Federal Register, Volume 75, Number 226, November 24, 2010, Pages 71519-72652 Page: 71,573

Federal Register/Vol. 75, No. 226/Wednesday, November 24, 2010/Proposed Rules

430) determines the energy efficiency of
a fluorescent lamp ballast based on light
output measurements and ballast input
power. The metric used is called ballast
efficacy factor. BEF is the relative light
output divided by the power input of a
fluorescent lamp ballast, as measured
under test conditions specified in ANSI
standard C82.2-1984, or as may be
prescribed by the Secretary. (42 U.S.C.
6291(29)(C))
The BEF metric uses light output of
the lamp-and-ballast system instead of
ballast electrical output power in its
calculation of the efficiency of a ballast.
To measure relative light output, ANSI
C82.2-1984 directs the user to measure
the photocell output4 of the test ballast
operating a reference lamp and the light
output of a reference ballast operating
the same reference lamp. Dividing
photocell output of the test ballast
system by the photocell output of the
reference ballast system yields relative
light output or ballast factor. Concurrent
with measuring relative light output, the
user is directed to measure ballast input
power. BEF is then calculated by
dividing relative light output by input
power and multiplying by 100. A ballast
that produces more light than another
ballast with the same input power will
have a larger BEF.
The National Electrical Manufacturers
Association (NEMA) commented that
BEF measurements would vary by plus
or minus five percent and that this
variation is unacceptable when trying to
differentiate between products that vary
in efficiency by three to five percent.
(NEMA, No. 15 at p. 13) For BEF, the
variation in measured power of the
reference lamps (rated power + 2.5%)
plus the variation in the photometric
measurement system itself leads to the
plus or minus 5% variation. Given the
variation observed in BEF measurement,
NEMA also does not believe a
thousandths place digit in a BEF
measurement discussed in the proposed
rule has any statistical validity. In
contrast, NEMA noted that for the
ballast efficiency (BE) measurement
proposed in the NOPR, the power
analyzer equipment introduces plus or
minus 1.5% variation into the
measurement and the current transducer
and wiring capacitances contribute 1%
for a total of plus or minus 2.50o
variation (NEMA, Public Meeting
Transcript, No. 12 at p. 15-16, 22-25).
4 The photocell output of a light source is
measured in units of watts. Photocell output (watts)
is one method of measuring the light output of a
light source. Through the remainder of this
document, DOE refers to the output of a fluorescent
lamp as "light output," even though the existing test

procedure indicates measuring the light with
photocell output.

DOE agrees that photometric based BEF
measurements are more variable than
electrical measurement based BE
measurements. In this test procedure
SNOPR, DOE is proposing a
methodology that uses electrical
measurements of a lamp and ballast
system to measure BLE. The BLE metric
includes a modification to the BE metric
discussed in the NOPR to account for
changes in lamp efficacy as a result of
differences in lamp operating frequency.
B. Metric
In the NOPR, DOE proposed a
resistor-based ballast efficiency
measurement that would then be
correlated to BEF, for consistency with
the standards set forth at 42 U.S.C.
6295(g)(5) and (8). At the NOPR public
meeting, the Appliance Standards
Awareness Project (ASAP) and
Earthjustice commented that they did
not believe DOE was required to
regulate ballasts using the BEF metric.
(ASAP, Public Meeting Transcript, No.
12 at p. 98-99 5; Earthjustice, Public
Meeting Transcript, No. 12 at p. 100)
In response to these comments, DOE
is proposing a new metric to describe
the efficiency of a ballast called ballast
luminous efficiency (BLE). EPCA does
not require DOE to set standards for
fluorescent lamp ballasts using the BEF
metric and grants DOE the authority to
use test procedures for measuring
energy efficiency that it determines are
appropriate. (42 U.S.C. 6291, 6295(g),
and 6293(b)(5)) The BLE metric and test
procedure are based on the NEMA
lamp-based ballast efficiency (BE) test
procedure considered in the test
procedure NOPR. Similar to the
procedure considered in the NOPR, the
BLE test procedure measures ballast
input power and lamp arc power of a
lamp-and-ballast system. The only
difference between the BE procedure
considered in the NOPR and the
proposed BLE test procedure is the
proposed adjustment to the BLE of 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
TA 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.

method for calculating the ballast factor
(BF) of a system by dividing the
measured lamp arc power on the test
ballast by the measured lamp arc power
on a reference ballast. In cases where
reference ballast operating conditions
are unavailable, the SNOPR provides a
reference lamp power (specific to the
ballast type and operating frequency)
from an ANSI standard or from
empirical results. The ballast factor
measurement is described in more detail
in section III.D.4. Particular lamp and
ballast pairings are specified for both
the BLE and BF measurements.
DOE is proposing the BLE test
procedure because it reduces
measurement variation and testing
burden compared to the existing test
procedure. In contrast to BEF and RSE,
the BLE metric can be used to compare
the efficiency across many different
types of ballasts. DOE also believes the
use of a lamp-and-ballast system allows
the ballast to operate at its natural
operating point and will more
accurately assess ballast performance
than when the ballast test load is a
resistor. Furthermore, a resistive load
can only model the effective resistance
of a lamp operated at a particular ballast
factor, requiring multiple ballast factor
specific resistors to be specified and
increasing the testing cost to
manufacturers. DOE also believes that
the use of electrical measurements and
the calculation of BLE reduce the
impact of lamp manufacturing variation
on the efficiency descriptor compared to
the existing test procedure.
C. Test Procedures Considered
In the NOPR, DOE proposed a
resistor-based ballast efficiency
measurement correlated to BEF. DOE
also provided descriptions of alternative
test procedures it considered in the
course of developing its proposal.
Interested parties commented on the
proposed methodology and the three
alternative methods considered. The
following sections discuss DOE's
responses to interested party comments.
1. Resistor-Based Ballast Efficiency
Correlated to BEF
In the NOPR, DOE proposed a test
procedure to measure a resistor-based
BE, which would then be correlated to
BEF. This procedure used precision
resistive loads to simulate the effective
resistance of a fluorescent lamp as the
ballast load. In response, DOE received
many comments suggesting performance
measurements of a lamp-and-ballast
system will provide more realistic data
than a resistor and ballast system while
still reducing measurement variation

compared to the existing method. These

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