EE·RM·97·500 COMMENT OF 

Summary Report - Fluorescent Lamp Ballast Stakeholder Interviews 

On July IS, 1996, the Department of Energy (Department or DOE) published a final rule in the 

Federal RelUster presenting new guidelines for expediting and improving the rulemaking process for 

developing appliance efficiency standards. This process improvement effort included priority setting 

for various products, and the Department detennined that the fluorescent 1\UIlP ballast rulemaking be 

assigned a "high priority." 

The enhanced rulemaking process provides for greater public input and improved analytical 

approaches, with particular emphasis on earlier and more extensive infonnation gathering from 

stakeholders. This collection of interviews represents one part of the effort by the De{iartment to 

contact a cross-section of stakeholders, including both manufacturers and environmental groups, 

within the available time frame. The following stakeholders were interviewed: Advance Transformer 

Co., The Alliance to Save Ene~gy, American Council for an Energy Efficient Economy, Howard 

Iudustries, Inc., MagneTek, Inc., Motorola Lighting, Inc., Natural Resources Defense Council, and 

Valmont Electric. 

The interview questionnaire .was distributed in advance iii. order to elicit the most comprehensive 

information, both qualitative and quantitative, in several areas: engineering issues, co:qsuJner and 

national issues, ballast industry characterization, and impacts on costs, prices, and sales •. Respondents 

were asked to identify any confidential information, and those sections, so designated, have been 

eliminated from public distnbution. Those interviewed were also given an opportunity to check and 

correct the reports of the meetings, as summarized by Department of Energy staff. 

The resulting swnmaries have been compiled alphabetically, accompanied bya brief overview of the 

major comments included. The results will be discussed at the public meeting on March 18, 1997, 

and incorporated into new analytical studies performed in support of the Department's decisionmaking process on how to proceed with the required rulemaking on fluorescent lamp ballast 

standards. For those areas where there was no clear direction, the Department will be seeking a 

better understanding for the underlying reasons and gathering infonnation to help clarifY the issues. 

The Department seeks infonnation on the estimated rate of conversions from magnetic to electronic 

. ballasts, estimated future sales, the effect of voluntary programs,· and the cost breakdowns to use in 

the analysis report that will be most representative of the ballast industry. 

The manufacturer interviews were also a preliminary activity in the development of a fonnal 

manufacturing impact analysis methodology, should the Department move forward with the 

rulemaking on fluorescent lamp ballasts. The interviews initiated an industry characterization and 

helped to identifY both the substantive and procedural issues that should be considered in any future 

ballast manufacturing impact analysis. The general manufacturer impact analysis methodology will 

be presented at the DOE manufacturer impact workshop on March '11-12, 1997. 

The Department would like to thank those who participated for their time, cooperation, and support 

for this project. The information acquired has provided invaluable insights into the ballast industry, 

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EE-RM-97-500 COMMENT OF 

and promises to make a significant contribution to guiding the Department's effort to ,establish an 

accurate and fair approach to promoting ballast energy savings. 

Part A. Engineering Issues 

DOE is using 45,000 hours for ballast life for both electronic and magnetic ballasts. Most 

respondents said that this was acceptable. DOE is using a 150/" lamp life reduction . (from 19,000 hrs.) 

for cathode cutout ballasts .. Most of the responses agreed with.this amount of reduction but some 

indicated that there would be no lamp life reduction if the lamps aretu,med on and off less frequently. 

There can be anincompattbility between electronic ballasts and 34 watt flU()rescent lamps, due to the 

tin coating. Some S\lggested that ~ ballast standardwo1.llcl reduce the use of the 34 watt lamp and 

. thus resolve the incompatibility issue., There are mterference effects between electronic ballasts and 

power we clllTier cOlj.trol syStems,securitysystems, and. with sCllneinfrared remote control devices. 

Estimates of the building stock affected by interference effects ranged from I % to 10%; 

Part B. Consumer and National Issues . . , 

Most of thOSe interviewedbelieVtl that electronic ballast prices are dropping; some agree with the 

Bureau of Census reduction. of 15%. Manlifa~turers liked, the LBNL uncertail:ltyana1ysis for the 

effects of electricity prices Vs.life cycle costs. Several,stakehQlders asked the Department to continue 

using the EIA priceprojections, DOE use the 1997 electricity prices and projectiOns from the EIA. 

The responses to market share~wCre divided between atIat market and a matJcetwlrlch increases 

slowly. Likewise for,the electrouic ballast market Estimates of conversions ranged from 1.7% to 

10%, while the effects ofvolUiltat)r progrl\IllS seemed tobe ~'present"butnotpredictilble, , ' -.' '. ' ..' "'- ,'-, ' ' ',-' ' '.-'- ",:' " -. 

All respondents agreed that the CathOde Cutout ballast is not the techtiologyofchoice in. the market 

because it cOsts, nearly as much as an electronic ball~ but savesot!ly2W!ittspc,:r lamp.' . 

, ' 

Part C.BaJlast Ind~$tty Cllaracterization 

Characteriziilgtheil).d~trybya fum's prod~ct~~s the rectJrtm,gtheme inre~pciJIset~ the first . 

industry characterization· qllCsti(lIL ". TheindU$tryfimll; can be segtegatedpriltiatilYil1to·l:W()segt'l1~ts: 

manufacturers of electronic ballasts olllY, orfulllinell1an~actllrersof electronicandmaghetic 

baIlas~, Other charac;teristics\o;ftheindustryinclllde<1firl:ri.siZe(teV!mues),plaiitloQ~tio~{foreign 

or dom~c), and to aless extent the level of vertical integration it!. atitm' s ~an\lfacturingop~tioiis. 

All firmS .eJtpressed a clear visi9n Mth~elves and howtheychatacteri#4t4eIIlSelves within the 

industrY.SpecIfically,some bollll?iIIrlescbaraclerized theinS~lvesaslat&e. f\lll line manufacturers and 

others identified themselves as USmaIiufactuters of electronic ballasts. . 

All participants commented that the most important changes in theballast industry stemmed from a 

majorshift to electronic ballasts. DOE concluded fromthese responsesthat the electronic ballast has 

had a significant impact On theindUgtry. The industry trend toward el.ectronic ballasts haS caused job 

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losses in the U.s., increased foreign competition, stranded assets in magnetic ballast manufacturing. 

fucilities, prompted new investment in electronic truinufacturing facilities, and. in gen~al stimulated 

competition in an otherwise relatively mature market. 

Based on these structured interviews, a clear characterization of the ballast industry emerges. 

Electronic ballasts currently have an important role in the market and will dominate the industry in 

the near future. . 

Part D. Manufacturer Cost Impacts 

Mat),ufacturers generally considered· the cost information they provided as confidential. The 

information included both manufacturing costs and stranded assets (investment and tooling). 

Manufucturers generally believe that they have an understanding of their competitor's costs in relation 

to their own. 

Most manufacturers did not agree with the detailed breakdown of manufacturing costs. Specifically 

there is concern over the use of average data and many different methods of reporting and allocating 

expenses. Several respondents disagreed with .the total estimated values (material, labor, 

shipping/packaging and tooling). Some stakeholders indicated that there is little to no variation in 

costs for different manufacturers since competition drives costs to be similar. In contrast, several 

stakeholders indicated that differences· in the level of· integration, labor rates, and SG&A 

(management) expenses could possibly lead to variations among firms especially if industry structure 

is changed. 

Estimates of the impact of an electronic ballast standard on current assets ranged from no impact to 

hundreds of millions of dollars. 

Part E: Impacts on Product Sales and Price.s 

Several stakeholders disagreed with the four standard levels outlined in Section 3.6 of the Draft 

Report on Potential Impacts of Possible Energy Efficiency Levels of Fluorescent Lamp Ballasts. The 

four levels proposed were: 

1) Non-Electronic (Cathode Cutout or Energy Efficient Magnetic)· . 

2) Cathode Cutout and Electronic Rapid Start 

3) Electronic Rapid siart 

4) Electronic Instant Start 

Some stakeholders indicated that there should be only two efficiency levels: Energy Efficient 

magnetic (level 1) and Electronic (levels 2,3,4) with no distinctions for cathode cutout, rapid start 

. or instant start. The stakeholders reasoned that the cathode cutout was not a viable product in the 

market and that rapid start and instant start electronic ballasts each have unique applications and both 

would need to be included in the standard. 

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Several manufacturers indicated that any new standard level would decrease the sales of magnetic 

ballasts. Manufacturers of electronic ballasts only would see a net increase in sales and full line 

manufacturers of magnetic and electronic would see a net decrease in sales. 

Many believe that electronic ballast prices would decrease as a result of a new standard. This 

decrease would be the result of cost savings in the design and manufacturing of electronic ballasts. 

Some believe that electronic ballast prices might increase in the short term due to a shortage of 

electronic components. 

Other fuctors identified by the stakeholders which would influence the price and shipments of ballasts 

included foreigncompetitioh, lower inventories, US exports of electronic ballasts, the status of 

electronic component supplies, and the added cost of reliability of electrOQic ballasts. 

Part F. Other Issues 

An electronic ballast sbmdaro would force closure or complete renovation of magnetic manufacturing 

fucilities which c;ouldJead to losses of jobs. However, the U.S. electronic ballast manufac.turers with 

plants in the US .. ,claim that their employment will increase. The return on investment ranges from 

some loss to slightly increasing. 

Most manufacturers claim that th~ir competitive position Wob.'t change or perhaps would improve, 

,but one manufacturer was very uncertain. Impacts from other regulations could be caused by the 

lamp reguia.tions and the-motor standards effective October 24, 1997.ASHRAE 90.1 could have a 

positive effect on electronic ballast' sales. There. also would be no negative in:Ipacts from the clean 

air standatdsbecause electronic ballast manufacturing is environme!1Wly "clean." 

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EE-RM-97-500 COMMENT OF 

Interview with Adyance Transformer Co_ 

Regarding Fluorescent Lamp BaUasts 

December 12, 1996 

On November 15, 1996 the Department of Energy (DOE) and its contractors interviewed the 

Advance Trnnsformer Company, having a place of business at O'Hare International Center, 10275 

West Higgins Road, Rosemont, Illinois, 60018, to discuss various engineering, consumer, national, 

and manufactUrer issues relating to fluorescent lamp ballasts. The interview was conducted at 

Advance's Monroe, Wisconsin manufacturing facility. The responses recorded are in italics below 

each interview question. 

Attendees 

Adyance Transfonner Co. 

Robert Wisbey - Vice President, Product Technology 

Norman Grimshaw -Vice President, Technical Relations 

Paul Thomann - Plant Manager 

Patricia Franco" Legislative and Regulatory Counsel - Philips Electronics 

DOE and Contractors 

Anthony Balducci - DOE 

Eugene Margolis - DOE 

Isaac Turiel - Lawrence Berkeley National Laborntory 

Stephen Mariano - Arthnr D. Little 

Michael Rivest - Arthur D. Little 

PART A: ENGINEERING ISSUES 

A.I BaPast Life. At the ballast workshop, held on June 20, 1996, there was some agreement that 

the ballast life currently used (33,000 hours) is too low. It was suggested that a life of 50,000 hours 

be used instead. The Illuminating Engineering Society (ffiS) Lighting Handbook, 8th edition, lists a 

life of 45,000 hours for magnetic ballasts. DOE is prepared to use this value for both magnetic and 

electronic ballasts and is planning to conduct sensitivity studies on. unequal ballast lifetimes for 

magnetic and electronic ballasts where one type would have a 33,000 hoUr life and the other ballast 

would have a 45,000 hour life. What are your opinions on this approach? 

The 45,000 hour life is more appropriate than 33,000 hours. The life of 45,000 hours should be 

used for both the magnetic and electronic ballasts in the analysis. Sensitivity analysis should also 

use the same values for the life of the ballasts, ifnot, the lives should be annualized. 

A.2 Lamp Life Reduction with the Cathode Cutout Ballast. DOE has received severnl 

comments to the effect that cathode cutout ballasts reduce lamp life by 10-25%. There seems to be 

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some agreement in the comments that a lamp life reduction of 15% is about average. There is also 

a June 1995 paper by Advance that supports a lamp life reduction of 16% for TI2 ballasts and 8% 

ror T8 ballasts. DOE is considering the values reported by Advance. Do you have any information 

to support these or that would guide DOE to use some other values? 

Would rather use the 25% reduction, but comfortable with the 15% reduction in lamp life. There 

is not enough evid,ence to use the 8% reductionfor T8lamps. Recommend using the 25% reduction 

in lamp life, but 'Will not object to 15% lamp life reduction. Also recommend using the same value 

for both the Ti2 and T8. ' 

A.3 Incompatibility of Electronic Ballasts an!i 34 watt lamps. -Is there an Incompatibility of 

Electronic Ballasts and 34 watt lamps? Do you manufacture electronic ballasts for use with 34 watt 

lamps. Are there price premiums for these ballasts? . If so, Can you provide pricing sheets? It appears 

that starting problems have a technical solution; therefore starting problems should not be used to rule 

out all electronic ballasts. Is this an accurate assessment? 

Yes, there is an incompatibility with the 34 'Watt Ti2and electronic ballasts. The tin coating acts 

.as a short circuit on high frequency (electronic) ballasts. Lamp manufacturers need to better 

control the thickness of the tin coating to reduce the problem. They (lamp manufacturers) are 

currently doing a better job control?ing the thickness of the coating. Ballast manufacturers can 

chalige the glow current in the ballasts, but this will compromise ihe design of the ballasts and will 

result in a reduction of the lamp life. The Ti2 electronic ballast market is backing off. 

1, " .: • 

Technically, the lamp manufacturers could make a lamP without the tin coati1ig, but commercially 

this 'Will not 'lWrk. There is an installation Ilamp replacemf;!nt problem even ift'heJamp is marked. 

