conservation standards by changing the tested
value for energy efficiency. Therefore, DOE would specify the
particular versions of the ANSI standards that would be used in
conjunction with ANSI C82.2-2002. DOE proposes to use ANSI C78.81-2010,
ANSI C82.1-2004, ANSI C82.11-2002, and ANSI C82.13-2002 in support of
ANSI C82.2-2002. All other normative references would be as directly
specified in ANSI C82.2-2002. These specifications would apply to the
ANSI C82.2-2002 references in Appendix Q and to the ANSI C82.2-2002
references in Appendix Q1.
E. Burden To Conduct the Proposed Test Procedure
EPCA requires that ``[a]ny test procedures prescribed or amended
under this section shall be reasonably designed to produce test results
which measure energy efficiency, energy use * * * or estimated annual
operating cost of a covered product during a representative average use
cycle or period of use * * * and shall not be unduly burdensome to
conduct.'' (42 U.S.C. 6293(b)(3)). Today's proposed test procedure
measures the performance of a ballast by computing the ratio of lamp
arc power to ballast input power and adjusting for lamp operating
frequency. The proposal is less burdensome than the existing procedure
largely because of the simplicity of electrical measurements compared
to photometric measurements. In addition, the lamp loads proposed in
the SNOPR are less expensive than precision resistor loads proposed in
the NOPR and are already a common item used in test facilities. The
assessment of testing burden is discussed in more detail with reference
to small businesses in section IV.C.
To further ensure that the test procedure proposed in this SNOPR is
not unduly burdensome to conduct, DOE is not proposing any changes to
the minimum sample size (four) for generating a reported value or to
the reported value itself. Currently, to demonstrate compliance with
energy conservation standards, manufacturers must first test four
examples of the basic model. The reported value of BLE is then equal to
either the lower 99% confidence interval limit divided by 0.99 or the
mean of the four values, whichever is smaller. DOE received comment
from NEMA supporting the reported value as currently defined in 10 CFR
430.24. (NEMA, No. 15 at p. 3) NEEA and NPCC also supported DOE using a
statistically valid method of reporting efficiency of a ballast. (NEEA
& NPCC, Public Meeting Transcript, No. 12 at p. 175-176) In addition,
Philips, GE, and OSI commented that an increase in the minimum number
of samples to ten or twenty samples from 70 categories of ballasts
would be burdensome as each test takes two to three hours. (Philips,
Public Meeting Transcript, No. 12 at p. 177-178; OSI, Public Meeting
Transcript, No. 12 at p. 178; GE, Public Meeting Transcript, No. 12 at
p. 178)
F. Impact on Measured Energy Efficiency
In any rulemaking to amend a test procedure, DOE must determine
``to what extent, if any, the proposed test procedure would alter the
measured energy efficiency * * * of any covered product as determined
under the existing test procedure.'' (42 U.S.C. 6293(e)(1)) If DOE
determines that the amended test procedure would alter the measured
efficiency of a covered product, DOE must amend the applicable energy
conservation standard accordingly. (42 U.S.C. 6293(e)(2)) This proposed
active mode test procedure would change the metric used to describe in
the energy efficiency of a ballast. DOE is currently amending energy
conservation standards for fluorescent lamp ballasts in the fluorescent
lamp ballast standards rulemaking. In that rulemaking, DOE is
[[Page 71586]]
considering standards based on the measured efficiency of the ballast
in accordance with the test procedure proposed in this active mode test
procedure rulemaking consistent with 42 U.S.C. 6293(e)(2). DOE will use
test data that it collects in the course of both this test procedure
rulemaking and the fluorescent lamp ballast standards rulemaking when
setting energy conservation standards for fluorescent lamp ballasts.
The BLE test procedure proposal will not affect compliance with
existing energy conservation standards, because DOE proposes that
manufacturers not be required to use the new test procedure until the
date manufacturers are required to comply with amended standards.
G. Scope of Applicability
Today's proposed test procedure is applicable to the fluorescent
lamp ballasts covered in the preliminary determination of scope
outlined in the preliminary technical support document for the
fluorescent lamp ballast standards rulemaking. DOE is considering
regulating certain ballasts that operate F32T8, F34T12, F28T5SO,
F54T5HO, F96T8/ES, F96T12/ES, F96T8HO, F96T12HO/ES, and F96T12HO lamps.
These ballasts can operate between one and six lamps and are used in
commercial, residential, and cold-temperature outdoor sign
applications. For the proposed test procedure in this rulemaking, DOE
would establish particular test setups and calculations depending on
type of ballast, as described in more detail in section III.D. For
example, DOE would specify certain fluorescent lamps and numbers of
these lamps to be paired with certain ballasts for determining ballast
performance.
H. Certification and Enforcement
As discussed in the NOPR, DOE regulations do not currently specify
the energy efficiency measurement to be certified for fluorescent lamp
ballasts. 10 CFR 430.62(a)(4). Earthjustice commented that this
omission undermines effective enforcement and negates the value of
energy conservation standards. NEEA and NPCC and the CA utilities
support DOE specifying the energy efficiency measurement to be
certified for fluorescent lamp ballasts. (NEEA & NPCC, No. 32 \17\ at
p. 10; Earthjustice, No. 14 at p. 1; CA Utilities, No. 13 at p. 3)
Earthjustice also commented that DOE could publish a separate final
rule to specify the energy efficiency measurement to be certified for
fluorescent lamp ballasts on an accelerated timeframe in advance of the
full test procedure final rule. Earthjustice further indicated that if
manufacturers do not need to retest units to ensure compliance with
existing standards using the test procedure in appendix Q, there would
be no justification for permitting a period of one year to submit data.
(Earthjustice, No. 14 at p. 1) DOE appreciates these comments and has
responded to them in the notice of proposed rulemaking for
certification, compliance, and enforcement for consumer products and
commercial and industrial equipment. 75 FR 56796.
---------------------------------------------------------------------------
\17\ This written comment was submitted in response to the
fluorescent lamp ballast energy conservation standard preliminary
analysis. 75 FR 14319.
---------------------------------------------------------------------------
In the context of increasing compliance with energy conservation
standards, Philips commented that compliance and enforcement could be
improved by requiring the ballasts to be tested at labs that meet
certain specifications such as having an audit program and meeting
International Organization for Standardization (ISO) criteria. Philips
requested that DOE make its criteria consistent with the California
Energy Commission (CEC) criteria so that the same data set can be used
for certifying products with both organizations. Philips also noted
that it has come to NEMA's attention that some offshore ballast
suppliers with private labeling may not be complying with energy
efficiency regulations. (Philips, Public Meeting Transcript, No. 12 at
p. 32-34) NEMA commented that they believe a clear and concise test
procedure may encourage voluntary compliance with energy conservation
standards. (NEMA, No. 15 at p. 7) Furthermore, NEMA commented that a
change from the existing test procedure to the test procedure proposed
by NEMA may yield increased compliance by simplifying the methodology.
