APPENDIX 12A. PRELIMINARY MANUFACTURER INTERVIEW GUIDE

TABLE OF CONTENTS

12A.1 INTRODUCTION ................................................................................................ 12A­1

12A.2 GENERAL SERVICE FLUORESCENT LAMPS............................................... 12A­2

12A.3 INCANDESCENT REFLECTOR LAMPS........................................................ 12A­11

LIST OF TABLES

Table 12A.2.1 Fluorescent Lamps Under Initial Consideration for this Rulemaking........... 12A­2

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APPENDIX 12A. PRELIMINARY MANUFACTURER INTERVIEW GUIDE

12A.1 INTRODUCTION

Appendix 12A contains a copy of the interview guides used for the preliminary

manufacturer impact analysis, described in Chapter 12 of this TSD. DOE developed two

separate interview guides, one for general service fluorescent lamps and one for incandescent

reflector lamps. The contractor to DOE who conducted the preliminary manufacturer interviews

circulated the interview guides to a limited number of manufacturers of fluorescent and

incandescent lamps who operate in the U.S. market.

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12A.2 GENERAL SERVICE FLUORESCENT LAMPS

PART 1. GENERAL SERVICE FLUORESCENT LAMPS

A. Market Data

This section addresses information on the distribution of GSFL by wattage, efficacy and lamp

type, as well as the average manufacturer selling price for common lamps. When responding to

questions in this section, please exclude any specialty application lamps that would otherwise be

exempt from regulations (e.g. cold temperature service, colored fluorescent lamps, etc.), with the

exception of the CRI limitation. Consider lamps with a CRI greater than 45 and less than 87.

Table 12A.2.1 Fluorescent Lamps Under Initial Consideration for this Rulemaking

Lamp Type Diameter

4ft linear medium bi­pin

>T8

≤T8

8ft linear single pin, slimline

>T8

≤T8

8ft linear, high output, recessed double­contact

>T8

≤T8

8ft linear, very high output, recessed double­contact

>T8

≤T8

2ft U­shaped, medium bi­pin

>T8

≤T8

A.1 Please comment on the above table, including any lamps that should be omitted or added.

A.2 Please comment on whether base­types should be specified, or if this aspect of a

fluorescent lamp does not directly impact the efficacy values, and therefore should be

omitted.

A.3 Of your total shipments of general service fluorescent lamps listed above, approximately

what percentage (by lamp type) have diameters other than T12 and T8?

Of the ten product classes identified above, DOE is currently considering analyzing four product

classes and scaling the results from those product classes to other lamps. The four product

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classes are:

o 4ft MBP, T12

o 4ft MBP, T8

o 8ft Single Pin, T12

o 2ft U­Shaped, T8

A.4 DOE seeks comment on whether these four are the most appropriate and representative

product classes to study in detail.

A.5 For the representative product classes identified, DOE seeks comment on the most

common lamp sold for each of the representative product classes. Please describe lamp

attributes (i.e., wattage, lumen output, life, CCT, CRI, and average manufacturer selling

price)

The Team is considering extrapolating findings from the analyzed lamps to the other product

classes.

A.6 Can you describe how this extrapolation might be applied to the following lamps?

o From 8ft Single­Pin T12 to 8ft Single­Pin T8

o From 8ft Single­Pin Slimline to 8ft HO and 8ft VHO

o From 2ft U­shaped T8 or 4ft T12 Medium Bi­Pin to 2ft U­shaped T12

In order to consider lamps with a higher efficacy than the baseline lamps identified (see question

A.5), DOE must develop Candidate Standard Levels. DOE is considering maintaining the light

output to within 10% of the baseline – considering reduced wattage lamps for replacements and

lamps with the same wattage operating at lower BF for new and renovation installations.

A.7 Please comment on the design options (i.e., gas fill, improved phosphors, etc.) used to

span the efficacy of the most common lamp sold to the maximum technologically

feasible (i.e., highest efficacy) lamp. Please comment on the impact on manufacturer

selling price associated with these design options.

A.8 Can you provide comment on what you would consider appropriate Candidate Standard

Levels for this analysis and why?

In order to calculate the aggregate national energy savings from the Candidate Standard Levels

considered, DOE would need data on shipments and typical efficacy values. For each of the

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representative product classes considered, DOE is interested in obtaining shipment data by

wattage.

A.9 For the 4ft medium bi­pin T12 lamps, what is the proportion of shipments and average

efficacy at 40W, 34W, 32W and 25W?