The illStaller may not know what type (magnetic or electronic) of ballast is in the fixture; 

A.4 Electronic Ballasts May Cause Interfereneewith Building Electronic Systems. Are you 

aware of published accounts ofretrafit situations where spme type of interference has occurred with 

electmmc ballasts? Are you aware of any electronic ballasts'which dO.tlPtcause this type of 

interference? Is it possible,to design an electronic ballast using appropriate filters.or shields, for 

example, which will not cause this interference? Is there Host premium for a non·int~g 

electronic baUast?Do cathode cutout ballasts ca\ISC this type of interference? .'. Wbatdo you dQ when 

a customer complains that ~n electronic ballllSt interferes 'Yith one orJllore of its building electronic 

syst~? Do you provide guidelines to yoUr distnbl.ltors regardiilginterference effi:cts with electronic 

ballasts? What .' portion of the U.S. building stock is affected by these interference problems? " . 

Yt',V, there are accounts of interference· in paging systems' .librar)i scanners, power line carrier 

systems, etc. There are currently no electronic MI!aststhal will not causetnterference. 

Manufacturers can filter the lfMI out of the front of the ballasts (effeCts •• cost, size, efficii!1lcy), but 

the lamp radiates EMI during operation causing interference, . This radiated inteiference is directly 

proportional to thefrequency of the lamp operation. Electronic pallasts operate in afrequency that 

can and does coincide with l'1fra·red controls and data communications. 

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10% of the building stock would be affected (a guess). Recommend using a. different ballast 

(cathode cutout / magnetic) in problem areas. 

PART Bi CONSUMER AND NATIONAL ISSUES 

B.1 Ballast Prices: Current ballast pricing information was obtained from a 1993 survey conducted 

by the Lighting Research Institute. ACEEE beJieves the survey overstates the current price of 

electronic models. DOE intends to reduce electronic ballast prices used in the February 1996 draft 

report by 15%. This is based on an a comparative analysis of shipments and value data from Bureau 

of Census (BoC)1993 and 1995 reports. Additionally, DOE will perform pricesensitivitx studies at 

+15% and -10% ofthenew price. Do you lfgree with DOE's approach? 

Suggest that DOE does 'not change the ballast prices in the analysis but continue to use the prices 

from the LRl study. The current prices from BoC are prices to OEM's, not to end users. ,The 

markups on ballasts do not track due to the various distribution channels. The price pressur.e is on 

the manufacturers, not the distributors. 

B.2 Energy Prices: The Energy Information Agency (EIA) energy price forecasts do not consider 

the possible impacts of utility restructuring. The Gas Research Institute (ORl) has a future price 

scenario showing 29% lower commercial electricity prices by 2015. DOE will use the most recent 

EIA electricity price forecast for the year 2001 in the engineering and life-cycle cost analysis. 

For the purpose of calculating national benefits the Department will perform life-cycle-cost sensitivity 

analyses at -12.5% and -25% of the EIA forecast. In an additional sensitivity analysis the Department 

will determine the rate of decrease in electricity price needed to reduce net present value of the 

reduced life-cycle-cost to zero. Do you a&ree with this approach? Do you have any suggestions for 

an alternative electricity price projection for the 30 year period? 

Advance would like to see the results presented as a percent of people advantaged and percent of 

people disadvantaged. Similar to presentation at the June 1996 workshop. 

B.3 New Market Shares: DOE will graph the annual ballast installations according to three 

segments: new construction, conversions and replacements. Market share (electronic as a percent 

oftota! instal1ations) as a function of time will also be disPlayed. The graphs will show the synergistic 

effects of conversions, replacements and new construction to make the discussion easier to follow. 

The electronic share of total ballast sales is approximately the same for the first half of 1996 as it was 

in 1995. Do you believe these shares should increase / decrease through 20007 If so, by how much 7 

Total sales will remain flat. The percent of electronic ballasts will continue to increase. Estimate 

that 50% of the sales will be electronic by 1997·1998* (CBM numbers, *eliminates the non· 

regulated ballasts). 

B.4 Conversion Rates - Retrofiti The current high efficiency base case assumes a constant 

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conversion rate of 5.5% after 2000. ACEEE claimed that a conversion rate based on the 1992/1993 

time period is unrealistic for future years. The low I<fficiency base case assumed no conversions after 

1995. Workshop participants suggested that sensitivity studies on conversion rates be performed. 

What conversion rates should be considered? 

Question not asked or didn't apply. 

B.5Futilre Ballast.SaJes Levels: Stakeholders disagree with the current forecast of total future· 

ballast sales which is based on 1993 data. The ballast shipments for '93, '94 and '95 are nearly flat 

at SO million pet year. What do you project the future ballast shipments to be? 

Total sales will remain flat. 

B.6 Incorporating Voluntary Programs: The current analysis assumes that utility DSM programs 

will diminish after 1995. DOE will review some DSM, FEMP, EPA, and EPRI data to develop an 

upper bound and best estimate of the effects of voluntary programs. Information On these or other 

voluntary programs would be appreciated. . . 

Shares of electronic oallasts.will increase due to voluntary programs. The NEMA program is large; 

they have $150k invested. 

B.7 Transition Technology - Cathode Cutout: Why has this technology captured only 1% market 

share? 

There are three basic reasons why Cathode Cutout ballastshaveasmallpercentage of the market: 

1. Certain image in market. People jumpfrom lowest cost to highest efficiency. Cathode 

cutout is in the middle (also considered amagneticballait.) .. 

2. No accepted standard for Cathode Cutout ballasts ... No consensus/Or life, reliability, etc. 

3. Availablefrom only three mam,ifacturers,<one of which half-heartedly sells them. 

PARI C: BAU.AST IJSDUSTRY ClIABACTERJZAUON 

C.I ·What are the televant characteristics that .colildbe usedtQ·divide ballast manufacturers ittto 

meaningfu1subgroups for the purpose of evaluating the impacts of standards? (i.e .• firm size,plant 

location,productmix, ete.) .. 

Two groupings; , 

1. Ske -small, medium, large 

2. Product - magnetic, (!iec/ronic, both 

C.2 How would you characterize your firm relative to the previous characteristics? 

Advance is a large manufacturer of both types of ballasts .. 

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EE·RM·97·500 COMMENT OF 

C.3 What changes have occurred in the ballast industry in recent years (~ilch as the shift to electronic 

ballasts), and how have these changes impacted your company? 

The shift to electronic ballasts has shifted jobs out of the U.S. to Asia. The profitability of the 

industry has decreased. There have been some stranded investments due to plant closures. 

Shipments are down 8·9% annually. The Monroe manufacturing facility will be the only U.S. 

magnetic ballast manufacturingfacility owned by Advance. 

PART D: MANUFACTURER COST IMPACTS 

For each of the efficiency levels descnbed in Section 3.6 of the "Draft R~port on Potential Impact of 

Possible Energy Efficiency Levels for Fluorescent Lamp Ballasts", February 1996. (Included below): 

D.I Are the manufacturing costs descnbed in the LBNL engineering analysis -labor, materials/parts, 

shipping/packaging, and tooling/equipment - r~resentative of your manufacturing costs? Please 

explain. 

The breakdowns are meaningless. They don't provide an estimated total cost of every ballast 

category. Each manufacturer allocates costs differently. Total cost equals sales revenue minus 

profit. 

D.2 Is there a large variation in costs between different ballast manufacturers? If so, how large, and 

what elements might account for these variations? 

The variation in total cost is not large. Allocation of cost is very different for individual 

manufacturers. -

D.3 What would be the effect on the value ofY9ur current assets in such areas as plant, equipment, 

and tooling? 

Electronic Standard: impact would be hundreds of millions 

Cathode Cutout: not as large an impact. secondary effect would be a greater shift to electronic 

ballasts. -

PART E: IMPACTS ON PRODUCT SAI.ES AND PRICE 

For each of the efficiency levels described in Section 3.6: 

E.I Would the total number ofba11asts sold by your finn increase or decrease from current forecasts? 

Why? . 

Any change in the standards would result in a minor change in number of total ballasts sold by 

Advance. Advance currently has the largest marketsharefor magnetic and electronic ballasts. 

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EE·RM·97·500 COMMENT OF 

If the standard was for electronic ballasts, there would be a slight decrease in total number of 

ballasts sold.by Advance. If the standard was for cathode cutout ballasts, in the short run Advance 

would have an increase in market share due to the current percentage of the. cathode cutout market 

we have. Eventually the standard would have the same impact as an electronic standard .. 

E.2 Would the price on ballasts increase or decrease? Why? By how much? 

Theprice ofball~sts would go up. Cathode Cutout and Electronic ballasts are more expensive. 

EJ Would the gross profit margin on ballasts increase or decrease? Why? By how much? 

ElectroniC:: profit margin is less than magnetic, \""ould be lessprofitable. 

Cathode Cutout: due to the secondary effect mentioned above, profits would go down . .. 

E.4 Are you aware of other factors that c01lld influence the price and quantitY variables for your 

fnm?{changes in distribution channels, changes in suppliers, etc.) . 

Increase in foreign competition influences price. There would be added cost to .the industry in 

reliability Jor ele9trOnic ballasts . 

. PART F: O'rHER ISSUES 

For each of the efficiency levels described in Section 3.6: 

I _ '. 

F.I . What might be the effect on current employment levels atyourdom~stic mallufacturing plants? 

Please explain and quantifY if possible. . 

. Nothing in the current magnetic plant that could be used to manufacfllre electronic' ballasts. 

Currently going./i'om three to two facilities. One more will goawaydue to natural decrease in 

magnetic market. 75% of the ballasts 'sold by 2005 will b.e electronic. Employment would move, 

destination unknown. .. 

F.2 What might be the effeqt on yo~ company's rennn on investmentand overalleconomi~ value? 

Please elaborate.' . 

Return on Investment (ROI) would decrease; 

FJ How might your competitive .position in the industry be affected? .. 

Still would be competitive. Intend to be #1 no matter what happens. Would not be as strong a 

leader as today. 

F.4 What other federal product I~gulations are likely to impact your firm in the near future? 

\ 

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Impact from lamp regulation. Exact impact is still being sorted out. Shift of product to electronic 

ballasts and T8lamps. Afactor but not a 'major one. 

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EE·RM·97'500 COMMENT OF 

February 10, 1997 

Interview with The Alliance to Save Enere:. 

Regarding Fluorescent Lamp Ballasts 

On Janumy 13, 1997 the Department of Energy (DOE) interviewed The Alliimce to Save Energy, 

having a place of business at 1200 1 8th Street, N.W., Washington, D.C. 20036, to disQuss various 

engineering, consumer, national, and manufacturer issues relating to fluorescent lamp ballasts. The 

responses recorded are in italics below each interview question. 

Attendees 

The Alliance to Save EneriY 

Eugene Foley· Program Manager 

DOE and Contractors 

A!tthony Balducci - DOE 

Terry Logee - DOE 

PART Ai . ENGINEERING ISSUES 

A.I BaDast Life. At the ballast workshop, held on June 20, .1996, there was some agreement that 

the blinast life currently used (33,000 hours) is too low. It was suggested that a life of 50,000 hours 

be used instead. The ntuminating Engineering Society (IES) Ligh$g Handbook, 8th edition, lists a 

life of 45,000 hours for magnetic ballasts. DOE is prepared to use thisvalue for both magnetic and 

electronic ballasts arid is pl!lDlling to conduct sensitivity studies on unequal ballast lifetimes for 

. magnetic and electronic ballasts where one type would have a 33,000 hour life and the other ballast 

would have a 45,000 hour life. What are your opinions, on thisllpproach? . . , 

Use the same value/or both types a/ballasts. 45,000 hour life is a reason~ble number. 

A.2 Lamp Life Redul;tion with the Cathode Cutout Bllllast.. DOJ,i: luis .received several 

comments tothe effect that cathode cUtout ballasts reduce.lamp life by 10-25%. There. seelllS to be 

some agreement in the comments that a lamp life reduction of 15% isabi>utaverage. There is also 

a June 1995 paper by Advance that supports a lamp life reduction of 16% for Tl2ballasts and 8% 

for T8 ballasts. DOE is considering the values reported by Advance. Do you h8te any information 

to support these or that would guide DOE to use some other values? 

DOE should do some research on the averageftxture "on time". If the averageftxture is on/or: 

. 3 hours or less - reduce lamp life; . 

6 hours or more - keep the lamp life the sameforall ballast types. 

JES handbook is agood place to look. . 

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A.3 Incompatibility of Electronic Ballasts and 34 watt lamps. ISthere an Incompatibility of 

Electronic BalIllsts and 34 watt lamps? . Do you manufacture electronic ballasts for use with 34 watt 

lamps. Are there price premiums for these ballasts? If so, can you provide pricing sheets? It appears 

that starting problems have a technical solution; therefore starting problems should not be used to rule 

out all electronic ballasts. Is this an accurate assessment? 

There is an incompatibility if you don't design the ballast correctly. Magnetic ballasts can have a 

hard time starting 34 watt lamps. 

A.4 Electronic Ballasts May Cause Interference with Building Electronic Systems. Are you 

aware of published accounts of retrofit situations where some type of interference has occurred with 

electronic ballasts? Are you aware of any electronic ballasts which do not cause this type of 

interference? Is it possible to design an electronic ballast using appropriate filters or shields, for 

examp Ie; which will not cause this interference? Is there a costpremimn for a non-interfering 

electronic ba1last? Do cathode cutout hallasts cause this type of interference? What do you do when 

a customer complains that an electronic ballast interferes with' one or more ofits building electronic 

systems? Do you provide guidelines to your distributors regarding interference effects with electronic 

ballasts? What portion of the U.S. building stock is affected by these interference problems?' 

Yes, interference occurs, but it is solvable. Interference with Simplex Clock systems is common. 

Simplex has produced a list of electronic ballasts that are compatible with their systems. Industry 

can build ballasts that will.not inteifere with different systems. For existing systems. manufacturers 

need to be aware of the "issues " .. Less than 10% of the building stack is affected. 