(NEMA, No. 15 at p. 2, 12)
DOE agrees that requiring certification and compliance data to be
generated in a certified facility could increase the integrity of the
data. DOE also agrees with NEMA that a clear and concise test procedure
may also foster voluntary compliance. In this test procedure SNOPR, DOE
proposes the measurement of BLE using electrical measurements of a lamp
and ballast system. DOE believes this test procedure to be clearer and
less burdensome to conduct compared to the existing method which may
result in increased compliance.
DOE also proposes that test facilities conducting compliance
testing in accordance with amended standards promulgated by the
fluorescent lamp ballast standards rulemaking be National Volunteer
Laboratory Accreditation Program (NVLAP) accredited, a program
administered by the National Institute of Standards and Technology
(NIST), or accredited by an organization recognized by NVLAP. NVLAP
accreditation is a finding of laboratory competence, certifying that a
laboratory operates in accordance with NVLAP management and technical
requirements. The NVLAP program is described in 15 CFR part 285, and
encompasses the requirements of ISO/IEC 17025.\18\ NVLAP (or an
organization recognized by NVLAP) accreditation is currently required
for laboratories providing certification and compliance data for
general service fluorescent, general service incandescent, and
incandescent reflector lamps. Either of these accreditation
requirements would ensure that all the data DOE uses in its rulemaking
comes from standardized and quality controlled sources, increasing
confidence in the precision of the data and limiting variations due to
differences between testing laboratories. DOE determined that NVLAP
imposes fees of $9000 and $8000 on years one and two of accreditation.
For the years following, the fees alternate between $5000 and $8000,
with the $8000 fee corresponding to the on-site evaluation required
every other year. Fees for other accreditation organizations are
expected to be similar. DOE invites comment on the benefits and burden
imposed by the requirement that certification and compliance data come
from an NVLAP or NVLAP recognized organization accredited laboratory.
---------------------------------------------------------------------------
\18\ International Organization for Standardization/
International Electrotechnical Commission, General requirements for
the competence of testing and calibration laboratories. ISO/IEC
17025.
---------------------------------------------------------------------------
IV. Procedural Issues and Regulatory Review
A. Executive Order 12866
Today's proposed rule has been determined to not be a ``significant
regulatory action'' under Executive Order 12866, ``Regulatory Planning
and Review,'' 58 FR 51735 (Oct. 4, 1993). Accordingly, this action was
not subject to review under that Executive Order by the Office of
Information and Regulatory Affairs (OIRA) of the Office of Management
and Budget (OMB).
B. National Environmental Policy Act
In this proposed rule, DOE proposes test procedure amendments that
it expects will be used to develop and implement future energy
conservation standards for ballasts. DOE has determined that this rule
falls into a
[[Page 71587]]
class of actions that are categorically excluded from review under the
National Environmental Policy Act of 1969 (42 U.S.C. 4321 et seq.) and
DOE's implementing regulations at 10 CFR part 1021. Specifically, this
proposed rule would amend the existing test procedures without
affecting the amount, quality or distribution of energy usage, and,
therefore, would not result in any environmental impacts. Thus, this
rulemaking is covered by Categorical Exclusion A5 under 10 CFR part
1021, subpart D, which applies to any rulemaking that interprets or
amends an existing rule without changing the environmental effect of
that rule. Accordingly, neither an environmental assessment nor an
environmental impact statement is required.
C. Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires
preparation of an initial regulatory flexibility analysis for any rule
that by law must be proposed for public comment, unless the agency
certifies that the rule, if promulgated, will not have a significant
economic impact on a substantial number of small entities. As required
by Executive Order 13272, ``Proper Consideration of Small Entities in
Agency Rulemaking,'' 67 FR 53461 (August 16, 2002), DOE published
procedures and policies on February 19, 2003, to ensure that the
potential impacts of its rules on small entities are properly
considered during the DOE rulemaking process. 68 FR 7990. DOE has made
its procedures and policies available on the Office of the General
Counsel's Web site: http://www.gc.doe.gov. In this section, DOE updates
the certification provided to the Office of Advocacy of the Small
Business Administration (SBA) subsequent to publication of the NOPR.
The SBA has set a size threshold for manufacturers of fluorescent
lamp ballasts that defines those entities classified as ``small
businesses'' for the purposes of the Regulatory Flexibility Analysis.
DOE used the SBA's small business size standards to determine whether
any small manufacturers of fluorescent lamp ballasts would be subject
to the requirements of the rule. 65 FR 30836, 30850 (May 15, 2000), as
amended at 65 FR 53533, 53545 (September 5, 2000) and codified at 13
CFR part 121. The size standards are listed by North American Industry
Classification System (NAICS) code and industry description and are
available at http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf. Fluorescent lamp ballast
manufacturing is classified under NAICS 335311, ``Power, Distribution,
& Specialty Transformer Manufacturing.'' The SBA sets a threshold of
750 employees or less for an entity to be considered as a small
business for this category.
To identify potential small manufacturers as defined by SBA, DOE
conducted a market survey using all available public information. DOE's
research involved several industry trade association membership
directories, product databases, individual company Web sites, and
marketing research tools (e.g., Dun and Bradstreet reports) to create a
list of every company that manufactures or sells fluorescent lamp
ballasts covered by this rulemaking. DOE reviewed all publicly-
available data and contacted companies on its list, as necessary, to
determine whether they met the SBA's definition of a small business
manufacturer of covered fluorescent lamp ballasts. DOE screened out
companies that did not offer fluorescent lamp ballasts covered by this
rulemaking, did not meet the definition of a ``small business,'' or are
foreign owned and operated. Ultimately, DOE identified at least 10
fluorescent lamp ballast manufacturers that produce covered fluorescent
lamp ballasts and can potentially be considered small businesses out of
the 42 ballast manufacturers listed in the preliminary technical
support document of the fluorescent lamp ballast standards rulemaking.
The proposed rule includes revisions to appendix Q and a new
appendix Q1. The revisions to appendix Q update an industry reference
and do not change the test method or increase testing burden. The only
difference between the two test procedures relates to the interference
of testing instrumentation. Specifically, the input power measurement
of ANSI C82.2-2002 reduces the interference of instrumentation on the
input power measurement as compared to ANSI C82.2-1984. The vast
majority of companies and testing facilities, however, already employ
modern instrumentation that does not significantly interfere with input
power measurements. Thus, updating this industry reference would not
impose additional financial burden in terms of labor or materials. As
described in more detail in sections III.C and III.D, the proposed test
procedure in appendix Q1 is generally less burdensome compared to the
existing test procedure, while reducing measurement variation. The
proposed procedure uses only electrical measurements which are
generally simpler and more quickly carried out than photometric
measurements. The proposed procedure only uses a reference ballast once
every 24 hours, rather than during the performance evaluation of each
individual ballast. This change reduces the number of measurements
necessary for assigning a BLE and BF to a ballast compared to the
number of measurements necessary for BEF and BF under the existing test
procedure. In addition, the proposed method specifies a shorter lamp
seasoning period (12 hours versus 100 hours) because the lamp's
electrical characteristics stabilize sooner than its photometric
characteristics.