A.10 For the 4ft medium bi­pin T8 lamps, what is the proportion of shipments and average

efficacy at 32W, 30W, 28W and 25W?

A.11 For the 8ft single­pin T12 lamps, what is the proportion of shipments and average

efficacy at 75W and 60W?

A.12 For the 2ft U­shaped T8 lamps, what is the proportion of shipments and average efficacy

at 32W, 31W and 30W?

For the lamps which are not being analyzed, more generalized data would be utilized to obtain an

estimate of the aggregate national energy savings.

A.13 For the following lamp types, what are the shipment weighted wattages and efficacies?

o 8ft Single­Pin T8

o 8ft RDC T12

o 8ft RDC T8

o 8ft VHO T12

o 8ft VHO T8

o 2ft U­shaped T12

The Team will need to prepare estimates of average lamp prices at each of the Candidate

Standard Levels considered.

A.14 Can you describe how the manufacturer selling price changes by efficacy, at constant

wattage? What are the technology options that underpin this change in price?

A.15 DOE also needs to estimate manufacturer prices for a range of wattages at constant

efficacy. Can you describe how the manufacturer selling price changes by wattage, at a

constant efficacy?

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B. Ballasts

In order to more accurately represent the performance of a fluorescent lamp, DOE will consider

some of the critical attributes of the ballasts that operate them.

B.1 You are invited to comment on the typical ballast factors and the typical number of lamps

per ballast for the baseline lamps of the analyzed product classes (see question A.5):

• 4ft MBP, T12

• 4ft MBP, T8

• 8ft Single Pin, T12

• 2ft U­Shaped, T8

B.2 You are invited to comment on the typical ballast factors for the installed stock of ballasts

operating each of the main categories of General Service Fluorescent Lamps in the U.S.

(4ft medium bi­pin, 8ft single­pin, 8ft recessed double contact, 8ft very high output and

2ft U­shaped). Do these ballast factors vary significantly with lamp diameter or wattage?

B.3 DOE has observed that the retail prices of fluorescent lamp ballasts vary with ballast

factor. Are you aware of why this might be the case? Does the manufacturer’s cost of

production change significantly? What is driving the variance in retail price (e.g., low

ballast factor ballasts tend to be more expensive)?

C. Distribution Channels, Installed Base and Operating Hours

DOE will need to develop a distribution chain model to understand how lamps migrate through

the market from manufacturer to end­user. DOE is interested in understanding both the

proportion (volume) of products that move through certain channels and the mark­ups applied.

C.1 Can you describe how the distribution chain operates for general service fluorescent

lamps? What proportion of shipments move through the various channels, and what are

the typical mark­ups applied by stakeholders in those channels?

C.2 Which end­use sectors (e.g., commercial, residential) tend to use the channels you

identified in C.1?

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C.3 DOE is intending to consider fluorescent lamps operating in different sectors. For the

lamp types under consideration in this rulemaking (Table A.1), can you provide an

estimate of the proportion of GSFL lamps sold into the commercial, industrial and

residential sectors?

To more accurately capture the energy savings potential of a standard, DOE is interested in

understanding the approximate installed stock of lamps in the United States, and how that stock

is changing over time.

C.4 Can you comment on the approximate number of sockets in the U.S., and how these are

changing over time for each of the ten product classes identified in Table A.1?

According to our analysis using EIA data and data from the U.S. Lighting Market

Characterization, Volume I (DOE, 2002), the average annual operating hours for GSFL is 3,435

hours for the commercial sector, 4,800 hours for the industrial sector and 712 hours for the

residential sector.

C.5 Are these reasonable estimates? If not, what is the average annual operating hours by

sector? Does the average annual operating hours vary significantly by lamp length, type

or diameter? Please comment.

D. Anticipated Consumer Responses to a Standard

In its analysis, DOE will need to anticipate how consumers may respond to an energy

conservation standard. Please provide your estimate of the anticipated consumer response to an

increase in the efficacy standard. Often, there is more than one possible replacement lamp for

consumers. Furthermore, with fluorescent lamps, consumers have the option to pair new ballasts

with lamps in new construction, retrofit, and ballast replacement situations.

D.1 What percentage of the market do you estimate will shift to lower wattages, stay at

constant wattage, or shift to higher wattages?

D.2 How would this percentage share change, as the standard increases in its efficacy

requirement?