PART B: CONSUMER AND NATIONAL ISSUES 

B.I BaDast Prices: . Current ,balliist pricing information was obtained from a 1993 survey conducted 

by the Lighting Research Institute. ACEEE believes the survey overstates the current price of 

electronic models. DOE intends to reduce electronic balJast prices used in the February 1996 draft 

report by 15%. This is based on a comparative analysis of shipments and value data from Bureau of 

Census 1993 and 1995 reports. Additionally, DOE will perform price sensitivity studies at + 15% and 

-10% of the new price. Do you agree, with DOE's approach? 

BOC data gives no pricing data. For one source. DOE should look at ballasts bought by various ' 

levels of government an various goverilment contracts to get ballast prices. 

B.2 Energy Prices: The Energy Information Agency (EIA) energy price forecasts do not consider 

the possible impacts of utility restructuring. The Gas Research Institute (GRI) has a future price 

scenario showing 29% lower commercial electricity prices by 2015. DOE will use the most recent 

EIA electricity price forecast for the year 2001 in the engineering and life-cycle cost analysis. 

For the purpose of calculating national benefits the Department will perform life-cycle-cost sensitivity 

analyses at -12.5% and -25% of the EIA forecast. In an additional sensitivity analysis the DepartJ.nent 

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. EE-RM-97-500 COMMENT OF 

will determine the rate of decrease iIi electricity price needed to reduce net present value of the 

reduced Jife-cycle-cost to zero. Do you agree with this approach? Do you have any suggestions for 

an alternative electricity price projection for the 30 yearperiod? 

25% is too Jarge of a deflated number. Depending on the sector, price could actually increase. 

B.3 New Market Shares: DOE will graph the annual ballast installations according to three 

segments: new construction, conversionS and replacements. Market share (electronj.c as a percent 

oftotal installations) as a function of time will also be displayed. The graphs will show the. synergistic 

effects of cpnversions,repiacements and new construction to make the discussion easierto follow. 

The electn>nic share of total ballast sales is approximately the same fOTthe first half of 1996 as it was 

in 1995. Do you believe these shares should increaSel decrease t)lrough 2000? If so, by how much? 

Most conversions go to electronic ballasts. In the short term. electronic ballast sales will be flat or 

decrease. This is primarily dUe to th£!end of Demand Side Management (DSM) programs. If 

electronic ballast prices come down, magnetic ballasts may bepricedout of the market . 

. BA Conversion Rates - Retrofit: The current high effiCiency base case assumes a constant 

conversion rate of 5.5% after 2000. ACEEE claimed that a conversion rate based on the 199211993 

time period is unrealistic fur future years. The low efficiency base case assumed no conversions after 

1995. Workshop participants suggested that sensitivity studies on conversion rates be perfozmed. 

What conversion rates should be considered? 

Question not asked or didn't apply. 

8.5 Future Ballast Sales Levels: Stakeholders disagree with the current forecast of total future 

ballastsaies wlrich is based on 1993 data .. The ballli$tshipments for '93, '94 and '95 are nearly flat 

at 80 miJlion per year. What.do you project thefutute.ballast shipinentsto be? 

As newconstru.ction increases, ballast sales Will follow. 

8.6 Inc9rporatingVoiuntaJ.y :Programs: The curreDt aIIalysis assJUries ,that utility OSM programs 

will diminish after 1995. ODE will review some OSM, FEMP, EP A, and EPRI data, to develop an 

upper bound and best estimate of the effects· ()f wluntary prograDls. Infozmation on these or other 

voluntary programs would be appreciated. 

" " Be careful when looking at EPA projections. Rebate progrQnlsare going down, they had a huge impact. . . . . 

B.7 Transition Technology - Cathode Cutout: . Why has this tecbnologycaptured'only 1 % market 

share? 

The cathode cutout ballast was never designed to. be a large item market item. Many reasons they 

14 
EE-RM-97-500 COMMENT OF 

are not used: 

1) reduced light output 

2) reduced life o/the lamps 

It has never been seen as a mass market, just a stop gap solution. 

PART Ci . BAJJ.AST INDUSTRY CHARACTERIZATION 

C.l What are the relevant characteristics that could be used to divide ballast manufacturers into 

meaningful subgroups for the purpose of evaluating the impacts of standards? (i.e. firm size, plant 

location, prOduct mix, etc.) 

There are basically two: 

Domestic versus Offshore , 

Full line versus Speciality 

C.2 How would you characterize your firm relative to the previous characteristics? 

, Question not asked or didn't apply. 

C.3 What changes have occurred in the ballast industry in recent years (such as the shift to electronic 

. ballasts), and how have these changes impacted your company? 

There have been huge changes in the industry. 

- the number of companies that manufacture electronic ballasts 

- everyone manufacturer makes electronic ballasts 

- more ~nd more resources are being invested in electronic ballasts 

- magnetic ballasts sales have been stayingflat or declining, there are/ewer entrants in the 

magnetic ballast market . 

PART Di MANUFACTURER COST IMPAcTS 

For each of the efficiency levels described in Section 3.6 of the "Draft Report on Potential Impact of 

Possible Energy Efficiency Levels for Fluorescent Lamp Ballasts", February 1996. (Included below): 

0.1 Are the manufacturing costs descnbed in the LBNL Cngine~g analysis -labor, materials/parts, 

shipping/packaging, and tooling/equipment - representative of your manufacturjng costs? Please 

explain. 

Question not asked or didn't apply. 

0.2 Is there a large variation in costs between different ballast manUfacturers? If so, how large, and 

what elements might. account for these' variations? 

15 
EE·RM·97·500 COMMENT OF 

Questionnoi asked or didrz 't apply. 

D.3 What would be the effect on the value of your current assets in such areas as plant, Cquipment, 

and tooling? 

Question not asked or didrz '/ apply. 

PARI Ei WPACTS ON PRODUCT SALES MID PRICE 

For each of the efficiency levels described in Section 3.6: 

E.l Would the total number ofpaUasts sold by yourfirm increase or decrease from Current forecasts? 

Why? 

Question no/ asked or didn't apply. 

E.2 Would the price on ballasts increase or decrease? Why? By how much? 

For.an electronic ballast standard, the prices of electronic ballasts would go down. 

E.3 Would the gross profit margin on. ballasts increase or decrease? Why? By' how much? 

CONFIDENTIAL 

E.4 Are you aware of other factors that could influence the price andql\llntity variables for your 

finn? (changes in distribution channels, changes in suppliers; etc.) • 

The international markets. The U.S. has an advantage in the manufacture of electronic ballasts. 

U.S.firms could sell more electronic ballasts and increase profitability as world markets d~elop. 

PAR,I Fi QTHER ISSIJES 

For each of the efficiency levels described in Section 3.6: 

V.I .. What might be the effect on current employment levels .at,your domestic manufacturing plarits? 

Please C)!:plain and quantifY If possible. . 

QUestion not asked or didn '(apply. 

F.2 What might be the effect on your company's retumon investment and overall economic value? 

Please elaborate. . 

Question not asked or didn't apply. 

16 
EE-RM-97-500 COMMENT OF 

F.3 How might your competitive position in the indusUy be affected? 

Question not asked or didn 'I apply. 

F.4 What other federal product regulations are likely to impact your firm in the near future? 

Question nol asked or didn't apply. 

17 
~E-RM,97-500 COMMENT OF 

February 14, 1997 

Interview with The American Council for an EneQlY-Effieient 

Economy Rellardinll Fluorescent Lamp Ballasts 

Oii February 5, 1997 the Department of Energy (DOE) interviewed The American Council for an 

Energy-Efficient Economy, having a place of business at 1001 ConnecticutAve., N.W., Washington, 

D.C. 20036, to discllSS various engineering, consumer, national, and manufacturer issues relating to 

, .. fluorescent lamp ballasts. The responses recorded are in italics below each interview question. 

Attendees 

The American C(.ouncil fot an EPew'-Efficien1 Economy 

Steven Nadel - Deputy Director 

DOE and CoDtractors 

Anth()ny B~lducci - DOE 

PARI A; ENGINEERING ISSUES 

A.l' Ballast Life. At the ballast workshop, held on June 20, 1996, there was some agreement that 

the ballast life currently ~ed (33,000 hours) is too l()w. It was suggested that a life ()f 50,000 h()urs 

be used-instead. The Illuminating Engineering SQCiety (IES) Lighting, Handbook; Sthedition, lists a 

lifO()f 45,000 hours f()r magnetic ballasts. DOE is prepared to use this, value for b()th magnetic and 

, electronic~allastsand is plattiring, to ,c()nduct sensitivjty studies ()n Uoequalballast lifetimes for 

magnetic and electronic ballasts ",here ()ne type would have a 33;000 h()ur life and the CJtber ballast' 

would have a 45,000 houtlife. What are y()ur,()pinions ()n this appr()al;h? 

. - \. . -, \ ; ;'. 

DOE should use the consensllS number of5Q,QQQ hours for the life :Of the ballas~. DOE should 

acknowledge that the 45,000 hour life is conservative. /n,a paperbyFred Gordon et ai, in the 1988 

A CEEE Summer Study Proceedings, there is a cite for 70,000 hour life for ballasts. Thisflgl,lre 

could be used as part ofasensitivity analysis. ' '. ' 

A.2 " ',Lamp" Life. Reduction' \Vlththe Cathode Cutout Bailast. , DOE hasteceived ,several 

comments to the effect that cdth()de cUtout ballasts reduCe lamp life by 1O~2S%.Thereseems to be 

some agreement in the C<lIDIDelits thatalamp life reductiOn of 1 S% is about average. There is al,So 

a ~une 1995 paper ~y Advancetbat supports a lamp Ufereciuction of 16% for TI2 ballasts and.S% " " " ,,', ' ,,', ' : ", ' - - ' ,'. -

fOr T8 ballasts. DOE is COilsidering the values reported by Advaric!" Do you have. any information 

to support these or. that w()uldguide DOE to use some other values? 

The numbers being used areflne. The TI2lamps are more critical in this area than the T8lamps. 

No argl,lment with what is being done. 

18 
EE·RM·97·500 COMMENT OF 

'. 

A.3 Incompatibility of Electronic Ballasts and 34 watt lamps .. ls there an Incompatibility of 

Electronic Ballasts and 34 watt lamps? Do you manufacture electronic ballasts for use with 34 watt 

lamps .. Axe there price premiums for these ballasts? If so, can you provide pricing sheets? It appears 

that starting problems have a technical solution; therefore starting problems should not be used to rule 

. out all electronic ballasts. Is this an accurate assessment? 

. Have heard about problems when the lamp is near the end of its life. it may fail. but have. not heard 

of any significant incompatibilities. It may be a problem at cold temperatures. It has to do with the 

coating on the lamps. 

A.4 Electronic Ballasts May Cause Interference with BuDding Electronic Systems., Are you 

aware of published accounts of retrofit situations where some type of interference has occurred with 

electronic ballasts? Are you aware of any electronic ballasts which do not cause this type of 

interference? Is it possible .to design an electronic ballast using appropriate filters or shields, for 

example, which will not cause this interference? Is there a cost premium for a non-interfering 

electronic ballast? Do cathode cutciut ballasts cause this type of interference? What do you do when 

a customer complains that an electronic ballast interferes with one or more of its building electronic 

.. systems? Do you provide guidelines to your distributors regarding interference effects with electronic 

ballasts? What portion of the U.S. building stock is affected by these interference problems? 

There are a couple of isolated incidents. One example is the U.S. Congress and the clock systems 

and some hospitals with older eqUipment. The problems are being worked out with adjustments in 

the equipment or the ballast. The frequency of problems are decreasing with time. The electronic 

ballasts may interfere with optical systems that use infrared communication. Less than 1 % of the 

building stock is affected. 

PARI B: CONSUMER AND NATIONAL ISSUES 

B.l Ballast Prices: Current ballast pricing information was obtained from a 1993 survey conducted 

by the Lighting Research Institute. ACEEE believes the survey overstates the current price of 

electronic models. DOE intends to reduce electronic ballast prices used in the February 1996 draft 

. report by 15%. This is based on a comparative analysis of shipments and value data from Bureau of 

Census 1993 and 1995 reports. Additionally, DOE will perform price sensitivity studies lit +15% and 

-10% of the new price. Do you agree with DOE's approach? 

Have concerns with what DOE is doing . . DOE should use the best data available. DOE should take 

the old LRI prices and reduce the difference between electronic and magnetic ballasts by 35%. The 

BOG-numbers show that manufacturers costs are down 35%for electronic. ballasts. therefore the 

price difference should also come down 35% This would give a price difference of $10 between the 

magnetic and electronic T12 ballasts. This $10 cost difference is consistent with i'!formation on the 

average price differences in the New England Electrics Incentive Program. if the mid· point of the 

analysis is biased. the sensitivities will show an inaccurate number of winners and losers. The 

estimates shouldn't be overly conservative or generous, they should be fair. The BOC numbers show 

19 
EE-RM-97-500 COMMENT OF 

that manufacturers costs are down 35%for electronic ballasts, therefore the price difference sho~ld. 

also come down 35%. DOE needs to do a sensitivity analysis shuwing the difference in price 

b~tween $5 and $15, where the $10 difference is the mid-point, DOE's Juw price differential is 

higher than ACEEE:SO average price differential. The $5 price differential comes from a .1993 study 

byASE. 

13.2 Energy Prices: The Energy Information Agency (EIA) energy price forecasts do not consider . 

the possible impacts of utility restructuring. The Gas Research Instit\lte (GRJ) has a future price 

scenario showing 29% lower commercial electricity prices by 2015,DOE will use the most recent 

EIA electricity price forecast for the year 2001 in theengineerlD.g andlife-cyCte cost analysis. 

For thepmpose of calculatingruitional benefits the Department will peri"orm life-eyc1ll-Cost sensitivitY 

analyses at -12.5% and -25% of the EIA forecast. In an additional sensitivity analysis the Department 

will determine the rate of decrease in electricity priceneedecito recJ:ttce net present vaJue of the . 

reduced 1ife-cyc\e-cost to zero. Do you agree with. this approach? Do you have any· silggestions for 

an alternative electricity price projection for the 30 year period? . 