To analyze the testing burden impacts described above on small
business manufacturers, DOE first sought to examine publically
available financial data for those companies identified as small
businesses to compare the estimated revenue and profit of these
businesses to the anticipated testing burden associated with this
proposed test procedure. DOE determined that all the identified small
business manufacturers were privately owned, and as a result, financial
data was not publically available. DOE estimates that the incremental
testing costs for an average small business would be no more and likely
less than testing costs under the existing BEF test procedure for the
reasons set forth in the following paragraph.
The BLE procedure requires no additional equipment compared to the
existing test procedure and eliminates the usage of photocells or an
integrating sphere. In addition, the existing BEF test procedure
requires measurements of lamp light output on a reference ballast and
measurements on a test ballast during each test. Light output
measurements and electrical measurements of the reference system can
require one to two hours depending on the number of reference ballasts
available and the speed at which the lamp reaches photometric
stability. Light output and electrical measurements of the test ballast
are taken immediately after switching the lamps from the reference to
the test system. In contrast, the BLE proposal in this SNOPR requires
the reference lamps to be measured and stabilized on a reference
ballast only once every twenty four hours. After this stabilization,
subsequent testing of the ballasts of interest can take between 15 and
60 minutes. DOE estimates that between 4 and 8 ballast samples could be
completed in an eight hour period using the existing BEF test
procedure, while between 8 and 16 tests could be completed using the
BLE test procedure. Therefore, DOE estimates the BLE
[[Page 71588]]
procedure could result in an incremental reduction in testing time of
about 50%. Assuming the labor rate for carrying out either procedure is
$100 per hour, the BLE procedure could reduce testing costs by $50 to
$100 dollars per test. DOE notes that depending on setup, some
facilities may see less of a reduction in testing time or potentially
no change in testing time.
In this SNOPR, DOE is also proposing that test labs be accredited
by NVLAP or an organization recognized by NVLAP. Accreditation by NVLAP
or an NVLAP-recognized organization may cost approximately $8000 per
year, which DOE believes would not be a significant impact.
On the basis of the foregoing, DOE tentatively concludes and
certifies that this proposed rule would not have a significant impact
on a substantial number of small entities. Accordingly, DOE has not
prepared a regulatory flexibility analysis for this rulemaking. DOE has
provided its certification and supporting statement of factual basis to
the Chief Counsel for Advocacy of the Small Business Administration for
review under 5 U.S.C. 605(b).
D. Paperwork Reduction Act
Manufacturers of fluorescent lamp ballasts must certify to DOE that
their products comply with any applicable energy conservation standard.
In certifying compliance, manufacturers must test their products
according to the DOE test procedure for fluorescent lamp ballasts,
including any amendments adopted for that test procedure. DOE has
proposed regulations for the certification and recordkeeping
requirements for all covered consumer products and commercial
equipment, including fluorescent lamp ballasts. 75 FR 56796 (Sept. 16,
2010). The collection-of-information requirement for the certification
and recordkeeping is subject to review and approval by OMB under the
Paperwork Reduction Act (PRA). This requirement has been submitted to
OMB for approval. Public reporting burden for the certification is
estimated to average 20 hours per response, including the time for
reviewing instructions, searching existing data sources, gathering and
maintaining the data needed, and completing and reviewing the
collection of information.
Public comment is sought regarding: whether this proposed
collection of information is necessary for the proper performance of
the functions of the agency, including whether the information shall
have practical utility; the accuracy of the burden estimate; ways to
enhance the quality, utility, and clarity of the information to be
collected; and ways to minimize the burden of the collection of
information, including through the use of automated collection
techniques or other forms of information technology. Send comments on
these or any other aspects of the collection of information to Ms.
Linda Graves (see ADDRESSES), and e-mail to [email protected].
Notwithstanding any other provision of the law, no person is
required to respond to, nor shall any person be subject to a penalty
for failure to comply with, a collection of information subject to the
requirements of the PRA, unless that collection of information displays
a currently valid OMB Control Number.
E. Unfunded Mandates Reform Act of 1995
Title II of the Unfunded Mandates Reform Act of 1995 (UMRA) (Pub.
L. 104-4) requires each Federal agency to assess the effects of Federal
regulatory actions on State, local, and Tribal governments and the
private sector. For proposed regulatory actions likely to result in a
rule that may cause expenditures by State, local, and Tribal
governments, in the aggregate, or by the private sector of $100 million
or more in any one year (adjusted annually for inflation), section 202
of UMRA requires a Federal agency to publish estimates of the resulting
costs, benefits, and other effects on the national economy. (2 U.S.C.
1532(a), (b)) UMRA also requires Federal agencies to develop an
effective process to permit timely input by elected officers of State,
local, and Tribal governments on a proposed ``significant
intergovernmental mandate.'' In addition, UMRA requires an agency plan
for giving notice and opportunity for timely input to small governments
that may be affected before establishing a requirement that might
significantly or uniquely affect them. On March 18, 1997, DOE published
a statement of policy on its process for intergovernmental consultation
under UMRA. 62 FR 12820. (This policy is also available at http://www.gc.doe.gov). DOE examined today's proposed rule according to UMRA
and its statement of policy and determined that the rule contains
neither an intergovernmental mandate, nor a mandate that may result in
the expenditure of $100 million or more in any year, so these
requirements do not apply.
F. Treasury and General Government Appropriations Act, 1999
Section 654 of the Treasury and General Government Appropriations
Act, 1999 (Pub. L. 105-277) requires Federal agencies to issue a Family
Policymaking Assessment for any proposed rule that may affect family
well-being. Today's proposed rule would not have any impact on the
autonomy or integrity of the family as an institution. Accordingly, DOE
has concluded that it is unnecessary to prepare a Family Policymaking
Assessment.
G. Executive Order 13132
Executive Order 13132, ``Federalism,'' 64 FR 43255 (August 4, 1999)
imposes certain requirements on agencies formulating and implementing
policies or regulations that preempt State law or that have Federalism
implications. The Executive Order requires agencies to examine the
constitutional and statutory authority supporting any action that would
limit the policymaking discretion of the States and to carefully assess
the necessity for such actions. The Executive Order also requires
agencies to have an accountable process to ensure meaningful and timely
input by State and local officials in the development of regulatory
policies that have Federalism implications. On March 14, 2000, DOE
published a statement of policy describing the intergovernmental
consultation process it will follow in the development of such
regulations. 65 FR 13735. DOE has examined this proposed rule and has
determined that it would not have a substantial direct effect on the
States, on the relationship between the national government and the
States, or on the distribution of power and responsibilities among the
various levels of government. EPCA governs and prescribes Federal
preemption of State regulations as to energy conservation for the
products that are the subject of today's proposed rule. States can
petition DOE for exemption from such preemption to the extent, and
based on criteria, set forth in EPCA. (42 U.S.C. 6297(d)) No further
action is required by Executive Order 13132.
