Federal Register, Volume 75, Number 226, November 24, 2010, Pages 71519-72652 Page: 71,580

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

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.
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
QI"). 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
so 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).

conservation standards for fluorescent
lamp ballasts. In section 5, DOE
describes an update to the existing test
procedure in appendix Q to subpart B
of 10 CFR part 430. The change to
appendix Q updates an industry
reference from ANSI C82.2-1984 to the
current ANSI C82.2-2002. DOE would
retain the existing BEF test procedure
for compliance with existing standards.
In section 6, DOE discusses proposed
amendments regarding references to
ANSI C82.2-2002.
1. Test Conditions
The test conditions required in the
SNOPR are unchanged from the NOPR
proposal. DOE proposes that testing be
conducted at 25 degrees Celsius + 2.0
degrees and in a draft-free environment
according to ANSI C78.375-1997 11.
These conditions provide for mostly
uniform electrical operating
characteristics for the lamp-and-ballast
system. In addition, DOE proposes that
ballasts be tested using the electrical
supply characteristics found in section
4 of ANSI C82.2-2002 with the
following changes: (1) Ballasts capable
of operating at a single voltage would be
tested at the rated ballast input voltage;
(2) users of universal voltage ballasts
would disregard the input voltage
directions in section 4.1 of ANSI C82.2-
2002 that indicate a ballast capable of
operating at multiple voltages should be
tested at both the lowest and highest
USA design center voltage; and (3)
manufacturers use particular revisions
to the normative references associated
with ANSI C82.2-2002 (see section
III.D.6 for additional detail). Instead of
testing universal voltage ballasts at the
voltages indicated in ANSI C82.2-2002,
DOE believes that testing ballasts at a
single voltage is more appropriate and
less burdensome. DOE believes 277 V is
the most common input voltage for
commercial ballasts and that 120 V is
the most common for residential ballasts
and commercial cold-temperature
outdoor sign ballasts. Therefore, DOE
proposes that all universal voltage
commercial ballasts be tested at 277 V
and that universal voltage residential
and commercial cold-temperature
outdoor sign ballasts be tested at 120 V.
2. Test Setup
For the BLE measurements, DOE
proposes in this SNOPR that the
fluorescent lamp (ballast load) be
mounted in a standard strip fixture with
lamps facing upward to minimize self-
heating according to ANSI C82.1-
11 "mrcnNational Standard for Fluorescent

Lamps-Guide for Electrical Measurements,"
approved September 25, 1997.

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