DOE~hould look at the predictk,1/S and determine a reaso1Uiblebounds of lAncertainty •. Use the 1997 

EIAfo1Yt¢ast numbers. For the sensitivity analyses, -25%price reduqtionfor the 1997 numbers is 

too 10lV, it is beluw the OR! numbers. DOE should only reduce the 1997 fON!Castnumbers by 13% 

for the s(!nsitivities for the most extreme case. The 1997 ElAforecast is· appr()ximately a 10% 

reduqti()nfrom last year's for(!cast. .. . 

B.3 .New Market Sha.res: DOE wiUgraph.the annual ballast installations according to three 

· ~s:new ConStruction. conversions andrep~cemC!lts ... ~~etsQare (electronic as a PercC!lt 

· oftQtal insWIations) as a function of time willalso .bedisplayCIL The graphs will show the synergistic 

effects cif conversions, replacements and new constructic>n to milke,t4e ~cussif>!leasier to'f()l1ow. 

The electronic share oftotalballast sales isapproxin!atelythe sm:ne for the f4'st half of 1996 as it was 

in 1995. Do you believe these Shares should increase IdegeaseUlrough 20007 If Bo,by how much? 

", , . " . '''( 

The number qfsharesshould remain stable. Through the thitdquarter 1995 electric ballast shares 

· were siightly below 1995 $~ar(1S. ASHR4E90,} willbejinalized-2000and incprporated into 

building codes -2003~ So there sh()uld be a mod(!rategrmvthin elecirrJnic ballastsali!S past 2.003. 

It ~illbe.a long time b(!fore electronic ballast sales pass magnetic sales (in terms Qf quantities). 

B.4 . ConverSion lutes - Retrofit: The current higbllffici~cy base ease ass~ell a constant 

conversion rate of 5 ,5% after 2000 ... ACEEE claimed. that a conversion fate based on the 1992/1993 

time period is unrealistic fur future yeats. The lOw efficiency base case. assumed no conversions after 

1995. Workshop participants suggested that sensitivity stuciies on conversion rateS be performed. 

What conversion rates should be considered? 

Based on a 15 year life, 6.7% of the i~talli!dstock are repla~edeach year. A 5.5% c()nversion rate 

is more than 80% 0/ the replacement market, . If an electronic standard were enacted, this 

20 
EE-RM-97-500 COMMENT OF 

conversion rate of 5.5% would be fairly accurate, but a little low. 'i.fthere were no new standard, 

this conversion rate is too high.. The conversion rate should be approximately 1/4 of the total 

replacements, which equals 1.7%. 

B.5 Future Ballast Sales Levels: Stakeholders disagree with the current forecast of total future 

ballast sales which is based on 1993 data. The ballast shipments for '93, '94 and '95 are nearly flat 

at 80 million per year. What do you project the future ballast shipments to be? 

The total ballast shipments have been increasing over the past several decades and should continue 

due to a growing population and economy. There were a few years in the past decade that showed 

large increases in sales levels, but the growth over time has been modest and should continue. Look 

at the growth over 1989-1996 period. 

The average growth per year is 5.8% for the years 1989-1995. 

B.6 Incorporating Voluntary Programs: The current analysis assumes that utility DSM programs 

will diminish after 1995. DOE will review some DSM, FEMP, EPA, and EPRI data to develop an 

upper bound and best estimate of the effects of voluntary programs. Information on these or other 

voluntary programs would be appreciated. 

The voluntary programs have helped increase the market for electronic ballasts, but we don't see 

them gaining much more. The FEMP, EPA and DSM programs are a significant market share of 

the 30million electronic ballasts sold annually, particularly in retrofit applications. There should ' 

a slight to moderate growth due to the EPA and FEMP programs. However, with the DSM 

programs diminishing, the other voluntary'program gains have to make up the difference to 

maintain the current market share. 

B. 7 Transition Technology - Cathode Cutout: Why bas this technology captured only 1 % market 

share? . 

There are a few reasons why cathode cutout ballasts are not widely accepted in the market. The 

most significant reason is that when people make the jump to a higher efficient ballast, they tend to 

pass over the cathode cutoutand go straight to an electronic ballast. The economics are about the 

same for both types of ballasts. Cathode cutout ballasts have not been marketed as much as 

electronic ballasts. Electronic ballasts are pushed by utilities, not cathode cutout ballasts. The 

cathode cutout ballast is seen as eighties technology, while the electronic ballast is seen as modern 

technology with big energy savings. The electronic ballast is better for most applications, but the 

CC may be best for the small portion of applications where electronic ballasts cause inierference 

problems. 

PART C: BALLAST INDUSTRY CHARACTERIZATION 

C. I What are the relevant characteristics that could be used to divide ballast manufacturers into 

21 
EE·RM·97·500 COMMENT OF 

meaningful subgroups for the purpose of evaluating the impacts of standards? (i.e. fum size, plant 

location, product mix, etc.) 

· Size and product mix would be the primary characteristics. 

C.2 .. How would you characterize your ftrm relative to the previous characteristics? 

Question not asked or didn't apply. 

C.3 What changes have occurred in the balli!stindustry in recent years (such as the shift tc>' electronic 

ballasts), and how have these changes impacted ypur company? . 

. There have been.afewthings that have occurred in the industry in thepastfew years: 

• there has been a major shift to electronitballasts due to building codes and DSM 

programs 

• problems predicting juturedemand 

• the market has become more international 

• cost cutting has bec(Jme more important. 

• many mpnufacturers have moved their magnetic manufacturing out of the country 

• the electronic bailastm(lnufq.cturing is highly automated 

• international companies are selling magnetic ballasts 

• in the absence of any standard, there is a trend towards overseas production 

PART Pi MANUFACTURER COST IMPACTS 

For~h of the efficiency levels descnbedln Section 3.6 of the "Draft Report on Potential Impact of 

Possible Energy :gfficiency Levels for FluoreSCent Lamp Bal.lasts" ,February 1996. (Included below): . '. 

, , ' , " '. . -. " ",: . . 

D.I Are the manufucturing costs descnbed in the LBNL engineering analysis .labo~, materials/parts, 

shipping/packaging, and tooling/equipment - representauve of your II1l!llufacturing costs? Please 

explain. . 

.-\.. 

· We muld tend tolook at the Bureau ofC~ilu~bersasa signifiCant check.on the cost numbers. 

· D.2 Is. there a large variation in costs between different ballast manuf'acfQiers? If so,how large, and 

, what elements might account for these variations? ' , ' 

There is not a lotofvariation because it isa competitive market FirmScannotsurvive if their costs 

are significantly higher than the rest of the market. 

D.3 What would be the effect on the value of your current assets in such areas as plant, equipment, 

and tooling? 

22 
EE-RM-97-500 COMMENT OF 

Question not asked or didn't apply. 

PARI E: IMPACTS ON PRODIJCT SALES AND PRICE 

For each of the efficiency levels described in Section 3.6: 

E.I Would the total number of ballasts sold by your fum increase or decrease from current forecasts? 

Why? 

Question not asked or didn't apply. 

E.2 Would the price on ballasts increase or decrease? Why? By how much? 

For an electronic ballast standard, there would be some cost reduction due to the increase in 

production and automation, but it would not be dramatic. 

E.3 Would the gross profit margin on ballasts increase or decrease? Why? By how much? 

Question not asked or didn.'t apply. 

E.4 Are you aware of other factors that could influence the price and quantity variables for your 

firm? (changes in distribution channels, changes in suppliers, etc.) 

Inventory costs would go down because companies would only stock one line of ballasts, not two. 

The overall quantities would not be affected 

PART F: OTHER ISSIJES 

For each of the efficiency levels describedin Section 3.6: 

F.I What might be the effect on current employment levels at your domestic manufacturing plants? 

Please explain and quantifY if possible. 

Question not asked or didn 't-apply. 

F2 What might be the.effect on your company's return on investment and overall economic value? 

Please elaborate. . 

Question not asked or didn't apply. 

F.3 How might your competitive position in the industry be affected? 

Question not asked or didn't apply. 

23 
EE-RM-97-500 COMMENT OF 

F.4 What other federal product regulations are likely to impact your firm in the near future? 

ASHRAE 90.1 building codes. won '( affect the market untii- 2003 and lamp standards even later, 

since the standards are not presently on DOE's agenda. 

24 
EE-RM-97-500 COMMENT OF 

February 6, 1997 

Howard Industries Ballast Interview 

On February 4, 1997, the Department of Energy (DOE) and its contractors visited Howard 

Industries, Inc. to discuss various engineering, consumer, national, and manufacturer issues 

relating to fluorescent lamp ballasts. The interview was conducted at the Howard Industries 

offices in Laurel, Mississippi. The responses are recorded in italics below.each interview 

question. 

Attendees 

Howard Industries 

Billy Howard, Jr. 

Dr. Wayne Causey 

Mr. Michael Dodds 

DOE and Contractors 

Ms. Barbara Twigg - DOE 

Mr. Terry Logee - DOE 

Stephen Mariano - Arthur D. Little 

PART Ai ENGINEERING ISSUES 

A.I Ballast Life. At the ballast workshop, held on June 20, 1996, there was some agreement 

. that the ballast life currently used (33,000 hours) is too low. It was suggested that a life of 

50,000 hours be used instead. The Illuminating Engineering Society (lES) Lighting Handbook, 

8th edition, lists a life of 45,000 hours for magnetic ballast. DOE is prepared to use this. Value for 

both magnetic and electronic ballasts. and is planning to conduct sensitivity studies on unequal 

ballast lifetimes for magnetic and electronic ballasts where one type would have a 33,000 hour life 

and the other ballast would have a 45~000 hour life. What are your opinions on this approach? 

Motorola literature shows a guarantee of 135,000 hours to the time where' 50% of '. 

ballasts have failed. Howard Industries designs with 500,000 hours. They thought that 45,000 

hours was much too short. Their information is based on reliability statistics, Mil Std. 217. 

Discussed the effects of temperature and electric field stresses. The industry uses a 5 to 7 year' 

warranty, 

A.2 Lamp Life Reduction with the Cathode Cutout (CC) Ballast. DOE has received several 

comments to the effect that cathode cutout ballasts reduce lamp life by 10-25%. There seems to 

be some.agreement in the comments that a lamp life reduction of 15% is about average. There is 

also a June 1995 paper by Advance that supports a lamp life redu.ction of 16% for T12 ballasts 

and 8% for TS ballasts. DOE is considering the values reported by Advance. Do you have any 

information to support these or that would guide DOE to use some other values? 

25 
EE-RM-97-500 COMMENT OF 

Howard Industries has not worked with the CC ballast but they didn't think that the CC 

· ballast should cause shorter lamp life based on the physics of lamp operation. The CC b,allast 

starts a lamp like a RS ballast and then runs a lamp like an IS ballast. 

A.3 Incompatibility of Electronic Ballasts and 34 watt lamps. Is there an Incompatibility of 

Electronic BaUasts and 34 watt lamps? Do you manufacture electronic ballasts for use with 34 

watt lamps. Are there price premiums for these ballasts? If so, can you provide pricing sheets? It 

appears that starting problems have a technical solution; therefore starting problems should not be 

used to rule out all electronic ballasts. Is this an accurate assessment? 

· Howard Industries doesn't manufacture any TIl, ballasts atpresent 

A.4 Electronic Ballasts May Cause lnterferencewlth BulldingElectr,onlc Systems. Are you 

aware of published accounts of retrofit situations where some type of interference has occurred 

with electronic ballasts? Are you aWare of any electronic ballasts which do not cause this type of 

interference? Is it possible to design aneleqtronic ballast using appropriate filters or shields. for 

tOxample. which Will not cause this interference? Is there a cost premiUlll fora non-interfering 

electronic ballast? Do cathode' cutout ballasts cause this type of interference? , What do you do 

when a customer complains that an electronic ballast interferes with one' or tll9re of its building 

electronic systems? Do you provide guidelines to your lfistributors regar4ing interference effects 

with electronic ballasts? What portiOn of the U.S. building stock is affected by these interference 

probiems? .. 

No, HowardJndustries hasn '( encounterei( any problems like these. A brief discussion of the 

three forms of fntfJrference follows. . 

Howard Industries electronic ballasts .use 24-25 kHz;Electroni(! baltaststYpicallxuse a range 

from 22, "30 kHz .. . '. They are aware of some problems that comPfltitors,havltlladwilh remote TV . 

controllers ina hospital. The remote control manufacturers are.goingtouffe 40 kHz and as long 

as ballast manufacturers avoid that frequency and multiples of that frequency there shOuld be no 

problem. 

There can be EMI interjerencealso but the FCC regulates this very stringently.· . . '. ,'. 

With. re~ardto power line c(Jrrier sigrlals lik/ii the Si,nplex clock contriJlIersuse. Boward 

Industries. has the highest input impedance of any manufacturer in their passive electronic 

ballast desigrls. . Simplex has apprQved th/ii Howard Industries passivi1 electronic ballast designs 

for use with Simplex systems. (High input impedance minimizes the intei:t'errtnce to power .line 

· carrier signals.) With their active electronic ballast designs, perhaps only one desigrl will work 

with the Simplex system. . ' ", 

They nole that a ballast manufacturer Will get the most cost savin~s in ballast components at 

higher frequencies because with smallermagrleticcomponents, the costs go down. 

26 

, 
EE-RM-97-500 COMMENT OF 

PART B: CONSUMER AND NATIONAL ISSUES 

B.! Ballast Prices: CUrrent ballast pricing infonnation was obtained from a 1993 survey 

conducted by the Lighting Research Institute. ACEEE believes the survey overstates the current 

price of electronic models. DOE intends to reduce eleptronic ballast prices used in the February 

1996 draft report by 15%. This is based on an a comparative analysis of shipments and value data 

from Bureau of Census 1993 and 1995 reports. Additionally, DOE will perfonnprice sensitivity 

studies at + 15% and -10% of the new price. Do you agree with DOE's approach? 