H. Executive Order 12988
With respect to the review of existing regulations and the
promulgation of new regulations, section 3(a) of Executive Order 12988,
``Civil Justice Reform,'' 61 FR 4729 (Feb. 7, 1996), imposes on Federal
agencies the general duty to adhere to the following requirements: (1)
Eliminate drafting errors and ambiguity; (2) write regulations to
minimize litigation; (3) provide a clear legal standard for affected
conduct rather than a general standard; and (4) promote simplification
and burden reduction. Section 3(b) of Executive Order 12988
specifically requires that Executive agencies make
[[Page 71589]]
every reasonable effort to ensure that the regulation: (1) Clearly
specifies the preemptive effect, if any; (2) clearly specifies any
effect on existing Federal law or regulation; (3) provides a clear
legal standard for affected conduct while promoting simplification and
burden reduction; (4) specifies the retroactive effect, if any; (5)
adequately defines key terms; and (6) addresses other important issues
affecting clarity and general draftsmanship under any guidelines issued
by the Attorney General. Section 3(c) of Executive Order 12988 requires
Executive agencies to review regulations in light of applicable
standards in sections 3(a) and 3(b) to determine whether they are met
or it is unreasonable to meet one or more of them. DOE has completed
the required review and determined that, to the extent permitted by
law, the proposed rule meets the relevant standards of Executive Order
12988.
I. Treasury and General Government Appropriations Act, 2001
Section 515 of the Treasury and General Government Appropriations
Act, 2001 (Pub. L. 106-554; 44 U.S.C. 3516 note) provides for agencies
to review most disseminations of information to the public under
guidelines established by each agency pursuant to general guidelines
issued by OMB. OMB's guidelines were published at 67 FR 8452 (Feb. 22,
2002), and DOE's guidelines were published at 67 FR 62446 (Oct. 7,
2002). DOE has reviewed today's proposed rule under the OMB and DOE
guidelines and has concluded that it is consistent with applicable
policies in those guidelines.
J. Executive Order 13211
Executive Order 13211, ``Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution, or Use,'' 66 FR 28355
(May 22, 2001), requires Federal agencies to prepare and submit to OMB,
a Statement of Energy Effects for any proposed significant energy
action. A ``significant energy action'' is defined as any action by an
agency that promulgated or is expected to lead to promulgation of a
final rule, and that: (1) Is a significant regulatory action under
Executive Order 12866, or any successor order; and (2) is likely to
have a significant adverse effect on the supply, distribution, or use
of energy; or (3) is designated by the Administrator of OIRA as a
significant energy action. For any proposed significant energy action,
the agency must give a detailed statement of any adverse effects on
energy supply, distribution, or use should the proposal be implemented,
and of reasonable alternatives to the action and their expected
benefits on energy supply, distribution, and use. Today's regulatory
action to amend the test procedure for measuring the energy efficiency
of fluorescent lamp ballasts is not a significant regulatory action
under Executive Order 12866. Moreover, it would not have a significant
adverse effect on the supply, distribution, or use of energy, nor has
it been designated as a significant energy action by the Administrator
of OIRA. Therefore, it is not a significant energy action, and,
accordingly, DOE has not prepared a Statement of Energy Effects.
K. Executive Order 12630
Pursuant to Executive Order 12630, ``Governmental Actions and
Interference with Constitutionally Protected Property Rights,'' 53 FR
8859 (March 15, 1988), DOE has determined that this rule would not
result in any takings that might require compensation under the Fifth
Amendment to the United States Constitution.
L. Section 32 of the Federal Energy Administration Act of 1974
Under section 301 of the Department of Energy Organization Act
(Pub. L. 95-91; 42 U.S.C. 7101), DOE must comply with section 32 of the
Federal Energy Administration Act of 1974, as amended by the Federal
Energy Administration Authorization Act of 1977. (15 U.S.C. 788; FEAA)
Section 32 essentially provides in relevant part that, where a proposed
rule authorizes or requires use of commercial standards, the notice of
proposed rulemaking must inform the public of the use and background of
such standards. In addition, section 32(c) requires DOE to consult with
the Attorney General and the Chairman of the Federal Trade Commission
(FTC) concerning the impact of the commercial or industry standards on
competition. The proposed rule incorporates testing methods contained
in the following commercial standards: ANSI C82.2-2002, Method of
Measurement of Fluorescent Lamp Ballasts. While today's proposed test
procedure is not exclusively based on ANSI C82.2-2002, one component of
the test procedure, namely measurement of ballast factor, adopts a
measurement technique from ANSI C82.2-2002 without amendment. The
Department has evaluated these standards and is unable to conclude
whether they fully comply with the requirements of section 32(b) of the
FEAA, (i.e., that they were developed in a manner that fully provides
for public participation, comment, and review). DOE will consult with
the Attorney General and the Chairman of the FTC concerning the impact
of these test procedures on competition, prior to prescribing a final
rule.
V. Public Participation
A. Submission of Comments
DOE will accept comments, data, and information regarding the
proposed rule no later than the date provided at the beginning of this
notice. Comments, data, and information submitted to DOE's e-mail
address for this rulemaking should be provided in WordPerfect,
Microsoft Word, PDF, or text (ASCII) file format. Interested parties
should avoid the use of special characters or any form of encryption,
and wherever possible, comments should include the electronic signature
of the author. Comments, data, and information submitted to DOE via
mail or hand delivery/courier should include one signed paper original.
No telefacsimiles (faxes) will be accepted.
According to 10 CFR 1004.11, any person submitting information that
he or she believes to be confidential and exempt by law from public
disclosure should submit two copies: one copy of the document including
all the information believed to be confidential, and one copy of the
document with the information believed to be confidential deleted. DOE
will make its own determination as to the confidential status of the
information and treat it according to its determination.
Factors of interest to DOE when evaluating requests to treat
submitted information as confidential include: (1) A description of the
items; (2) whether and why such items are customarily treated as
confidential within the industry; (3) whether the information is
generally known by or available from other sources; (4) whether the
information has previously been made available to others without
obligation concerning its confidentiality; (5) an explanation of the
competitive injury to the submitting person which would result from
public disclosure; (6) a date upon which such information might lose
its confidential nature due to the passage of time; and (7) why
disclosure of the information would be contrary to the public interest.
B. Issues on Which DOE Seeks Comment
DOE welcomes comments on all aspects of this rulemaking. See
section I for further detail. In addition, DOE is particularly
interested in receiving comments and views of interested parties
concerning the following issues:
[[Page 71590]]
1. Impact of Ballast Output on Lamp Efficacy
DOE seeks comment on the impact of lamp current crest factor,
waveform, and lamp operating frequency on the efficacy of a fluorescent
lamp. DOE also seeks comment on its decision to adjust the BLE of low-
frequency ballasts by a factor of 0.9. See section III.C.2 for further
detail.
2. Ballast Factor Calculation
DOE seeks comment on the proposed technique for calculating ballast
factor and on the lamp arc powers empirically derived. DOE also seeks
comment on how frequently reference lamp power (on a reference ballast)
should be measured. See section III.D.4 for further detail.
3. Impact of Reference Lamp Measured Power Variation on Ballast Factor
DOE seeks comment on the impact of reference lamp measured power
variation on the ballast factor calculation. See section III.D.4 for
further detail.