D.3 When replacing the ballast, what percentage of consumers will choose the same ballast

factor, lower ballast factor or higher ballast factor ballast? Will they place in this ballast a

lamp with the same, lower or higher wattage?

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D.4 How would this percentage share change, as the standard increases in its efficacy

requirement?

DOE’s analysis will take into account the market impact of new ballast standards (both that of

DOE’s energy conservation standards rulemaking (10 CFR 430.32(M) and the Energy Policy

Act of 2005 (135(c)(2)(B)).

D.5 If a 8ft T12 Slimline magnetic ballast is taken out of service what is the likelihood that

the consumer will replace it with a 4ft T8 MBP, an 8ft T8 or an 8ft T12 electronic?

D.6 If a 8ft T12 RDC magnetic ballast is taken out of service what is the likelihood that the

consumer will replace it with a 4ft T8 MBP, an 8ft T8 or an 8ft T12 electronic?

D.7 How would these anticipated consumer responses (both in lamps and ballasts) change at

higher efficacy lamp standards?

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PART 2. PRELIMINARY MANUFACTURER IMPACT ANALYSIS

A. Key Issues

A.1 What are the key issues for your company regarding any new or amended energy

conservation standards for general service fluorescent lamps?

B. Production and Product Mix

B.1 What are your product lines, niches and relative strengths in the lamps market?

B.2 Where are your production facilities located, and what is the product mix manufactured at

each location? Does the bulk of your company’s lamp production occur domestically?

What are your employment levels at these facilities?

B.3 Are the materials necessary to build more energy­efficient lamps readily available?

B.4 How would material price changes affect your company’s business?

B.5 How would your company’s product mix and marketing strategy change as the efficiency

standard changes?

B.6 Generally how would new efficiency standards on lamps impact your customer mix,

distribution channels and corresponding profit margins?

B.7 Are there any other manufacturing or employment issues that DOE should be aware of in

terms of producing more energy efficient lamps at your facility?

C. Conversion Costs

C.1 What level of capital expenditure and product conversion costs would you anticipate you

may need to make at higher standard levels? Please describe what they are and provide

your best estimate of their respective magnitudes.

C.2 How would the imposition of new energy efficiency standards affect capacity utilization

and manufacturing assets at your domestic production facilities? Would a new standard

result in stranded capital assets? Would any facilities be closed or downsized? Added or

upgraded?

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C.3 What are the depreciation periods for the three types of capital expenditures (building,

equipment, tooling)?

C.4 How might a new standard impact product innovation?

C.5 What specific annual compliance costs (after the effective date) do you anticipate

incurring to comply with standards? Will they vary with standard level? Would these

costs vary over time?

D. Exports, Foreign Competition, and Outsourcing

D.1 Would new standards change your projected export sales?

D.2 Would new standards have an impact on the portion of the domestic market served by

foreign competition?

D.3 Would standards impact your decisions regarding domestic production levels? How

would domestic employment levels change under new energy efficiency standards?

E. Market Shares and Industry Consolidation

E.1 In the absence of new standards, do you expect any industry consolidation?

E.2 How would new standards affect your ability to compete?

E.3 Could new standards disproportionately advance or harm the competitive positions of

some firms?

E.4 Are there concerns over intellectual property?

E.5 Could new standards result in disproportionate economic or performance penalties for

particular consumer/user subgroups?

E.6 Beyond price and energy efficiency, could new standards result in products that will be

more or less desirable to consumers due to changes in product functionality, utility or

other features?

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F. Cumulative Regulatory Burden

F.1 Are there recent or impending regulations on lamps or related products that do or will

impose a cumulative burden on the industry? How might an energy efficiency standard

impact the cumulative regulatory burden faced by your company?

F.2 What is the total expected impact of those other regulations?

G. Miscellaneous

G.1 Are there any federal tax credits or other incentive programs to encourage you to produce

energy efficient lamps (covered or subsidized for covered)?

12A­10
12A.3 INCANDESCENT REFLECTOR LAMPS

PART 1. INCANDESCENT REFLECTOR LAMPS

A. Shipments, Efficacy, Wattage and Price

This section addresses information on the distribution of IRL by wattage and efficacy, and

average manufacturer selling prices. Two sub­sections address information pertaining to 1)

lamps currently regulated by DOE, and to 2) lamps proposed for coverage by NEMA and

ACEEE. When responding to questions in this section, please exclude any specialty application

lamps that would otherwise be exempt from regulations (e.g. rough service, colored lamps, etc.).

i. Currently regulated IRLa

DOE is considering analyzing common wattages for its analysis and extrapolating to other

wattages.