CONFIDENTIAL 

B.2 Energy Prices: The Energy Infonnation Agency (EIA)· energy price forecasts do not 

consider the possible impacts of utility restructuring. The Gas Research Institute (GRI) has a 

future price scenario' showing 29% lower commercial electricity prices by 2015. DOE Will. use the 

most recent EIA electricity price forecast for .the year 2001 in the engineering and life-cycle cost 

analysis. 

For the purpose of calculating national benefits, the Department will perfunn life-cycle-cost 

sensitivity analyses at -12.5% and -25% of the EIA forecast. In an additional sensitivity analysis 

the Department will detennine the rate of decrease in electricity price needed to reduce net 

present value of the reduced Iife-CY,cle-cost to zero. Do you agree with this approach? Do you 

have any suggestions for an alternative electricity price projection for the 30 year period? 

Howard Industries is not really expert enough to comment but they believe that even where 

electric rates are lowest; most paybacks are still within the time frame that most buyers would 

consider cost effective. For example, Mississippi Power •. which services Howard Industries, has 

some of the lowest rates. Howard Industries retrofitted their offices which used older EEM 

ballasts with new T8 electronic ballasts and lamps. At Howard Industries' commercial rate of 4 

cents per kWh, they have less than a 2 year payback. This was without rebates. 

B.3 New Market Shares: DOE will graph the annual ballast installations according to three 

segments: new construction, conversions and replacements. Market share (electronic as a . 

percent of total installations) as a function of time will also be displayed. The graphs will show 

27 
EE·RM·97·500 COMMENT OF 

the synergistic effects of conversions, replacements and. new constructi~n to make the discussion· 

easier to follow. The electronic share of total ballast sales is approximately the same for the first 

half of 1996 as it was in 1995. Do you believe these shares should increase 1 decrease through 

2000? If so, by how much? .. 

Howard Industries belieVes that the market share of electronic ballasts should increase slowly 

through 2000. They discussed. this statement ill the context of the three major market segments 

of ballast sales: new construction, conversions and replacements. 

Howard Industries believes that barring any unforseen economic downium, sales of e1i!ctronic 

ballasts in new construction will continue to grow Pa$/ the 50% range that they were at by the 

end of 1996. This is based on their discussions with the six major fixture manufacturers and 

with several smaller speciality fixture manufacturers. 

Howard Industries believes that conversions are probably flat or downfrom apeak in 1994 when 

utility rebates were flowingfreely. There has been a dramatic decline in DSM jUnding but many 

utilities are creating their own energy ser,vice companies (eSCO 's)as subsidiaries arid these 

Compalliesare buying ballasts and fixturesfor the conversion mark~t. Howard Industries claims 

this is a conseq/.lence of utility deregulation .andefforts byutility.companies to lock in an 

existing customer under a lease buy back program at a flXedelectric power rate. 

In the replacement market, Howard Industries only knows aboul/he largest projects . . They 

believe that electronic ballasts accountfor less than 20% of the 71larket, since people usually 

replace what is already there with similar ballasts, . usually magfletic. , ' . 

B.4 CODversloD.Rates - Retrofit:· The curreiJ.t highefficiencybas.e case· assumes a constant 

conversion rate of 5.5% after 2000, ACEEE claimed that a conversion rate based on the ' 

1992/1993 time period is unrealistic ror future years. Thelowefljciericy base case assumed no, 

conversions after 1995. Workshop participants suggested that seiJ.sitivity studies on conversion 

rates be performed ... What .conversion rates should be considered? '. 

Howard Industries disagrees with DOt's lowejJiciencybqsecase·~ihi~h asS/.l71led no conversions 

after 1995. See the answer 10 B3. Howard Industries suggested that conversions miiyrise 

someWhat in 1997 if/he econotnystaysstrong: ., . 

B.5 Future Bal!ast Sale.s Levels: Stakeholders disagree with the cuttent forec~t of tOtal future 

ballast saleswhichis based on 1993 data. The ballast shipmentsfor'~3, '94 ~d'95 are nearly flat 

at "80 million per year. What do you project the future ballast shipm.ents to .be? . . 

Howard Industri(!S believesthat these will mcrease slightlY in the next several years due to new 

construction, assuming· a steady economy. New construction is using inorethan the retrofit 

market now. 

28 
EE-RM-97-500 COMMENT OF 

B.6 Incorporating Voluntary Programs: The current analysis aSsilihes that utility DSM 

programs will diminish after 1995. DOE will review some DSM, FEMP, EPA, and EPR] data to 

develop an upper bound and best estimate of the effects of voluntary programs. Information on 

these or other voluntary programs would be appreciated. 

The utility ESCO 's. may fill the gap left by the vanishing DSM program, as utilities try to protect 

their market from erosion due to deregulation. Howard Industries believes that the EPA Green 

Lights program has been quite successfol. Howard Industries also believes that the EPACT 

legislation has had a positive impact with regard to federal facilities. With a mandate to reduce 

electricity use by 30% by 1998, federal facility managers are relying heavily on lighting retrofits 

to get most of the jOlJ done. EPRI may have some information from a certification program that 

they run. Howard Industries expects that ASH RAE 90,[ may have large impacts on electronic 

ballasts use in new and retrofit construction once the program becomes codified in state building 

codes. They thought that this effect wouldn't occur for about 5 years. 

B.7 Transition Technology - Cathode Cutout: Why has this technology captured only 1% 

market share? . 

Howard Industries doesn't manufacture this type of ballast but they do 1lf2I. view it as transition 

technology. They believe that the cost difference between an electronic ballast and a cathode 

cutout balldst is small and growing smaller. Since the energy savings with cathode cutout 

ballasts is small, the payback isn't good. Furthermore, utility rebates didn't include cathode 

cutout technology because the total harmonic distortion with these ballasts is about 30%. 

PARI C: BALLAST INDUSTRY CHARACTERIZATION 

C.I What are the relevant characteristics that could be used to divide ballast manufacturers into 

meaningful subgroups for the purpose of evaluating the impacts of standards? (i.e. firm size, plant 

location, product mix, etc.) 

CONFIDENTIAL 

C.2 How would you.characterize your firm relative to the previous characteristics? 

CONFIDENTIAL 

C.3 What changes have occurred in the ballast industry in recent years (such as the shift to 

electronic ballasts), and how have these changes impacted your company? 

29 

o 
EE-RM-97-500 COMMENT OF 

CONFIDENTIAL 

PART D: MANUFACTURER COST IMPACTS 

, For each of the' efficiency levels described in Section 3.6 of the "Draft Report on Potential Impact 

of Possible Energy Efficiency Levels for FhiorescentLattlP Ballasts", February 1996. (Included 

below): ' 

. '. '. . 

, 

D.l Are the manufacturing costs described in the LBNL engineering analysis -labor, 

materials/parts, shipping/packaging, and tooling/equipment -representative of yoUr manufacturing 

costs? :Please explain. 

CONFIDENTIAL 

D.2 • Is there a large variation in costs between different ballasUnanufacturers? If so, how large, 

and what elements might account for these variations? ' , ' 

There are no large differences in costs ~etweenballast manufachlrersdue to intense 

competition., There are two different design topologies but most m,timgacturers make both kinds, ' 

, active and passive. There are not many spf!!cial desi/PI.s/n-otepted by patents.! Also, aU the ' 

manufacturers are highly automated even in the forei/PI.colintries. , 

D.~ What would b!) th!)!)ffect on the value of your cUIl'ent assets in such areas as plant, 

equipment, and toOling? 

None. 

PART E: IMPACTS ON PRODUCT SALES AND PRICE 

For each of the' efficiency levels described in Section 3.6: 

30 
EE-RM-97-500 COMMENT OF 

E.l Would the total number of ballasts sold by your finn increasebr decrease from current 

forecasts? Why? 

Cathode cutout ballasts are a non-issue. However, DOE could allow manufactur~ of cathode 

cutout ballasts and it would not affect the industry because the savings is only 4 watts. 

The largest selling electronic ballast is the instant start T8 ballast. It accounts for about 85% of 

the 4 'fluorescent ballast sales .. They suggest simplifications such as putting the categories of 

instant-start and rapid-siart ballasts together, saying that DOE has created artificial categories 

that don't really exist in the market. Then, DOE could cover those situations like occupancy 

sensor controls where the rapid-start ballast is appropriate. Either level three or levei four 

would result in an increase in ballast sales for Howard Industries. However. they commented 

that in 5 years, 80% of the market will probably be electronic ballasts anyway. They noted that 

the instant-start ballast is slightly cheaper and there are more energy savings but a somewhat 

shorter lamp lifo. 

E.2 Would the price on ballasts increase or decrease? Why? By how much? 

Electronic ballast prices will go down due to competition regardless of any government 

standards! 

E.3 Would the gross profit margin on ballasts increase or decrease? Why? By how much? 

Not now; the market has matured. 

E.4 Are you aware of other factors that could influence the price and quantity variables for your 

finn? (changes in distribution channels, changes in suppliers, etc.) . 

Not really. A rulemaking wouldn't change distribution. Electronic ballasts are a small part of 

the electronic component market so a rule wouldn't affect the electronic component supply 

capacity. It's a different situation today from J 993 - the industry has already done what an 

earlier rulemaking would 'have. 

PART F: OTHER ISSUES 

For each of the efficiency levels described in Section 3.6: 

F.l What might be the effect on current employment levels at your domestic manufacturing 

plants? Please explain and quantifY ifpossible. 

CONFIDENTIAL 

F.2 What might be the effect on your company's return on investment and overall economic 

31 
EE-RM-97-500 COMMENT OF 

value? Please elaborate. -

Some increase with levels three or four. 

F.3 How might your competitive position in the indusJ:rr be affected? 

A slight improvement. 

F.4 What other federal product regulations are likely to impact your fum in the near future? 

No negative impacts. Since electronic ballast mamifacture is quite clean, they have no impact 

from the clean air standards.' ' 

The AsHRAE 90.1 standards will have a positive impact. 

OTHER COMMENTS NOT DIRECTLY ADDRESSED BY INTERVIEW QUESTIONS , , ' 

Electronic ballasts with active designs typically can only withstand surge voltages of about 1,000 

V. Active designs a/so Jrave higher inrush current but can be designed with total harmonic , 

distortion less than J 0%. They are higher priced by$1-$1.50. All of the Motorola electronic , 

ballasts are active designs. 

Passive ballast.designs·can withstand,much higher surge voltage, typically greater than 5,000 

volts. They have low inrush current and they are cheaper but typically have total harmonic 

distortion around 20%. 

CONFIDENTIAL 

32 
8 

~ 

s 

~ 

~ 

w 

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EE·RM·97·500 COMMENT OF 

December 26, 1996 

. . h MagneIek. Inc. 

IntervIew WIt t Lamp Ballasts. Regarding Fluorescen 

On December 10, 1996 the Department of Energy (DOE) and its contractors interviewed 

MagneTek, inc., having a place of business at 26 Century Boulevard, Nashville,Teil1lessee, 

37214, to discuss various' engineering, consumer, national,. and manufacturer issues relating to 

fluorescent lamp ballasts. The interview was conducted at MagneTek's headqulj.l'!ers ~ Nashville, 

Tennessee .. The responses recorded are in italics below each interview question. 

Attendees 

Ma~.Inc. 

Michael Stein, Director, Prodqct Development .. 

William Bacon, Jr. " Vice President,Product Management 

Peter Caldwell· Vice President, Marketing 

Jim Hagar· Product Manager·. . 

William Kirkland • Vice President, EaStern Region Lighting Products Group 

Robert Mmray, Vice President, Communications, Inve~torRelations 

DOE and Contractors 

Anthony Balducci" DOE 

Terence Logee - DOE 

Michael Rivest - Arthur D. Little 

PAATA:· ENGIlSEWNG ISSUES 

A.IBallast Life. At the ballast workshop, held on June 2Q, 1996, there was some agreement 

thatthe ballast life! curi:ently used (33,000 hours) is too low. It was suggested that a life of 

50,000 hours be used instead. TheJlluminating Engineerinj! !;ociety QES) Lighting Handbook, 

8th edition, lists a life. of 45,000 hours for magnetic ballasm. DOEispteparedtousethis valUe for 

, both magnetic and electronic ballasts and isp1anning to conduct sensitlvitystudies on unequal 

ballast lifetimes for magnetica0gelectronic ballasts where one ,type wotddhavea 33,000 hour life 

and the other ballast would have a 45,000 hour life. What are your opinions. on this approach? 

Comfortablewith the 45,000 hour life. Do sensitivity analysis with the life of the ballasts equal. 

Do not use unequal baliast lifetimes for electronic and magnetic ballasts. . . 

A.2 Lamp Life Reduction with the Cathode Cutout Ballast. nOE has received several 

comments to the effect that cathode cutout ballasts reduce lamP life~y 10-25%. :There, seems to 

be some agreement in the comments that a lamp life reduction of 15% is about average. There is 

also a June 1995 paper by Advance that supports a lamp' life reduction 006% for TI2 ballasts 

34 
EE·RM·97·500 COMMENT OF 

and 8% for T8 ballasts. DOE is considering the values reported l:IyA.dvance. Do you have any', 

infonnation to support these or that would guide DOE to use some other values? . 

15% reduction in lamp life is reasonable compromisl;!. Perform sensitivity analysis down to IO% 

and \lP to 25%. Lamp manufacturers publish 25% reduction in lamp life with cathode cutout 

ballasts. Give weight to lamp manufacturers for lamp life reduction. The Advance paper just 

looks at a batch of lamps. It is the average for the test. Make lamp life reduction equal for both 

types of ballasts in the analysis. 