4. Laboratory Accreditation
DOE seeks comment on the potential benefits and burden imposed as a
result of requiring all certification and compliance data to be
generated at a laboratory accredited by NVLAP or an organization
recognized by NVLAP. See section III.H for further detail.
VI. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of this proposed
rule.
List of Subjects in 10 CFR Part 430
Administrative practice and procedure, Confidential business
information, Energy conservation, Household appliances, Imports,
Incorporation by reference, Intergovernmental relations, Small
businesses.
Issued in Washington, DC on November 4, 2010.
Cathy Zoi,
Assistant Secretary, Energy Efficiency and Renewable Energy.
For the reasons stated in the preamble, DOE is proposing to amend
part 430 of Chapter II of Title 10, Code of Federal Regulations as set
forth below:
PART 430--ENERGY CONSERVATION PROGRAM FOR CONSUMER PRODUCTS
1. The authority citation for part 430 continues to read as
follows:
Authority: 42 U.S.C. 6291-6309; 28 U.S.C. 2461 note.
2. Section 430.3 is amended by:
a. Redesignating paragraphs:
1. (c)(11) as (c)(14);
2. (c)(6) through (c)(10) as (c)(7) through (c)(11);
3. (c)(12) as (c)(13);
4. (c)(13) as (c)(17);
b. Adding the phrase ``, Appendix Q1'' before ``and'' in paragraph
(c)(5) and in newly designated paragraph (c)(8); and adding the phrase
``Appendix Q1 and'' in newly designated paragraph (c)(14) before
``Appendix'';
c. Revising newly designated paragraph (c)(13); and
d. Adding new paragraphs (c)(6), (c)(12), (c)(15), and (c)(16).
These revisions and additions read as follows:
Sec. 430.3 Materials incorporated by reference.
* * * * *
(c) * * *
(6) ANSI C78.81-2010, Revision of ANSI C78.81-2005 (``ANSI C78.81-
2010''), American National Standard for Electric Lamps--Double-Capped
Fluorescent Lamps--Dimensional and Electrical Characteristics, approved
January 14, 2010; IBR approved for Appendix Q and Appendix Q1 to
subpart B.
* * * * *
(12) ANSI C82.1-2004, Revision of ANSI C82.1-1997 (``ANSI C82.1''),
American National Standard for Lamp Ballast--Line-Frequency Fluorescent
Lamp Ballast, approved November 19, 2004; IBR approved for Appendix Q
and Appendix Q1 to Subpart B.
(13) ANSI C82.2-2002, Revision of ANSI C82.2-1994 (R1995), American
National Standard for Lamp Ballasts-Method of Measurement of
Fluorescent Ballasts, Approved June 6, 2002, IBR approved for Appendix
Q and Appendix Q1 to subpart B.
* * * * *
(15) ANSI C82.11-2002, Revision of ANSI C82.11-1993 (``ANSI
C82.11''), American National Standard for Lamp Ballasts--High-frequency
Fluorescent Lamp Ballasts, approved January 17, 2002; IBR approved for
Appendix Q and Appendix Q1 to subpart B.
(16) ANSI C82.13-2002 (``ANSI C82.13''), American National Standard
for Lamp Ballasts--Definitions for Fluorescent Lamps and Ballasts,
approved July 23, 2002; IBR approved for Appendix Q and Appendix Q1 to
subpart B.
* * * * *
3. Section 430.23 is amended by revising paragraph (q) to read as
follows:
Sec. 430.23 Test procedures for the measurement of energy and water
consumption.
* * * * *
(q) Fluorescent Lamp Ballasts. (1) The Estimated Annual Energy
Consumption (EAEC) for fluorescent lamp ballasts, expressed in
kilowatt-hours per year, shall be the product of:
(i) The input power in kilowatts as determined in accordance with
section 3.1.3.1 of appendix Q to this subpart before the compliance
date of the amended standards for fluorescent lamp ballasts or section
6.2.6 of appendix Q1 to this subpart beginning on the compliance date
of the amended standards for fluorescent lamp ballasts; and
(ii) The representative average use cycle of 1,000 hours per year,
the resulting product then being rounded off to the nearest kilowatt-
hour per year.
(2) Ballast Efficacy Factor (BEF) shall be as determined in section
4.2 of appendix Q of this subpart before the compliance date of the
amended standards for fluorescent lamp ballasts. Ballast luminous
efficiency (BLE) shall be as determined in section 7.2 of appendix Q1
to this subpart beginning on the compliance date of the amended
standards for fluorescent lamp ballasts.
(3) The Estimated Annual Operating Cost (EAOC) for fluorescent lamp
ballasts, expressed in dollars per year, shall be the product of:
(i) The representative average unit energy cost of electricity in
dollars per kilowatt-hour as provided by the Secretary,
(ii) The representative average use cycle of 1,000 hours per year,
and
(iii) The input power in kilowatts as determined in accordance with
section 3.1.3.1 of appendix Q to this subpart before the compliance
date of the amended standards for fluorescent lamp ballasts or section
6.2.6 of appendix Q1 to this subpart beginning on the compliance date
of the amended standards for fluorescent lamp ballasts, the resulting
product then being rounded off to the nearest dollar per year.
(4) Standby power consumption of certain fluorescent lamp ballasts
shall be measured in accordance with section 3.2 of appendix Q to this
subpart.
* * * * *
4. Section 430.25 is revised to read as follows:
Sec. 430.25 Laboratory Accreditation Program.
The testing for fluorescent lamp ballasts shall be performed in
accordance with Appendix Q1 to this subpart. The testing for general
service
[[Page 71591]]
fluorescent lamps, general service incandescent lamps, and incandescent
reflector lamps shall be performed in accordance with Appendix R to
this subpart. The testing for medium base compact fluorescent lamps
shall be performed in accordance with Appendix W of this subpart. This
testing shall be conducted by test laboratories accredited by the
National Voluntary Laboratory Accreditation Program (NVLAP) or by an
accrediting organization recognized by NVLAP. NVLAP is a program of the
National Institute of Standards and Technology, U.S. Department of
Commerce. NVLAP standards for accreditation of laboratories that test
for compliance with standards for fluorescent lamp ballast ballast
luminous efficiency (BLE), fluorescent lamp efficacy, and fluorescent
lamp CRI are set forth in 15 CFR part 285. A manufacturer's or
importer's own laboratory, if accredited, may conduct the applicable
testing.
5. Appendix Q to subpart B of part 430 is amended by:
a. Adding an introductory paragraph after the Appendix heading.
b. Revising sections 1.15, 1.16, 1.17, and 2.
c. Redesignating sections 3.1, 3.2, 3.3, 3.3.1, 3.3.2, 3.3.3, 3.4,
3.4.1, and 3.4.2 as sections 3.1.1, 3.1.2, 3.1.3, 3.1.3.1, 3.1.3.2,
3.1.3.3, 3.1.4, 3.1.4.1, and 3.1.4.2, respectively.
d. Revising newly redesignated sections 3.1.1, 3.1.2, 3.1.3.1,
3.1.3.2, 3.1.3.3, 3.1.4.1, and 3.1.4.2.
e. Redesignating sections 3.5, 3.5.1, 3.5.2, 3.5.3, 3.5.3.1,
3.5.3.2, 3.5.3.3, and 3.5.3.4 as sections 3.2, 3.2.2, 3.2.3, 3.2.4,
3.2.4.1, 3.2.4.2, 3.2.4.3, and 3.2.4.4, respectively.
f. Adding sections 3.1 and 3.2.1.
g. Revising section 4.
