Proposed Amendment to the Energy Efficiency Regulations

Bulletin
August 2005

Fluorescent Lamp Ballasts

NRCan continuously strives to improve upon the availability of energy efficient fluorescent lamp ballasts on the Canadian market. The purpose of this bulletin is to inform you of Natural Resources Canada's proposed changes to the fluorescent lamp ballast regulation, and to provide background information so that stakeholders may submit comments before it proceeds to prepublication in the Canada Gazette. Depending on the nature of the comments received, NRCan may initiate further consultation.

As of April 1, 2005 Canada's Energy Efficiency Regulations requires that fluorescent lamp ballasts, manufactured on or after this date, meet a prescribed minimum energy performance standard (column "B" below) in order to be imported or shipped interprovincially for sale or lease in Canada, effectively eliminating some current models from the market.

Stakeholders were consulted extensively in preparation for the fluorescent lamp ballasts regulation amendment. This amendment was approved and published in the Canada Gazette in April 2003 giving stakeholders almost two years to prepare for the new requirements.

In March 2005, NRCan issued a notice reminding stakeholders of the April 1, 2005 effective date. At this time, NRCan also noted future amendments to the regulations being considered for fluorescent lamp ballasts. These included:

• repealing the effective date requiring all ballasts to comply with the regulations regardless of date of manufacture;
• addressing the BEF for ballasts operating with energy saving lamps;
• revising the cold temperature exclusion;
• adding an exclusion for dimming ballasts.

A fifth issue has surfaced since the issue of the notice. For a while now, Residential Light Fixtures (RLF) have been part of EPA's Energy Star Program in the US, but have not yet been adopted in Canada. In the US, the use of ballasts in residential fixtures are not regulated; moreover, the Energy Star Program in the US has adopted a lower power factor of 0.5 or greater for these ballasts. In Canada, the regulations stipulate that regulated ballasts must have a power factor equal or greater than 0.9 independent of its applications.

In Canada, there is great interest particularly from utilities, to promote high energy efficient RLFs through the Energy Star Program. Implementing this program in Canada would influence market transformation towards the use of more energy efficient light fixtures in residential applications, saving consumers energy and money on their utility bill, and protecting the environment.

There had been concerns expressed on the part of some utilities that lowering the power factor in residential applications would cause problems with higher total harmonic distortion on the system. NRCan has investigated the situation and has not discovered evidence that this impact is significant enough to outweigh the benefits of adopting the Energy Star RLF criteria.

For these reasons and in order to be harmonized with the US EPA Energy Star criteria for RLFs, we are proposing a lower power factor for a very specific group of ballasts. Amending the regulations will allow for a greater variety of fixture models to be available to the consumer, and help promote market transformation by keeping the overall cost of Energy Star qualified RLFs to a minimum.

As a result of the above-mentioned issues, the following changes are proposed as indicated in bold in the body of the document. An explanation of the change is contained within the boxed text.

Product Description

The regulation applies to ballasts intended to operate in the following: F32T8, F34T12, F40T10, or F40T12 rapid start; or F96T12IS, F96T12ES, F96T12HO, or F96T12HO ES fluorescent lamps.

Products excluded from the regulations include:

• ballasts designed to operate 96WT12 lamps for use in outdoor signs and in ambient temperatures of –28.9 °C or lower;

  The exclusion contained in the current regulations (and within the CSA Standard C654) applies to all products operating at temperatures below –17.8?C. The proposed change would be harmonized with the US DOE rule.

• ballasts that have integrated dimming capabilities to 50% or less of their maximum output;.

  In response to stakeholder input NRCan is proposing to add this exclusion which would harmonize with the intent of the US DOE rule. The exclusion wording has been refined somewhat to specifically exclude products with “integrated dimming capabilities”.

• and "Replacement Ballasts" defined as ballasts:
• shipped in packages containing not more than 10 units
• where the total length of the output leads shall be shorter than the length of the lamps
• that are marked "FOR REPLACEMENT USE ONLY".

Note: Replacement Ballasts are required to meet the current standard (column "A" below) and will be required to meet the new standard on April 1, 2010 (column “B”).

Energy Performance Test Procedure

The energy performance test procedure prescribed under the Regulations for fluorescent lamp ballasts is the Canadian Standards Association (CSA) standard, CAN/ CSA-C654-M91 (Amended 2001) Fluorescent Lamp Ballast Efficacy Measurements.

NRCan will work with the Canadian Standards Association Technical Committee for this standard to ensure that the proposed changes are incorporated into the standard.

Energy Efficiency Standards

The proposed minimum ballast efficacy factor will be as found in the CSA standard CAN/ CSA-C654-M91 (Amended 2001) Fluorescent Lamp Ballast Efficacy Measurements section 4.1, Column B (except for F34T12, F96T12(ES) and F96T12HO(ES)). The following table lists all proposed BEF factors in Bold:

¹ Also for use on 40W/48T10/RS lamps
² Also for use on 40W/48T10/RS lamps
³ Also for use on 60W/96T12/IS lamps

The changes indicated in the table in bold apply unique BEF to ballasts intended for operation of energy saving lamps. These products were previously included in the regulations (by direct reference to section 4.1 of the C654 standard under the relevant non-energy saving designation.)

Power Factor

Currently, all regulated ballasts described in the Regulations are required to have a power factor greater or equal to 0.9.

Although the BEF listed above would still apply to regulated ballasts, NRCan is proposing to lower the power factor to be equal or greater than 0.5 for electronic ballasts used with F32T8 lamps, with a CRI greater than 75 and used in residential applications. This would only apply to ballasts of 120 volts.

Effective Date

The standard for fluorescent lamp ballasts came into effect on April 1, 2005. NRCan is proposing to repeal this effective date as of July 1, 2006. The effective date for Replacement Ballasts is April 1, 2010 (unchanged).

Concerns have been raised about the application of the date of manufacture and the opportunity for stockpiling of non-compliant product. The proposal to remove the effective date as of July 1, 2006 will prohibit the sale of non-compliant product either individually or contained within a fixture. The equivalent date is within the US DOE rule, with a similar intent.

The proposed changes in this document will come into effect July 1, 2006. These changes will apply to all products (except for replacement ballasts) regardless of date of manufacture.

NRCan believes that the changes to cold temperature exclusion and the addition of the dimming exclusion, brings the exclusions in line with the US DOE rulemaking and could be effective earlier, however for simplicity, we are proposing a common effective date for all proposed changes.

NRCan is also aware that due to their internal processes, DOE is considering a different application date for energy saving lamp ballasts. However NRCan believes that the changes proposed in this Bulletin reflect the original intent of the legislation and do not require additional notice.

Verification, Reporting and Importing Requirements

NRCan proposes no changes to the verification, reporting and importing requirements currently in place for fluorescent lamp ballasts.

Comments Invited

The purpose of this bulletin to provide stakeholders with a concise interpretation of the proposed amendment, as they apply to fluorescent lamp ballasts. The full legal text will be as pre-published in the Canada Gazette Part I, which will amend the official regulations once published in the Canada Gazette Part II.

Comments are invited during the 75 day comment period (between pre-publication and publication) and should be forwarded to:

Office of Energy Efficiency
Housing and Equipment Division
Natural Resources Canada
580 Booth Street, 18th Floor
Ottawa ON K1A 0E4
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