A.3 Incompatibility of Electronic Ballasts and 34 watt lamps. Is there an incompatibility of 

Electronic Ballasts and 34 watt lamps? Do you manufacture electronic ballasts for use With 34 

watt lamps. Are there price premiums for these ballasts? If so, can-you provide pricing sheets? It 

appears that starting problems have a technical solution; therefore starting problems should not be 

used to rule out all electronic ballasts. Is this an accurate assessment? 

Yes there is an incompatibility with electronic ballasts and 34 watt lamps. The 34 watt lamp uses 

a krypton gas fill which makes the lamps harder to start. Therefore, the lamp manufacturers put 

a metallic coating on the lamp to make them easier to start with magnetic ballasts. . Without the 

. coating, magnetic ballasts cannot start the lamps. The coating acts as a capacitor with the 

electronic ballasts. The lamp manufacturers don't have good control over the tin coating 

thickness on lamps. This causes vtlriability with operation on electronic ballasts. 

The 34 watt lamp does not dim well and industry will get away from the 34 watt TI2 lamp. 

A.4 Electronic Ballasts May Cause Interference with BuDding Electronic Systems. Are you 

aware of published accounts of retrofit situations where some type of interference has occurred 

with electronic ballasts? Are you aware of any electronic ballasts which do not cause this type of 

interference? Is it possible to design an electronic ballast using appropriate filters or shields, for 

example, which will not cause this interference? Is there a cost premium for a non·interfering 

electronic ballast? Do cathode' cutout ballasts cause this type of interference? What do you do 

when a customer complains that an electronic ballast interferes with one or more of its building 

electronic systems? Do you provide guidelines to your distributors regarding interference effects 

with electronic ballasts? What portion of the U.S. building stock is affected by these interference 

problems? 

Yes, we are aware of situations where some type of interference has occurred with electronic 

ballasts. NEMA has a paper on it. See MagneTek technical notes 24 and 25. There are options 

to avoid this· magnetic and cathode cutout ballasts. Retrofits very small-I%. This problem is 

very diffiCUlt to overcome with equipment using power line carriers, i.e. Simplex. The industry 

needs to address the infra-red issues. There are some problems with inrush currents and 

occupancy sensors. NEMA is working with manufacturers of this equipment. 

35 
EE-RM-97-500 COMMENT OF 

PART Bi . CONSUMER AND NATIONAL ISSUES 

B.1 Ballast Prices; Current ballast pricing information was obtained from a 1993 survey 

conducted by the Lighting Research Institute .. ACEEE believes t)1e survey overstates the current 

price of electronic models. DOE intends to reduce electronic ballast prices used in the February . 

1996 draft report by 15%. This is based on an a comparative analysis of shipments and value data 

from Bureau of Census (DoC) 1993 and 1995 reports. Additionally, DOE wilI perform price 

sensitivity studies at + 15% and -10% of the new price. Do you agree with DOE's approach? 

Suggest that DOE does'not change the ballasts prices in the analysi;, use the pricesjr9m the LRi 

s~dy. The BoC ~eflects prices paid by ballast Tflanufac~rerc!/Stomers,not the end users. 

Change in mix afballasts has changed the distribution. More ballasts to OEM's than . 

distributors .. The only way to get updat~dprices is'todoanothersurvey. Agree with the LRi 

report and approach. Agree with sensitivity analysis,but don 'tchange the numbers without 

proper data. . 

13.2 Energy Prices: The Energy Information Agency (EIA)~ergy price forecasts do not 

consider the possible impacts Qfutility restructuring, The Gas Research Institute (GRI) has a 

fu,tute price scenario shOwing 290/0' lower commercial electricity prices by 2015. DOE will use the 

mo.strecent EIA electricity price forecast for the year2001 in the enginc:eringand life-cycle cost 

analysis; - . , . 

For the purpose of calculating national benefits the Departmel1t wilI perform life-cycle-cost 

sensitivityanalys~s at -125% and -25% of the EIAforecast.In an additional s~sitivity analysis, 

the Departm~t wiU determine the ~ate of decrease.in electricity Jlriceneeded tortlduce net 

present V'ah~eofthe reduced life-cyc)e,cost to zero. D~youagreewitht)1is approach? . Do you 

have any suggestions for analtefilativeelectricity price projection for the 10yearperi6d? 

Look at sensiti~itYforthefour (4) ballasts with the Mghests.al~VQlumes, tikedthepresentation 

.by LBNL on electriCity pric~ vs. energy savings at theJuneworksliop •. D,o one s,cel/llrio with 

different price reductions, J:i,5%and 25% price redlfctionsare fine. . 

B.3New Markd Shares:' DOE willgrllph theanp.u~·~aUast.inStal!atiotis accotd#1gto three 

segments: new coustruction, cOliversiousand replacetnen1:s.¥Brke1: share (ele~o~c as a 

percent of total installations) as a function of timewin.alsri.be display~. The graphs will sh()w 

the sYnergistic ~ffe~sof conversions, replacements arid newconS1:!'uction tomake1he discussion 

easier to follow. The e1ecti'onic share of total ballast sales isapProximatc:;ly.the Sam,eforthe first 

half .of 1996 as. it was in 1995. . Do you believe these shatesshoul4 mcrease I decrease through 

2000? If so, by how mUch? .' . 

CONFIDENTIAL 

B.4 CI)Dvei'sionRates - Retrofit: The current high efficiency base case assumes a constant 

36 
EE-RM-97-500 COMMENT OF 

conversion rate of 5.5% after 2000. ACEEE claimed that a convetSidli rate based on the 

199211993 time period is unrealistic for future years. The low efficiency base case assumed no 

conversions after 1995. Workshop participants suggested that sensitivity studies on conversion 

rates be perfonned .. What conversion rates should be considered? 

No conversion scenario is ridiculous. Conversions occur all the time, not just for efficiency 

reasons. Suggest 10% or greater. 

B.5 Future Ballast Sales Lev!lls: Stakeholders disagree with the current forecast of total future 

ballast sales which is based on 1993 data. The .ballast shipments for '93, '94 and '95 are nearly.flat 

at 80 million per year. What do you proj ect the future ballast shipll}ents to be? . 

Total shares will remain relatively flat. 

B.6 Incorporating Voluntary Programs: The current analysis assumes that utility DSM 

programs will diminish after 1995. DOE will review some DSM, FEMP, EPA, andEPRI data to 

develop an upper bound and best estimate of the effects of voluntary programs. Infonnation OD 

these or other voluntary programs would be appreciated. 

FEMP program and NEMA program are'hard to quantify. Federal government buildings may 

be a good check. ASHRAE 90.1 requires certain watts per square foot, per EPA CT the states 

should adopt this. Have to promote to change the mind set. Will work together to promote 

voluntary programs to sell electronic ballasts. All for selling electronic ballasts, but don't want 

itforced on consumers or us. 

B.7 Transition Technology - Cathode Cutout: Why has this technology captured only 1% 

market share? 

If someone is goingfor an efficiency gain they will purchase the electronic ballasts. If thij are 

looking atjirst cost, magnetic ballasts are the choice. Believe that the price difference between 

electronic and cathode cutout is not a driver .. 

PARI C; BALLAST INDUSTRY CHARACTERIZATION 

C.I What are the relevant characteristics that could be used to divide ballast manufacturers into 

meaningful subgroups for .the purpose of evaluating the impacts of standards? (i.e. fum size, plant 

location, product mix, etc.) 

Three groupings; 

1. Most meaningfUl - Product Orientaiion - magnetic, electronic, both 

2. Serve market - applications I product mix 

Niche market vs. Full product lines (serves all / most markets, more diversity) 

3. Vertical Integration -fully integrated vs. assembler 

37 
EE-RM-97-500 COMMENT OF. 

C.2 How would you characterize your firm relative to the previous characteristics? 

MagneTek offers full product lines for magnetic and electronic ballasts. Vertical integration is 

different for different products. Magnetic ballasts -fully vertically integrated, electronic -

assembler, purchase parts. 

C.3 .What changes have occurred in the ballast industry in recent years (such as the shift to 

electronic ballasts), and how have these changes impacted your company? . 

The shift to electronic ballasts has beef! the most dramatic change. It will change: 

- how we. look at competition . 

- how we have to manufacture ballasts 

-.how we deploy assets - different assets forthe two different types of ballasts 

PARTD: MAlSJJFACTJ1RER COST IMPACTS 

For each oftheefficfency levels described in Section 3.6 ()fthe "Draft Report on Potential Impact 

of Possible Energy Efficiency LevelsforFluorescel1t LaIllp Ballasts", February 1996. (Included 

below); 

DJ Are the manufacturing costs described in the LBNL eI1gil:1eering analysis .. labor, 

materials/parts, shipping/packaging, and tooling/equipment -representative of your manufacturing 

costs? Please explain. . 

Some made sense, some didn '~. For a conventional manufacturer material, labor and overhead 

tire the manufacturing costs. Overhead is done different ~ays ~ labor hours, machine hours, 

production units. Capital investrnentshave to be acco.unt.ed far. The buckets in the report don't 

cover all the expenses, nqr does the report allocate ~pense .the way·rnost do it. 

D.2 Is there a large variation' in costs betweel1differ~t ballast manufacturers? If so, how large, 

and what elements might \,ccount for these variations? 

Severalfactors play into it;' 

- volume . . - vertiqaUntegration ;. buy rolls of steel, not iaminatiollS 

- labor costs - offsetby equipment (automation). Equipment gets depreciated 

- G&A -management structure 

D.3 What would be the effect on the value of your current.assets in such areas as plant, 

equipment, and too1ing? 

Would have to pUrchase different assets to manufacture electronic ballasts anddispose of 

current assets. Would have stra1')ded costs due to lost assets. 

38 
EE·RM·97·500 COMMENT OF 

PART E; IMPACTS 9N PRODUCT SALES AND PRICE 

For each of the efficiency levels described in Section 3.6: 

E.l Would the total number of ballasts sold by your finn increase or decrease from current 

forecasts? Why? 

Cathode Cutout not Widely accepted, so a cathode cutout standard would inCrease electronic 

ballast sales. As you go more towards electronics, the total volume of ballasts sold will decrease 

because there are 3 and 4 lamp electronic ballasts. Cathode Cutout ballast sales would 

increase, but not as much as electronic ballasts. 

E.2 Would the price on ballasts increase or decrease? Why? By how much? 

For Cathode Cutout ballasts, don 't know what the price increase would be. You are asking the 

device to do something additional, which adds costs. . 

Electronic ballasts are very complex. The price may go up due to the shortage of reliable 

components. Problem is with the availability of ballast grade components. 

E.3 Would the gross profit margin on ballasts increase or decrease? Why? By how much? 

Market place sets the price. many people in the distribution chain .. Anyone who has 

infrastructure (existing magnetic ballast manufacturing assets) could be put out of business. 

Assets have everything to do with the business. 

E.4 Are you aware of other factors that could b;tfluence the price and quantity variables for your 

finn? (changes in distribution channels, changes in suppliers, etc.) 

Suppliers of steel, copper and tar would be affected. Finding enough component suppliers to 

. support electronic ballasts would influence the price and quantity of electronic ballasts. The 

reliability of components in electronic ballasts is (and must continue to be) very high. For 

example, if 4% of the ballasts (under warranty) fail, have to replace 100% of the installed 

ballasts plus pay for the labor to do the change. There is a shortage of ballast grade 

components for electronic ballasts so any regulation would have to be very carefolly timed. 

PART F; OTHER ISSIJES 

F.or each of the efficiency levels described in Section 3.6: 

F.I What might be the effect on current elnployment levels at your domestic manufacturing 

plants? Please explain and quantifY if possible. 

With a Cathode Cutout standard, the employment level may go up if there is a onefor one 

39 
EE·RM·97·500 COMMENT OF 

replac.ement of magnetic with cathode cutout ballasts. As electronic ballast sales increase, there 

will be a reduction in employment. Magnetic ballast manufacturing is more labor intensive than 

manufacturing electronic ballasts. There would be an impact on the suppliers as well. 

Electronic components are sourced around the world. 

F.2 What might.be the effect on your company's return on investment and overall economic 

value? Please elaborate. . 

An electronic ballast standard~ould decreaSe the retumon investment. Would have to write off 

stranded assets and purchase new assets to man~facture electrOnic ballasts. 

F.3 How might your competitive position in the industry bi: affected? 

, 

Don't know how c011lpetitive we would be due to the uncertainty in the market and the other 

manufacturers. We know the current competition; don't know who will enter or leave the market . 

.Don't know how or what other manufoclllrerswill do .. It .all has to do with the deplO)'T1ient and . 

use of assets. 40% of sales are from the Lighting part of MagneTek, so anew regulation which 

outlaws half of their assets .will have a big impact. 

F.4 What other federal product regulations are likely to impact your firm in the near future? 

The electric motors standard (EPAct) that becomes effective October 24, 1.997. Also the small 

m%rs covered by EPAct and any OSHA. regulations. 

40 
EE-RM-97-500 COMMENT OF 

Interyjew with Motorola L!&htin&_ Inc. 

Re&ardiDlI Fluorescent Lamp BaUasts 

January 6, 1997 

On November 14, 1996 the Department of Energy (DOE) and its contractors interviewed 

Motorola Lighting, Inc., having a place of business at 887 Deerfield Parkway, Buffalo Grove, 

Illinois 60089, to discuss various engineering, consumer, national, and manufacturer issues 

relating to fluorescent lamp ballasts. The responses recorded are in italics below each interview 

question. 

Attendees 

Motorola LilWtini. Inc. 

Marios Zenios - Vice President, Motorola Inc., and President, Motorola Lighting, Inc. 