These revisions and additions read as follows:
Appendix Q to Subpart B of Part 430--Uniform Test Method for Measuring
the Energy Consumption of Fluorescent Lamp Ballasts
Appendix Q is effective until the compliance date of the amended
standards for fluorescent lamp ballasts. After this date, all
fluorescent lamp ballasts shall be tested using the provisions of
Appendix Q1.
* * * * *
1.15 Power Factor means the power input divided by the product
of ballast input voltage and input current of a fluorescent lamp
ballast, as measured under test conditions specified in ANSI C82.2-
2002 (incorporated by reference; see Sec. 430.3).
1.16 Power input means the power consumption in watts of a
ballast of a fluorescent lamp or lamps, as determined in accordance
with the test procedures specified in ANSI C82.2-2002 (incorporated
by reference; see Sec. 430.3).
1.17 Relative light output means the light output delivered
through the use of a ballast divided by the light output of a
reference ballast, expressed as a percent, as determined in
accordance with the test procedures specified in ANSI C82.2-2002
(incorporated by reference; see Sec. 430.3).
* * * * *
2. Test Conditions.
2.1 Measurement of Active Mode Energy Consumption, BEF. The test
conditions for testing fluorescent lamp ballasts shall be done in
accordance with ANSI C82.2-2002 (incorporated by reference; see
Sec. 430.3). Any subsequent amendment to this standard by the
standard setting organization will not affect the DOE test
procedures unless and until amended by DOE. The test conditions for
measuring active mode energy consumption are described in sections
4, 5, and 6 of ANSI C82.2-2002. The test conditions described in
this section (2.1) are applicable to section 3.1 of section 3, Test
Method and Measurements.
2.2 Measurement of Standby Mode Power. The measurement of
standby mode power need not be performed to determine compliance
with energy conservation standards for fluorescent lamp ballasts at
this time. This and the previous statement will be removed as part
of a rulemaking to amend the energy conservation standards for
fluorescent lamp ballasts to account for standby mode energy
consumption, and the following shall apply on the compliance date
for such requirements.
The test conditions for testing fluorescent lamp ballasts shall
be done in accordance with ANSI C82.2-2002 (incorporated by
reference; see Sec. 430.3). Any subsequent amendment to this
standard by the standard setting organization will not affect the
DOE test procedures unless and until amended by DOE. The test
conditions for measuring standby power are described in sections 5,
7, and 8 of ANSI C82.2-2002. Fluorescent lamp ballasts that are
capable of connections to control devices shall be tested with all
commercially available compatible control devices connected in all
possible configurations. For each configuration, a separate
measurement of standby power shall be made in accordance with
section 3.2 of the test procedure.
3. * * *
3.1 Active Mode Energy Efficiency Measurement
3.1.1 The test method for testing the active mode energy
efficiency of fluorescent lamp ballasts shall be done in accordance
with ANSI C82.2-2002 (incorporated by reference; see Sec. 430.3).
Where ANSI C82.2-2002 references ANSI C82.1-1997, the operator shall
use ANSI C82.1-2004 (incorporated by reference; see Sec. 430.3) for
testing low-frequency ballasts and ANSI C82.11-2002 (incorporated by
reference; see Sec. 430.3) for high-frequency ballasts.
3.1.2 Instrumentation. The instrumentation shall be as specified
by sections 5, 7, 8, and 15 of ANSI C82.2-2002 (incorporated by
reference; see Sec. 430.3).
* * * * *
3.1.3.1 Input Power. Measure the input power (watts) to the
ballast in accordance with ANSI C82.2-2002 (incorporated by
reference; see Sec. 430.3), section 4.
3.1.3.2 Input Voltage. Measure the input voltage (volts) (RMS)
to the ballast in accordance with ANSI C82.2-2002 (incorporated by
reference; see Sec. 430.3), section 3.2.1 and section 4.
3.1.3.3 Input Current. Measure the input current (amps) (RMS) to
the ballast in accordance with ANSI C82.2-2002 (incorporated by
reference; see Sec. 430.3), section 3.2.1 and section 4.
* * * * *
3.1.4.1 Measure the light output of the reference lamp with the
reference ballast in accordance with ANSI C82.2-2002 (incorporated
by reference; see Sec. 430.3), section 12.
3.1.4.2 Measure the light output of the reference lamp with the
test ballast in accordance with ANSI C82.2-2002 (incorporated by
reference; see Sec. 430.3), section 12.
* * * * *
3.2.1 The test for measuring standby mode energy consumption of
fluorescent lamp ballasts shall be done in accordance with ANSI
C82.2-2002 (incorporated by reference; see Sec. 430.3).
* * * * *
4. Calculations.
4.1 Calculate relative light output:
[GRAPHIC] [TIFF OMITTED] TP24NO10.390
Where:
Photocell output of lamp on test ballast is determined in accordance
with section 3.1.4.2, expressed in watts, and photocell output of
lamp on ref. ballast is determined in accordance with section
3.1.4.1, expressed in watts.
4.2 Determine the Ballast Efficacy Factor (BEF) using the
following equations:
(a) Single lamp ballast
[GRAPHIC] [TIFF OMITTED] TP24NO10.391
(b) Multiple lamp ballast
[[Page 71592]]
[GRAPHIC] [TIFF OMITTED] TP24NO10.392
Where:
Input power is determined in accordance with section 3.1.3.1,
Relative light output as defined in section 4.1, and
Average relative light output is the relative light output, as
defined in section 4.1, for all lamps, divided by the total number
of lamps.
4.3 Determine Ballast Power Factor (PF):
[GRAPHIC] [TIFF OMITTED] TP24NO10.393
Where:
Input power is as defined in section 3.1.3.1,
Input voltage is determined in accordance with section 3.1.3.2,
expressed in volts, and
Input current is determined in accordance with section 3.1.3.3,
expressed in amps.
6. Appendix Q1 is added to subpart B of part 430 to read as
follows:
Appendix Q1 to Subpart B of Part 430--Uniform Test Method for Measuring
the Energy Consumption of Fluorescent Lamp Ballasts
Appendix Q1 is effective on the compliance date of the amended
standards for fluorescent lamp ballasts. Prior to this date, all
fluorescent lamp ballasts shall be tested using the provisions of
Appendix Q.
1. Where ANSI C82.2-2002 (incorporated by reference; see Sec.
430.3) references ANSI C82.1-1997, the operator shall use ANSI
C82.1-2004 (incorporated by reference; see Sec. 430.3) for testing
low-frequency ballasts and shall use ANSI C82.11-2002 (incorporated
by reference; see Sec. 430.3) for high-frequency ballasts.