A.1 Of the lamps that are currently regulated, what are the most common wattages sold today

and what are their percent shipments?

A.2 What are the most common lamps sold at each of the common wattages noted above?

Please describe lamp attributes (i.e., lumen output, life, coating, average manufacturer

selling price).

b ii. NEMA & ACEEE­Proposed Additional Lamps

DOE is considering NEMA and ACEEE’s proposal to regulate additional incandescent reflector

lamps.

A.3 Of the proposed additional lamps, what are the most common wattages sold today and

what are their percent shipments?

A.4 What are the most common lamps sold at each of the common wattages noted above?

Please describe lamp attributes (i.e., lumen output, average manufacturer selling price,

life).

iii. All Lamps: Designs and Extrapolations

The Team is considering extrapolating findings from the analyzed lamps to other wattages.

a R, PAR, or similar bulb shape with diameter ≥ 2.75” that has a rated wattage between 40 and 205W (42 U.S.C

6291(30)(C)(ii)) (42 U.S.C 6291(30)(F))

b Includes ER, BR and BPAR with diameter ≥ 2.25”, R, PAR, similar bulb shape lamps with 2.25” ≤ diameter ≤

2.75”. Exempting ≤ 45 Watt R20; ≤ 50 Watt ER30, ER40, BR30, BR40; and 65 Watt ER40, BR30, BR40. (ACEEE

& NEMA, No. 14 at p. 4­8)

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A.5 Please comment on the design options (i.e., life, filament, capsule coating, gas fill, etc.)

used to span the efficacy of the most common lamp sold to the maximum technologically

feasible (i.e., highest efficacy) lamp.

A.6 What is the relationship between operating life, efficacy and wattage for incandescent

lamps? Is that relationship the same for halogen lamps and halogen infrared lamps?

A.7 Comparing published literature, there is some variation in IRL efficacy at constant

wattage and life for commercially available incandescent lamps and for commercially

available halogen lamps. Please comment on the factors that may be contributing to that

variation.

iv. Average Manufacturer Selling Prices

A.9 Please comment on how manufacturer selling price varies with design options (i.e., life,

filament, capsule coating, gas fill, etc.) incorporated in IRL. If possible, please provide

examples.

A.10 For a given lamp design (i.e., incandescent, halogen, halogen infrared), please comment

on how manufacturer selling price varies with wattage. If possible, please provide

examples.

B. Distribution Channels

DOE will need to develop a distribution chain model to understand how lamps migrate through

the market from manufacturer to end­user. DOE is interested in understanding both the

proportion (volume) of products that move through certain channels and the mark­ups applied.

B.1 Can you describe how the distribution chain operates for IRL? What proportion of

shipments move through the various channels, and what are the typical mark­ups applied

by stakeholders in those channels?

B.2 Which end­use sectors (e.g., residential, commercial) tend to use the various channels

you identified in B.1?

C. Installed Stock and Market Trends

In order to calculate the aggregate national energy savings from the standard levels considered,

DOE would need data on shipments and typical efficacy values and wattages.

C.1 Please provide your estimate of national shipments of IRL.

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C.2 Please comment on the magnitude of the installed stock (i.e., number of E26 medium

screw base sockets serviced by IRL).

C.3 Please comment on the proportion of shipments for the major wattages noted in your

answer to question A.1 and A.3, and their reduced wattage counterparts.

C.4 What are your relative shipments by lamp design (i.e., incandescent, halogen, halogen

infrared)? Do shipments of a certain lamp design vary significantly by efficacy, and if

so, how?

C.5 Please comment on any trends you notice in the market for IRL.

D. Sector and Operating Hours

i. Sector

DOE recognizes that electricity prices, discount rates, and contractor markups vary by sector.

Therefore, DOE is considering which sectors typically operate which incandescent reflector

lamps.

D.1 For the most common lamp wattages noted above, please estimate the proportion of IRL

lamps sold to the commercial, industrial and the residential sectors?

ii. Operating Hours

DOE uses average operating hour, by sector, to develop estimates of lamp service life.

According to our analysis using EIA data and data from the U.S. Lighting Market

Characterization, Volume I (DOE, 2002), the average annual operating hours for IRL is 712

hours for the residential sector, 3,450 hours for the commercial sector and 4,660 hours for the

industrial sector.