Howard Wolfman - Manager, Industry Standards and Utilities 

Tim Callard - Controller 

DOE and Contractors 

Anthony BalducCi- DOE 

Eugene Margolis - DOE 

Isaac Turiel - Lawrence Berkeley National Laboratory 

Stephen Mariano - Arthur D. Little 

Michael Rivest - Arthur D. Little 

PARI A; ENGINEERING ISSUES 

A,I Ballast Life. At the ballast workshop, held on June 20, 1996, there was some agreement 

that the ballast life currently used (33,000 hours) is too low. It was suggested that a life of 

50,000 hours be used instead. The Illuminating Engineering Society (JES) Lighting Handbook, 

8th edition, lists a life of 45,000 hours for magnetic ballasts. DOE is prepared to use this value for 

both magnetic and electronic ballasts and is planning to conduct sensitivity studies on unequal 

ballast lifetimes for magnetic and electronic ballasts where one type would have a 33,000 hour life 

and the other ballast would have a45,OOO hour life. What are your opinions on this approach? 

For electronic ballasts you get the quality that you pay for. The ballast life is highly dependent 

on the manufacturer. Motorola aims to produce the ballast with longest life- electronic or 

magnetic. Motorola has produced similar electronic products that are used in harsher 

environments-sue/} as Caterpillar tractors- and achieved lives of 15120 years. The better quality 

of Motorola ballasts does not command a premium cost. 

Do you have failure rate Data? 

41 
EE-RM-97-500 COMMENT OF 

Yes ~e have accelerated-life-testing data. We have achieved a wiry good balance of quality and 

first costs. Motorola hasafive year in-pkice guarantee which is also an industry standard. Our 

,design life-time is 87,600 hours. 

We believe that a 45,000 hour lifetimefor electronic ballasts is too low. DOE should benchmark 

ballast lifetime with tlJe best available electronic ballasts since all manufacturers will improve 

their quality to be competitive. Recognize that we are not dealing with a mature technology that 

haS achieved its foil performance potential. 

We have no opinions (that can be substantiated)pn magnetic ballast lifetimes . 

. A.2 Lamp LifeReducU"n with the Cath"dEl Cutout Ballast. DOE has received several 

com1ilents to the.' effect that cathode cutout b,alillsts reduc¢ lamp life by 10-25%. Ther,e seems to 

be some agre¢ment in the comments that a lamp life reduction of15% is aooutaverage. There is 

also a June 1995 paper by Advance thlltsupports a lamp life reductionof 16% forTI2 ballasts 

and 8% for T8 ballasts. DOE is considering the values reported' by Advance. Do you have any 

information to support these or that would guide DOE to use some other values? 

Cathode cutout ballasts are primarily.magnetic. We don it manufacture any but we.agree with 

the statement of reduced lamp life based on our engineering experience and understanding of 

the phenomena. 

A.3 Incompatibility :of Electronic Ballast, and 34 watt lamps. Is there an Incompatibility of. 

Electronic Ballasts and 34 watt lamps? Do you manufactureelectroni'lballasts. for use with 34 . 

watt lamps. Are there price prennums. for these ballasts? If so,can you provide pricing sheets? It ' 

appears that starting problems have a technical solution; therefore .startingproblems·should not be 

used to rule out all electronic ballasts.b this an accurate assessment? ' ,' .

. Yes, there areaq~ounis of incompatibility. The tin coafingon the lamps cah.act asa short 

circuit. Only 10% of the electronic market goes to T12 !lamps; this is decreasing. ,·One way of ' 

addressing this issue would be for the lamp companies to provide a .34 watt ramp without the tin . 

oxide coatingfor.operationwith. electronic ballaSts. Genel'al Electric didoffei' such a lamp type 

a number of years ago. ' ' 

AAEledr"nlcBalIasts ~aycause lnterference With BUilding E.ectl'l)nicSy~tems. Are you 

aware of publish~accounts of retrofit situations wh~ sometyp~ofintert'erencehas occurred 

with electronic balla.sts? Are you awllteofany electronicl);:Illastswhich <10 nQtcaus.e this type of 

interference? Is it possible to design ;:In electronic ballast using appropriatefiiters or shields, for 

example, which will not cause this interference? Is there. a cost premium for a non-il;1terfering 

electronic ballast? Do cathode cutout ballasts cause this type of interference?' What do you do 

when a customer complains that an electronic . ballast interferes with one or more of its building 

electronic systems? Do you provide guidelines to your distributors regarding interference effects 

with electronic ballasts? What portion of the U.S. building stock is affected by these interference 

42 
EE-RM-97-500 COMMENT OF 

problems? 

Problems do arise. A possible solution would be to allow the installation of magnetic ballasts in 

areas where interference issues arise. This is less than 5% of the electronic market. 

PARI B: CONSUMER AND NATIONAl, ISSUES 

B.I Banast Prices: Current ballast pricing information was obtained from a 1993 survey 

conducted by the Lighting Research Institute. ACEEE believes the survey overstates the current 

price of electronic models. DOE intends to reduce electronic ballast prices used in the February 

1996 draft report by 15%. This is based on a comparative analysis of shipments and value data 

from Bureau of Census 1993 and 1995 reports. Additionally, DOE will perform price sensitivity 

studies at + 15% and -10% of the new price. Do you agree with DOE's approach? 

Ballast prices have definitely decreased in the 1993-1995 timeframe. Our experie,!ce has been 

to observe an 8% annual reduction in the price of electronic ballasts. Based on our larger 

experience in the area of consumer electronics production. we project that the price of electronic 

ballasts will follow a 70% learning curve - a 30% reduction in price for every doubling of the 

cumulative production volume. (Not to be confosed with a doubling of annual output). Example: 

if cumulative total by 1996 was 90 million and volumes were 30 million per year. in 2000 prices 

would be 30% lower than today" 

In summary Motorola agrees with the Department's use of Bureau ,of Census data. This data, 

may in fact underestimate the price reduction since ballasts shipped in 1995 had greater product 

features such as dimming capability. 

B.2 Energy Prices: The Energy Information Agency (EIA) energy price forecasts do not 

consider the possible impacts of utility restructuring. The Gas Research Institute (GR!) has a 

future price scenario showing 29% lower commercial electricity prices by 2015. DOE will use the 

most recent EIA electricity price forecast for the, year 2001 in the engineering and life-cycle cost 

analysis. 

For the purpose of calculating national benefits the Department will perform life-cycle-cost 

sensitivity analyses at -12.5% and -25% of the EIA forecast. In an additional sensitiVity analysis 

the Department will determine the rate of decrease in electricity price needed to reduce net 

present value of the reduced life-cycle-cost to zero. Do you agree with this approach? Do you 

have an~ suggestions for an alternative electricity price projection for the 30 year period? 

Motorola is unconvinced that energy priceswillfall appreciatively with deregulation. The 

Department should seek EEl projections and conduct multiple sensitivity analyses: 

B.3 New Market Shares: DOE will graph the annnal ballast installations according to three 

segments: new construction, conversions 'and replacements. Market share(electronic as a 

43 
EE-RM-97-500 COMMENT OF 

percent of total installations) as a function of time will also be displayed. The graphs will show 

the synergistic effects of conversions, replacements lIIld new construction to make the discussion 

easier to follow. The electrOl).ic share of total ballast sales is approximately the same for the first 

half of 1996 as it was in 1995. Do you believe these sh!l\'es should increase / decrease through 

2000? Ifso, by how much? 

Motorola believes electrotonic ballasts will continue to increase in total market share but the 

. ratt! of increase will be lower than experienced in recent years. 

B.4 Conversion Rates -. Retrofit: The current high efficiency. base case assumes a copstant 

conversion rate bf 5.5% after 2000. ACEEEclaimed that .a conversion rate based on the 

1992/1 993time period is unrealistic f()r future years. The low efficiency base case assuined no 

conversions after 1995. Workshop participantssuggested.thatsensitivity studies on conversion 

rates be performed. What conversion rates shouldbeconsidered? . 

The installed base o/ballasts is estimated to be '600, 000,000 linit~. A 5.5% conversion rate 

represents 33,000,000 ballasts.in the retrofit market alone. ThiS figute seems high. 

B.5 Future Ballast Sales Levels: Stakeholders disagree with the current forecast of total future 

ballastsales which is based on 1993. data. The ballast shipments for '93, '94l11li:! '95 are nearly flat· 

at SO million per year. What do you project the future billiast Shipmehts to be? 

Motorola's industry salesforecastfor 1996 is 70 million ballastS. Longer forecasts track growth 

figures for GNP (2.5'Yo to 3% range). . 

B.6lncorporating Voluntary Programs: ~e currentllll8lysis assumes that utilitY DSM 

programs will diminish after 1995. DOE will review some DSM,.FEMP, EPA, lIIldEPRI data to 

develop an upper bOund lIIld best estimate of the effects of voluntary programs. InfOJ:mation on 

. these or other voluntary programs would be appreciated. 

DSM programs are dropping off. At best thejuture holdsfewer programs ()jferings,;"aller 

subsidies. Lookat Green Lights. The ratio of squarefeetof space coil1!erti!d to number of 

partners, is drrjpping. There wil.l be more E8COactivity and continua(ion o/FEMPprograms. , ' , , 

B. 7 ·TraQ$i~ion Technology - Ce,thode Cuttiut: Why has thistecbhology captured only·l % 

market share? . . 

Question not asked or didn 'I apply 

.p ART C; BAl,LASTTNDUSTRY CHARACTERIZATION 

C.I What are the relevllllt characteristics that could be used to divide ballastmllllufacturers into 

meaningful subgroups forthe purpose of evaluating the impacts of standards? (i.e. firm size, pll11lt 

44 
EE·RM·97·500 COMMENT OF 

location, product mix, etc.) 

Ballast manufacturers are divided into three primary groupings; manufacturers of electronic 

ballasts only, manufacturers of magnetic ballasts only, and manufacturers of both technologies. 

I. Motorola, OSRAMISylvania (who brand offihore ballasts), Solium and Howard produce· 

only electronic ballasts. 

II. MagneTek, Advance and Valmont produce both. 

III. Robertson and other small manufacturers build primarily magnetic. 

Small manufacturers will have a different cost structure from their larger c01!lpetitors. Small 

manufacturers will tend to use more labor whereas larger manufacturers will be more automated 

and thus incur proportionately higher [lXed costs. 

Manufacturers of magnetic ballasts may have large capital investments that have already been 

folly depreciatedfor accounting purposes. For this reason magnetic ballast sales may be more 

profitable than electronic sales for companies that produce both. 

Some manufacturers have stated that magnetic ballast plants cannot be cost tiffectively 

retrofitted to manufacture electronic ballasts. Motorola believes that the plants can be 

converted given investment in the plant and employee retraining. 

C.2 How would you characterize your firm relative to the previous characteristics? 

Motorola is a large manufacturer of electronic ballasts. A distinguishing characteristic is the 

fact that all production is in the U.S. 

C.3 What changes have occurred in the ballast indusUy in recent years (such as the shift to 

electronic ballasts), and how have these changes impacted your company? 

The significant change has been the growing market share of electronic ballasts. Since 

Motorola has strong expertise in consumer electronics, it identified the electronic ballast as a 

natural addition to its product line. Motorola's started production in 1991 and is today one of 

the tdp three producers of electronic ballasts for the U.S. market. 

P~T D; MANUFACTURER COST IMPACTS 

For each of the efficiency levels described in Section 3.6 of the "Draft Report on Potentiallnipact 

of Possible Energy Efficiency Levels for Fluorescent Lamp Ballasts", February 1996. (Included 

below): 

D.I Are the manufacturing costs described in the LBNL engineering analysis - labor, 

materials/parts, shipping/packaging, and tooling/equipment - representative of your manufacturing 

costs? Please explain. 

45 
EE·RM·97·500COMMENT OF 

CONFIDEN11AL 

D.2 Is there a large variation in costs between different ballast manufacturers? If so, how large, 

and what elements might account for these variations? 

CONFIDENTIAL 

D.3 What would be the effect on the value of your current assets in such areas as plant, 

equipment, and tooling? 

A standard would not affict the value of current manufacturing assets since they are already 

used to produce both rapid and instant start el~ctronic ballasts . 

PART E; IMPACTS ON PRODUCT SALES AND PRICE 

For each ofthe efficiency levels described in Section 3.6: 

E.I Would the total number of ballasts sold by your finn increase or decrease from current 

forecl\8ts? Why? 

Assuming Motorola maintained an equal market share •. its total sales would increase in 

proportion to the total increase in electronic ballast sales. 1996 electronic ballasts sales are 

39% of the total 7'0 million ballasts sold. Motorola intentb to meet any increased U.S. demand 

with increased U.S. production. . 

E.2 Would the price on ballasts·increase. or decrease? Why? By how much? . 

Not certain howprices would be iinpacted in the short run,. bu.t increased production levels 

would decrease price in the long run due to previously describe,d/earning effect. . 

E.3 Would the gross profit margin on ballasts increase or decrease? Why? By how much? 

Not certain. 

E.4 Are you aware of other factors that could influence tile price and qUantity variables for your 

firm? (changes in distribution channels, changes in suppliers, etc.) 

No. 

PART F; OTHER ISSUES 

For each of the efficiency levels described in Section 3.6: 

46 
EE-RM-97-500 COMMENT OF 

F.l What might be the effect on current employment levels at yoUr domestic manufacturing 

plants? Please explain and quantifY ifpossible . 

. The plant currently has some overcapacity built-in but additional investments and labor would 

be needed to meet the demand resultingfrom an electronic ballast standard. Thesejobs would 

compensate that might be lost in the production. of magnetic ballasts. All manufacturing 

operations are in the US andfoture capacity would be US based. 80% of world's magnetic 

ballasts are manufactured in Mexico for consumption in US. Advance has moved a plant from 

Wisconsin to Mexico, Valmont has plants in Mexico despite HQ in El Paso TX Magnetic plants. 

would be folly depreciated 

F.2 What might be the effect on your company's return on investment and overall economic 

value? Please elaborate. . 

Question not asked or didn't apply. 

F.3 How might your competitive position in the industry be affected? 

Motorola will be there and be competitive. 

F.4 What other federal product regulations are likely to impact your firm in the near future? 