2. Definitions
2.1. Cathode heating refers to power delivered to the lamp by
the ballast for the purpose of raising the temperature of the lamp
electrode or filament.
2.2. Commercial ballast is a fluorescent lamp ballast that is
not a residential ballast as defined in section 2.9 and meets
technical standards for non-consumer RF lighting devices as
specified in subpart C of 47 CFR part 18.
2.3. High-frequency ballast is as defined in ANSI C82.13-2002
(incorporated by reference; see Sec. 430.3).
2.4. Instant-start is the starting method used instant-start
systems as defined in ANSI C82.13-2002 (incorporated by reference;
see Sec. 430.3).
2.5. Low-frequency ballast is a fluorescent lamp ballast that
operates at a supply frequency of 50 to 60 Hz and operates the lamp
at the same frequency as the supply.
2.6. Programmed-start is the starting method used in programmed-
start systems as defined in ANSI C82.13-2002 (incorporated by
reference; see Sec. 430.3).
2.7. Rapid-start is the starting method used in rapid-start type
systems as defined in ANSI C82.13-2002 (incorporated by reference;
see Sec. 430.3).
2.8. Reference lamp is a fluorescent lamp that meets certain
operating conditions as defined by ANSI C82.13-2002 (incorporated by
reference; see Sec. 430.3).
2.9. Residential ballast is a fluorescent lamp ballast designed
and labeled for use in residential applications. Residential
ballasts must meet the technical standards for consumer RF lighting
devices as specified in subpart C of 47 CFR part 18.
2.10. RMS is the root mean square of a varying quantity.
3. Instruments
3.1. All instruments shall be as specified by ANSI C82.2-2002
(incorporated by reference; see Sec. 430.3).
3.2. Power Analyzer. In addition to the specifications in ANSI
C82.2-2002 (incorporated by reference; see Sec. 430.3), the power
analyzer shall have a maximum 100 pF capacitance to ground and
frequency response between 40 Hz and 1 MHz.
3.3. Current Probe. In addition to the specifications in ANSI
C82.2-2002 (incorporated by reference; see Sec. 430.3), the current
probe shall be galvanically isolated and have frequency response
between 40 Hz and 20 MHz.
4. Test Setup
4.1. The ballast shall be connected to a main power source and
to the fluorescent lamp load according to the manufacturer's wiring
instructions and ANSI C82.1-2004 (incorporated by reference; see
Sec. 430.3) and C78.81-2010 (incorporated by reference; see Sec.
430.3).
4.1.1. Wire lengths between the ballast and fluorescent lamp
shall be the length provided by the ballast manufacturer. Wires
shall be kept loose and not shortened or bundled.
4.1.1.1. If the wire lengths supplied with the ballast are of
insufficient length to reach both ends of lamp, additional wire may
be added. The minimal additional wire length necessary shall be
added, and the additional wire shall be the same wire gauge as the
wire supplied with the ballast. If no wiring is provided with the
ballast, 18 gauge or thicker wire shall be used. The wires shall be
separated from each other and ground to prevent parasitic
capacitance for all wires used in the apparatus, including those
wires from the ballast to the lamps and from the lamps to the
measuring devices.
4.1.2. The fluorescent lamp shall meet the specifications of a
reference lamp as defined by ANSI C82.13-2002 (incorporated by
reference; see Sec. 430.3) and be seasoned at least 12 hours.
4.2. The ballast shall be connected to the number of lamps equal
to the maximum number of lamps the ballast is designed to operate.
4.3. The ballast shall be tested with a reference lamp of the
nominal wattage listed in Table A.
Table A--Lamp-and-Ballast Pairings & Reference Lamp Arc Power
----------------------------------------------------------------------------------------------------------------
Reference lamp arc
Nominal power
Ballast type lamp Lamp diameter and base -----------------------
wattage Low High
frequency frequency
----------------------------------------------------------------------------------------------------------------
Ballasts that operate one, two, three, 32 T8 MBP 30.8 29
four, five, or six straight-shaped lamps
(commonly referred to as 4-foot medium
bipin lamps) with medium bipin bases, a
nominal overall length of 48 inches, a
rated wattage of 25 W or more, and an
input voltage at or between 120 V and 277
V.
34 T12 MBP 32 29.81
Ballasts that operate one, two, three, 32 T8 MBP 30.8 29
four, five, or six U-shaped lamps
(commonly referred to as 2-foot U-shaped
lamps) with medium bipin bases, a nominal
overall length between 22 and 25 inches, a
rated wattage of 25 W or more, and an
input voltage at or between 120 V and 277
V.
34 T12 MBP 32 29.81
Ballasts that operate one or two rapid- 86 T8 HO RDC N/A 86
start lamps (commonly referred to as 8-
foot high output lamps) with recessed
double contact bases, a nominal overall
length of 96 inches and an input voltage
at or between 120 V and 277 V.
95 T12 HO RDC 90 84.88
Ballasts that operate one or two instant- 59 T8 slimline 60.1 57
start lamps (commonly referred to as 8- SP
foot slimline lamps) with single pin
bases, a nominal overall length of 96
inches, a rated wattage of 52 W or more,
and an input voltage at or between 120 V
and 277 V.
60 T12 slimline 60.5 56.91
SP
[[Page 71593]]
Ballasts that operate one or two straight- 28 T5 SO Mini- N/A 27.8
shaped lamps (commonly referred to as 4- BP
foot miniature bipin standard output
lamps) with miniature bipin bases, a
nominal length between 45 and 48 inches, a
rated wattage of 26 W or more, and an
input voltage at or between 120 V and 277
V.
Ballasts that operate one, two, three, or 54 T5 HO Mini- N/A 53.8
four straight-shaped lamps (commonly BP
referred to as 4-foot miniature bipin high
output lamps) with miniature bipin bases,
a nominal length between 45 and 48 inches,
a rated wattage of 49 W or more, and an
input voltage at or between 120 V and 277
V.
Ballasts that operate one, two, three, or 32 T8 MBP 30.8 29
four straight-shaped lamps (commonly
referred to as 4-foot medium bipin lamps)
with medium bipin bases, a nominal overall
length of 48 inches, a rated wattage of 25
W or more, an input voltage at or between
120 V and 277 V, a power factor of less
than 0.90, and that are designed and
labeled for use in residential
applications.
34 T12 MBP 32 29.81
Ballasts that operate one, two, three, 86 T8 HO RDC N/A 86
four, five, or six rapid-start lamps
(commonly referred to as 8-foot high
output lamps) with recessed double contact
bases, a nominal overall length of 96
inches, an input voltage at or between 120
V and 277 V, and that operate at ambient
temperatures of 20 [deg]F or less and are
used in outdoor signs.
110 T12 HO RDC 106 100.03
MBP, Mini-BP, RDC, and SP represent medium
bipin, miniature bipin, recessed double
contact, and single pin, respectively..
----------------------------------------------------------------------------------------------------------------
4.4. Power Analyzer
4.4.1. The power analyzer shall have n + 1 channels where n is
the number of lamps a ballast operates.