D.2 Are these reasonable operating hour estimates for these three sectors? If not, what is the

average annual operating hours for IRL per sector?

D.3 Please comment on whether the operating hours considered would vary by lamp type

(IRL)?

E. NICHE PRODUCTS

DOE is interested in whether new standard levels might have a significant impact on some subgroups of products because of either technical or commercial considerations.

E.1 Do you have any products whose sales could be significantly impacted by a higher

efficiency standard? If so, please identify and comment on these products and the

threshold standard level that would have a significant impact.

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E.2 Enhanced Spectrum or daylight lamps that use >5% Neodymium are exempted from

coverage. Do you manufacture lamps containing Neodymium? Are these lamps exempt

under the >5% of Neodymium criterion?

F. Anticipated Consumer Responses to a Standard

In its analysis, DOE will need to anticipate how consumers may respond to an energy

conservation standard. Please estimate how you believe consumers might respond to an increase

in the efficacy standard.

F.1 Relative to the common products sold, if DOE were to establish a minimum efficacy

standard, what percentage of the market do you estimate will shift to lower wattages, stay

at constant wattage, or shift to higher wattages?

F.2 How would this percentage change as the efficacy standard increases?

F.3 Do you think CFL shipments will be impacted by a Federal minimum efficacy standard

for IRL? If so, how? Would this impact vary with higher standard levels? What about

emerging technologies such as ceramic metal halide or white­light LEDs?

F.4 Would you consider GSIL a substitute for IRL, or vice versa? If so, are there any

constraints on their substitution?

12A­14
PART 2. PRELIMINARY MANUFACTURER IMPACT ANALYSIS

A. Key Issues

A.1 What are the key issues for your company regarding any new or amended energy

conservation standards for incandescent reflector lamps?

B. Production and Product Mix

B.1 What are your product lines, niches and relative strengths in the lamps market?

B.2 Where are your production facilities located, and what is the product mix manufactured at

each location? Does the bulk of your company’s lamp production occur domestically?

What are your employment levels at these facilities?

B.3 Are the materials necessary to build more energy­efficient lamps readily available?

B.4 How would material price changes affect your company’s business?

B.5 How would your company’s product mix and marketing strategy change as the efficiency

standard changes?

B.6 Generally how would new efficiency standards on lamps impact your customer mix,

distribution channels and corresponding profit margins?

B.7 Are there any other manufacturing or employment issues that DOE should be aware of in

terms of producing more energy efficient lamps at your facility?

C. Conversion Costs

C.1 What level of capital expenditure and product conversion costs would you anticipate you

may need to make at higher standard levels? Please describe what they are and provide

your best estimate of their respective magnitudes.

C.2 How would the imposition of new energy efficiency standards affect capacity utilization

and manufacturing assets at your domestic production facilities? Would a new standard

result in stranded capital assets? Would any facilities be closed or downsized? Added or

upgraded?

12A­15
C.3 What are the depreciation periods for the three types of capital expenditures (building,

equipment, tooling)?

C.4 How might a new standard impact product innovation?

C.5 What specific annual compliance costs (after the effective date) do you anticipate

incurring to comply with standards? Will they vary with standard level? Would these

costs vary over time?

D. Exports, Foreign Competition, and Outsourcing

D.1 Would new standards change your projected export sales?

D.2 Would new standards have an impact on the portion of the domestic market served by

foreign competition?

D.3 Would standards impact your decisions regarding domestic production levels? How

would domestic employment levels change under new energy efficiency standards?

E. Market Shares and Industry Consolidation

E.1 In the absence of new standards, do you expect any industry consolidation?

E.2 How would new standards affect your ability to compete?

E.3 Could new standards disproportionately advance or harm the competitive positions of

some firms?

E.4 Are there concerns over intellectual property?

E.5 Could new standards result in disproportionate economic or performance penalties for

particular consumer/user subgroups?

E.6 Beyond price and energy efficiency, could new standards result in products that will be

more or less desirable to consumers due to changes in product functionality, utility or

other features?

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F. Cumulative Regulatory Burden

F.1 Are there recent or impending regulations on lamps or related products that do or will

impose a cumulative burden on the industry? How might an energy efficiency standard

impact the cumulative regulatory burden faced by your company?

F.2 What is the total expected impact of those other regulations?

G. Miscellaneous

G.1 Are there any federal tax credits or other incentive programs to encourage you to produce

energy efficient lamps (covered or subsidized for covered)?

12A­17