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Federal Register / Vol. 86, No. 203 / Monday, October 25, 2021 / Rules and Regulations compliance certification database only four products 11 between 140 W and 150
W currently met this level of efficiency.
NEMA, No. 12 at p. 2
DOE identified ballasts in DOEs compliance certification database that are in the >100 W and <150 W tested at voltages other than 480 V equipment class and meet the proposed EL 3 for this equipment class. Because there are products that meet the max tech level, DOE is not adjusting ELs proposed for this equipment class in this final determination. However, DOE is adjusting the ELs for the >100 W and <150 W tested at 480 V equipment class see section IV.C.5 for further details in this final determination.
NEMA stated that for the 150 W and 250 W equipment classes for all voltages the proposed ELs for 150 to 200
W are close to those in the previous rulemaking and therefore, already screened for technological feasibility.
NEMA, No. 12 at p. 3 DOE ensured that all ELs analyzed represent commercially available products and therefore, are technologically feasible.
NEMA stated that the proposed EL 1
for ballasts operating lamps between 200 W to 250 W appears slightly lower than the current standards, which is not permissible and should be amended.
NEMA, No. 12 at p. 3
DOE reviewed all ELs developed for this analysis to ensure that they are equal to or more stringent to the existing minimum MHLF ballast efficiency standard i.e., that backsliding is not occurring. For EL 1 for the 150 W and 250 W equipment class tested at voltages other than 480 V, DOE is modifying the equation to ensure no backsliding occurs across the entire wattage range. Specifically, in this final determination DOE is modifying the exponent in the equation from 1/
1+0.5017P0.26 to 1/
1+0.507P0.263.
NEMA also stated that for ballasts operating lamps between 200 W and 250
W, EL 2 appears technologically feasible. Additionally, NEMA stated that based on its review of DOEs compliance certification database only two products operating lamps between 200 W and 250 W, both from a single manufacturer, met EL 3, which means EL 3 is arguably infeasible. NEMA, No.
12 at p. 3
DOE identified ballasts in DOEs compliance certification database that are in 150 W and 250 W tested at voltages other than 480 V equipment class and meet the proposed EL 3 for
this equipment class. These ballasts are from multiple manufacturers. Because there are products that meet the max tech level, DOE is not adjusting ELs aside from EL 1 to prevent backsliding proposed for this equipment class in this final determination. DOE addresses ELs for the 150 W and 250 W tested at 480 V equipment class in section IV.C.5.
NEMA stated that the proposed EL 1
for ballasts operating lamps between 200 W and 500 W for all voltages appears slightly lower than the current standards, which is not permissible.
NEMA, No. 12 at p. 3
For the >250 W and 500 W
equipment class tested at voltages other than 480 V, NEMA stated that DOEs compliance certification database does not have products meeting EL 2 and EL
3 for higher wattages indicating that they are technologically infeasible.
NEMA, No. 12 at p. 3
DOE identified ballasts in DOEs compliance certification database that are in the >250 W and 500 W
equipment class tested at voltages other than 480 V equipment class and meet the proposed EL 3 for this equipment class. These ballasts operate 250 W and 400 W lamps. Because there are products that meet the max tech level, DOE is not adjusting ELs proposed for this equipment class in this final determination. For EL 1 for the 250 W
and 500 W equipment class tested at voltages other than 480 V, DOE is modifying the equation to ensure no backsliding occurs across the entire wattage range. Specifically, in this final determination DOE is modifying the exponent in the equation from 1/1 +
0.5017P0.26 to 1/1 +
0.507P0.263.
For the >500 W and 1,000 W
equipment class, NEMA stated that the 97 percent efficiency requirement at EL
1 would eliminate nearly all currently certified products making it technologically infeasible. NEMA stated that per DOEs compliance certification database the few ballasts that reach the 93 percent efficiency level would not be able to meet 97 percent efficiency because they operate 1,000 W lamps.
NEMA, No. 12 at p. 3
The max tech level for the >500 W
and 1,000 W equipment class tested at voltages other than 480V is based on a 1,000 W representative unit with an efficiency of 0.94. DOE identified ballasts in DOEs compliance certification database that are in the >500 W and 1,000 W tested at voltages
other than 480 V equipment class and meet the proposed EL 1 max tech for this equipment class. Because there are products that meet the max tech level, DOE is not adjusting ELs proposed for this equipment class in this final determination. DOE addresses ELs for the >500 W and 1,000 W tested at 480
V equipment class in section IV.C.5.
For the >1,000 W and 2,000 W
equipment class, Signify stated DOE
should set a standard but disagreed with DOEs proposed EL for this equipment class. Signify noted that, per some ballast catalogs, DOE found that ballasts operating 2,000 W lamps are less efficient than those operating 1,000 W.
Signify stated that ballast efficiency decreasing as wattage increases is contradictory to ballasts in other equipment classes and it had found no documented scientific or engineering explanation to substantiate such a trend.
Signify stated that research indicates that for a magnetic transformer or magnetic ballast energy efficiency increases with the transformer power rate. To align with this trend, Signify suggested DOE change its proposed EL
1 equation from 0.000008P + 0.946
to 0.00001P + 0.928 for the >1,000 W
and 2,000 W equipment class. Signify, No. 13 at pp. 25
NEMA also stated that based on its calculations DOE was proposing a 93
percent efficiency for ballasts operating lamps at 1,000 W and 92 percent efficiency for those operating lamps at 2,000 W and it was unusual for efficiency requirements to decrease as wattage increases. NEMA, No. 12 at p.
3 NEMA also stated that the proposed levels for the >1,000 W and 2,000 W
equipment class appear technologically feasible. However, NEMA stated that because these products are not currently subject to standards and thus have no certified products, it cannot comment in detail on potential product availability.
NEMA, No. 12 at p. 3
In developing the equation for the >1,000 W to 2,000 W equipment class DOE prioritized maintaining a continuous equation across product classes. Ballasts in the >1,000 W to 2,000 W equipment class are not currently subject to standards and therefore are not certified in DOEs compliance certification database. Based on the limited data available, maintaining a continuous equation resulted in a slight negative slope for the efficiency level equation.
Table IV.12 summarizes the efficiency requirements and associated equations
11 It was unclear from the comment whether NEMA was referring to four products tested at 480
V or at voltages other than 480 V.

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