4.4.2. Lamp Arc Voltage. Leads from the power analyzer should
attach to each fluorescent lamp according to Figure 1 for rapid- and
programmed-start ballasts, Figure 2 for instant-start ballasts
operating single pin (SP) lamps, and Figure 3 for instant-start
ballasts operating medium bipin (MBP), miniature bipin (mini-BP), or
recessed double contact (RDC) lamps. The programmed- and rapid-start
ballast test setup includes two 1000 ohm resistors placed in
parallel with the lamp pins to create a midpoint from which to
measure lamp arc voltage.
4.4.3. Lamp Arc Current. A current probe shall be positioned on
each fluorescent lamp according to Figure 1 for rapid- and
programmed-start ballasts, Figure 2 for instant-start ballasts
operating SP lamps, and Figure 3 for instant-start ballasts
operating MBP, mini-BP, and RDC lamps.
4.4.3.1. For the lamp arc current measurement, the full
transducer ratio shall be set in the power analyzer to match the
current probe to the power analyzer.
[GRAPHIC] [TIFF OMITTED] TP24NO10.382
Where:
Iin Current through the current transducer
Vout Voltage out of the transducer
Rin Power analyzer impedance
Rs Current probe output impedance
[[Page 71594]]
[GRAPHIC] [TIFF OMITTED] TP24NO10.383
[GRAPHIC] [TIFF OMITTED] TP24NO10.384
[[Page 71595]]
[GRAPHIC] [TIFF OMITTED] TP24NO10.385
5. Test Conditions
5.1. The test conditions for testing fluorescent lamp ballasts
shall be done in accordance with ANSI C82.2-2002 (incorporated by
reference; see Sec. 430.3). DOE further specifies that the
following revisions of the normative references indicated in ANSI
C82.2-2002) should be used in place of the references directly
specified in ANSI C82.2-2002: ANSI C78.81-2010 (incorporated by
reference; see Sec. 430.3), ANSI C82.1-2004 (incorporated by
reference; see Sec. 430.3), ANSI C82.3-2002 (incorporated by
reference; see Sec. 430.3), ANSI C82.11-2002 (incorporated by
reference; see Sec. 430.3), and ANSI C82.13-2002 (incorporated by
reference; see Sec. 430.3). All other normative references shall be
as specified in ANSI C82.2-2002.
5.2. Room Temperature and Air Circulation. The test facility
shall be held at 25 2[deg]C, with minimal air movement
as defined in ANSI C78.375-1997 (incorporated by reference; see
Sec. 430.3).
5.3. Input Voltage. The directions in ANSI C82.2-2002
(incorporated by reference; see Sec. 430.3) section 4.1 should be
ignored with the following directions for input voltage used
instead. For commercial ballasts capable of operating at multiple
voltages, the ballast shall be tested 277V 0.1%. For
ballasts designed and labeled for residential applications and
capable or operating at multiple voltages, the ballast shall be
tested at 120V 0.1%. For ballasts designed and labeled
as cold-temperature outdoor sign ballasts and capable of operating
at multiple voltages, the ballast shall be tested at 120V 0.1%. Ballasts capable of operating at only one input voltage
shall be tested at that specified voltage.
6. Test Method
6.1. Ballast Factor
6.1.1. Reference ballast lamp arc power shall be measured with a
reference ballast at the same frequency as the test ballast in
accordance with ANSI C78.375-1997 (incorporated by reference; see
Sec. 430.3), ANSI C78.81-2010 (incorporated by reference; see Sec.
430.3), and ANSI C82.3-2002 (incorporated by reference; see Sec.
430.3). Total reference ballast lamp arc power shall be equal to the
sum of the reference ballast lamp arc powers of all the reference
lamps used with the test ballast. Reference ballast lamp arc power
shall be measured once every 24 hours.
6.1.1.1. If the reference ballast characteristics are not
specified in ANSI C78.81-2010 (incorporated by reference; see Sec.
430.3), then the reference ballast lamp arc power shall be equal to
the reference lamp power value listed in Table A times the maximum
number of lamps the ballast is designed to operate. The reference
lamp power selected from Table A should be at the same frequency as
the test ballast.
6.2. Ballast Luminous Efficiency.
6.2.1. The ballast shall be connected the appropriate
fluorescent lamps and to measurement instrumentation as indicated by
the Test Setup in section 4.
6.2.2. The ballast shall be operated for at least 15 minutes but
no longer than 1 hour until stable operating conditions are reached.
After this condition is reached, concurrently measure the parameters
described in sections 6.2.3 through 6.2.9.
6.2.2.1. Stable operating conditions are determined by measuring
lamp arc voltage, current, and power once per second in accordance
with the setup described in section 4. Once the difference between
the maximum and minimum values for lamp arc voltage, current, and
power do not exceed one percent over a four minute moving window,
the system shall be considered stable.
6.2.3. Lamp Arc Voltage. Measure lamp arc voltage (volts) using
the setup described in section 4.4.2.
6.2.4. Lamp Arc Current. Measure lamp arc current (amps) using
the setup described in section 4.4.3.
6.2.5. Lamp Arc Power. The power analyzer shall calculate output
power by using the measurements described in section 6.2.3 and
6.2.4.
6.2.6. Input Power. Measure the input power (watts) to the
ballast in accordance with ANSI C82.2-2002 (incorporated by
reference; see Sec. 430.3), section 7.
6.2.7. Input Voltage. Measure the input voltage (volts) (RMS) to
the ballast in accordance with ANSI C82.2-2002 (incorporated by
reference; see Sec. 430.3), section 3.2.1 and section 4.
6.2.8. Input Current. Measure the input current (amps) (RMS) to
the ballast in accordance with ANSI C82.2-2002 (incorporated by
reference; see Sec. 430.3), section 3.2.1 and section 4.
6.2.9. Lamp Operating Frequency. Measure the frequency of the
waveform delivered from the ballast to any lamp in accordance with
the setup in section 4.
7. Calculations
7.1. Calculate ballast factor (BF):
[GRAPHIC] [TIFF OMITTED] TP24NO10.386
Where:
Total test ballast lamp arc power is the sum of the lamp arc powers
for all lamps operated by the ballast as determined in accordance
with section 6.2.5, expressed in watts, and total reference ballast
lamp arc power is determined in accordance with section 6.1.1,
expressed in watts.
7.2. Calculate ballast luminous efficiency (BLE).
[[Page 71596]]
[GRAPHIC] [TIFF OMITTED] TP24NO10.387
Where:
Total Lamp Arc Power is the sum of the lamp arc powers for all lamps
operated by the ballast as determined by section 6.2.5, ballast
input power is as determined by section 6.2.6, and [beta] is equal
to 1.0 for high-frequency ballasts and 0.9 for low-frequency
ballasts.
7.3. Calculate Power Factor (PF).
[GRAPHIC] [TIFF OMITTED] TP24NO10.388
Where:
Ballast input power is determined in accordance with section 6.2.6,
input voltage is determined in accordance with section 6.2.7, and
input current in determined in accordance with section 6.2.8.
[FR Doc. 2010-28793 Filed 11-23-10; 8:45 am]
BILLING CODE 6450-01-P