Motorola plant was designed as a vac ..free plant (water based systems) and uses fluxless 

soldering. 

47 
EE~RM-97-500 COMMENT OF 

Interview with The Natural Resour\=es Defense 

CouneD Regarding Fluorescent Lamp Ballasts 

February 6, 1997 

On Februmy 4, 1997 the Department of Energy (DOE) interviewed The Natural Resources 

Defense Council by phone, to discuss various engineering, consumer, national, and manufacturer 

issues relating to fluorescent lamp ballasts. The responses recorded are in italics below c.ach 

interview question. 

Attendees 

The Natura! ReSOllroes Defense Council 

David Goldstein 

DOE and Contractors 

Anthony Balducci - DOE 

PARI A: ENGINEERING ISSUES 

A.1 Ballast Life. At the ballast workshop, held on June 20, 1996, there wassome agreement 

that the ballast life currently used (33,000 hours) is too low, It was suggested that a life of 

50,000 hours be used instead. The Illuminating Engineering Society (lES) Lighting Handbook, 

8th edition, lists a life of 45,000 hours for magnetic ballasts. DOE is prepared to use this. value for 

~oth magn.etic and electronic ballasts and is planning to conduct sensitivity studies on JJilequal 

b.allast lifetimes formagnetic and electronic ballasts where one type wOllldbavea 33,000.hour life 

and the other ballast wOUld have a 45,00Q hour life. What.are your opinions on this approach? 

In general, iUs a good idea to use 45,000 hour life for botbtypes of ballasts. DOEshould 

examine where IES got .the lifefigures: the 50,000 hours that seemed acceptable to .everyone at . 

the workshop may be better. if the IESnumber is notbased.pn.,anything~ A 13,000 hour lifefor 

electronic ballasts appears too low, Each manufacturer has.a different Circuitry, but would not, 

survive in the market if the life were only 11,000 hOlU's.4, sensitivjtyanalysis using a 33,000 

hour lifedoesn't make sense, it is too/r)w. DOE should balance the life oftheb"llast with a 

, stock and flow model and be able to duplicate realistic walts per square f~ot and kWhlyear 

values for fluorescent lighting. . 

A.2 Lamp Life Reduction with the Cathode~utoutBall~st. OOE hasr,eceivedseveral 

comments to tile effect that cathode cutout ballasts reduce 181rip life by 10-25%. There seems to 

be some agreementin the comments that a lamp life reduction of 15% is about average. There is 

also a June 1995 paper by Advance that supports a lamp life reduction of 16% for T12 ballasts 

and 8% for T8 ballasts. DOE is considering the values reported by "Advance. Do you have any 

. information to support these or that would guide DOE to use some other values? 

48 , 
EE·RM·97·500 COMMENT OF 

We have no problem with what is being done. 

A.3 Incompatibility of Electronic Ballasts and 34watt lamps. Is there an Incompatibility of 

Electronic Ballasts and 34 watt lamps? . Do you manufacture electronic ballasts for use with 34 

watt lamps. Are there price premiums for these ballasts? If so, can you provide pricing sheets? It 

appears that starting problems have a technical solution; therefore starting problems. should not be 

used to rule out all electronic ballasts. Is this an accurate assessment? 

We have not heard of any problem. 1/ a problem does exist, it is not an issue if DOE goes 

forward with a standard, the 34 watt lamp has a limited life. By the time the new ballast 

standard would be effective, existing 34 watt lamps would be gone from the buildings before 

ballasts needed replacement. 

A.4 Electronic Ballasts May Cause Interference with Building Electronic Systems. Are you 

aware of published accounts of retrofit situations where some type of interference has occurred 

with electronic ballasts? Are you aware of any electronic ballasts which do not cause this type of 

interference? Is it possible to design an electronic ballast using appropriate filters or shields, for 

example, which will not cause this interference? Is there a cost premium for a non.interfering 

electronic ballast? Do cathode cutout ballasts cause this type of interference? What do you do 

. when a customer complains that an electronic ballast interferes with one or more of its building 

electronic systems? Do you provide guidelines to your distributors regarding interference effects 

with electronic ballasts? What portion of the U.S. building stock is affected by these interference 

problems? . 

Not aware of any published accounts, but have experienced a problem. The problem occurred 

with electronic ballasts and cheap lighting controls. The lighting controls went from bad to non· 

fUnctioning. The problem was easily fixed. In Cali/ornia, electronic ballasts represent 90% of 

the ballast market. There have only been a few problems and they are fixable. The market 

solves the problems. Overall, the problem of incompatibility is always solvable, not very 

prevalent, and needs to be addressed sooner or later. My guess is that the building stock 

affected would be approximately J%. 

PARI B: CONSUMER AND NATIONAL ISSUES 

B.l Ballast Prices: Current ballast pricing iuformation was obtained from Ii 1993 survey 

conducted by the Lighting Research Institute. ACEEE believes the survey overstates the current 

price of electronic models .. DOE intends to reduce electronic ballast prices used in the February 

1996 draft report by 15%. This is based on a comparative analysis of shipments and value data 

from Bureau of Census 1993 and 1995 reports. Additionally, DOE will perform price sensitivity 

studies at +15% and ·10% of the new price. Do you agree with DOE's approach? 

The price of electronic ballasts is coming down consistent with a learning curve. The price 

should be extrapolated to the qrective date of the standard. Another source for ballast pn'ces is 

49 
EE-RM-97-500 COMMENT OF 

the "Utility Measurement and Evaluation Studies" coordinated by San Diego Gas and Electric . 

. Other utility data should be sought by DOE. 

B.2 Energy Prices: The Energy Information Agency (EIA) energy price forecasts do not 

consider the possible impacts of utility restructuring. The Gas Research Institute (GRI) has a 

future price scenario showing 29% lower commercial electricity pJjces by 2015. DOE will uSe the 

most recent EIA electricity price forecast for the year 200 lin the engineering and life-cycle cost 

analysis .. 

For the purpose of calculating national benefits the Department will perform life-cycle-qost 

sensitivity analyses at -12.5% and -25% of the EIA forecast. In an additiopalsensitivityanalysis 

the Department wi!! deter:QJine t11e rate of decrease in electricity price needed· to reduce net 

present value of the reduced life-cycle-cost to zero. Do .:Y6u agree with this approach? Do you 

have any suggestions for an alternative electricity price projection for the 30 yearperiod? 

You, DOE, have to use the EIAjorecast. For symmetry, theprice should beincr~ased. There 

will bea period in .the foture wh(f1'e electricity priCes will go up. The idea that there will be no 

global carbon tax in the.next 30 years appears implausible. Data on deregulatipn ofthe;electric 

industry in other countries doesn't show competition drivingprices down. Electricity price 

extremes will converge tp a mean value with competition . 

. B.3New Market Shares:· DOE will graph the annnal ballast installatiOns w;cording to three 

segments: new construction, conversions and replacements ... Market share (electronic as a 

percentoftotal installations) as a function of time will also be displayed .. The graphs will show 

the syn~istic effects of coil versions, replacements and \lew construcnon to make the discus.sion 

easier to follow. The electronic share oftota:l ballast sales is approXimately the same for the first 

half of 1996 as it was in 1995. Do you believe these sh\lres should increase I decrease through 

20001 Ifso,byhowmuch? . " .,'.' - . 

We don '(believe tha/one can accurately preilictthe marketshares. Suggest that y(J~ calau/ate 

the mean and standard deviation of the stakeholders opiniOns and.use thqt in the analysis. The 

deviation could be large but unpr~dictable. Projections maylwi/l be wrong,jobs.willbe lost and 

assets will be stranded. If you invest in new capq.city, yOumajistilllose;!f)ioudon 'timiest, you 

may lose, . We cannot ac~rqtely predict consUmer behaviOr. . 

B.4Conv~rsion Rates - Retrl)fit: The cUrrent high efficiency base cIlse IIssmrtes a constant 

conversion rate of5.5% after 2000. ACEEEclairited that acoilversion rateb~sedon the 

1992/1993 fune period isunrllalistic for future years. The low efficiency base case assUIiled no 

conversions· after 1995. .w orkshopparticipantssuggested . that sensitivity studies Oil conversion 

rates be performed. What conversion rates should be considered? . 

This is hard to predict. As apracticatmatter, 0% to 7% could represent the bpundsfor 

retrofits; but in theory, 0% should not be the lower bound. The/ower bound should be a 

50. 
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EE-RM-97-500 COMMENT OF 

negative number because, 'in some instances, electronic ballasts may be converted to magnetic 

ballasts. 

B.5 Future Ballast Sales Levels: Stakeholders disagree with the current forecast of total future 

ballast sales which is based on 1993 data. The ballast shipments for '93, '94 and '95 are nearly flat 

at 80 million per year. What do you proj ect the future ballast shipments to be? 

Total ballast shipments beingflat does not adversely affect the base case. Cannot see any 

reason Jar a significant change in the total number oJballasts sold. Should look at the stock and 

flaw model again. 

B.6 Incorporating Voluntary Programs: The current analysis assumes that utility DSM 

programs will diminish after 1995. DOE will review some DSM, FEMP, EPA, and EPR! data to 

develop an upper bound and best estimate of the effects of voluntary programs. Information on 

these or other voluntary programs would be appreciated. 

Premature to declare that DSM programs are dead. Although difficult to predict, DSM 

programs may still make a comeback. 

B.7 Transition Technology - Cathode Cutout: Why has this technology captured only 1% 

market share? 

The cathode cutout ballast doesn't offer the same quality oJlighting as an electronic ballast. 

Electronic ballasts areflicker free and have a better light color. While there maybe an 

economic value to better lighting, it is mostly a quality improvement issue. 

PART C; BALLAST INDUSTRY CHARACTERIZATION 

C.I What are the relevant characteristics that could be used to divide ballast manufacturers into 

meaningful subgroups for the purpose of evaluating the impacts of standards? (i.e. ~ size, plant 

location, product mix, etc.) 

1. Product Mix - what extent does the company make both types oJbaliasts. 

2. Don't know ifsize matters - is there a minimum typicalsizeJor the global market. 

3. Look at the 1988 standard in retrospect to check size. 

C.2 How would you characterize your firm relative to the previous characteristics? 

Question not asked or didn't apply. 

C.3 What changes have occurred in the ballast industry in recent years (such as the shift to 

electronic ballasts), and how have these changes impacted your company? 

• 

51 
EE-RM-97-500 COMMENT OF 

The shift during a 2-3 year period in the market to electronic ballasts. That change was more 

disruptive than the standards because it may not have been predicated. 

PART D: MANUFACTURER COST IMPACTS 

For each of the efficiency levels described in Section 3.6 of the "DrafiReport oil Potential Impact 

of Possible Energy Efficiency Levels for Fluorescent Lamp Ballasts", February 1996. (Included 

below): 

D.l Are the manufacturing costs described in the LBNL engineering analysis - labor, .' 

materials/parts, Shipping/packaging, and tooling/equipment - representative of your manufacturing 

costs? Please explain. " '. . 

Do not have any insight into the costs . .suggest that stranded costs shiJuld be amortized in the 

same way as the capital costs. 

D.2 Is there a large variation in costs between different ballast manufacturers? If so, how large, 

and what elements might account for- these variations? 

Question not asked or didn ;t apply. 

. . D.3 What would be the effect on the value of your current assets in such areas as plant, 

equipment, and tooling? 

Question not.asked ordidn 't apply. 

PARI EI IMPACTS ON .PRODUCT SALES AND PRICE 

For each bfthe effiCiency levels described in Section 3.6: . 

E.1 Would the total number of ballasts sold by your firm incr!)ase or decrease from current 

forecasts? Why? . . . 

Question not asked or didn't apply. 

E.2 Would the price on ballasts increase or decrease? Why? By how much? 

For an electronic ballast standard, logically the price would ap'pearto decrease because of 

faster prow:eS$ along the learning curve. Manl,lfocturers.would nqthave the excess capacity 

problem c-or a shortage problem-c that they would have in an unpredictable market: Currently, 

electronic ballasts have a higher markup because they are considered a premium product . . If the . 

electronic ballast were the standard,. it would become a commodity item. A caihode.cutout 

ballast standard probably would not be very different from an electronic ballast standard. The 

52 
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EE-RM-97-500 COMMENT OF 

cathode cutout ballast would still represent a small percentage ojthemarket. 

E.3 Would the gross profit margin on ballasts increase or decrease? Why? By how much? 

Question not asked or didn't apply. 

E.4 Me you aware of other factors that could influence the price and quantity variables for your 

fum ? (changes in distribution channels, changes in suppliers, etc.) 

There is always the possibility of a breakthrough in the production of electronic ballasfs, with or 

without a standard. Either gradually or dbruptly, electronic ballasts may become less expensive 

than magnetic ballasts. If that happened, a standard, would be essential to preserve jobs in the 

United States. An electronic ballast standard would force investment in newer technologies for 

manufacturing ballasts. 

PART F: OTHER ISSUES 

For each of the efficiency If;vels described in Section 3.6: 

F.l What might be the effect on current employment levels at your domestic manufacturing 

plants? Please explain and quantifY if possible. 

The decision would rest with individual companies on where to invest. Ifplaced under a time 

deadline to get electronic ballast manufacturingon line, companies are more likely to build 

outside the U.S. If a standard were enacted, it would establish a certainty regarding when the 

market would completely change over and manufacturers would have more time to plan and 

invest in the U.S. 

F.2 What might be the effect on your company's return on investment and overall economic 

value? Please elaborate. 

Question not asked or didn't apply. 

F.3 How might your competitive position in the industry be affected? 

Getting U.s. firms to produce higher technologies is to their foture benefit. 

F.4 What other federal product regulations are likely to impact your fum in the near future? 

Question not asked or didn't apply. 

53 
EE-RM-97-500 COMMENT OF 

January 2, 1997 

Interview with YaImont Electric. 

Regarding Fluorescent Llinlll Ballasts 

On December 17, 1996 the Department of Energy (DOE) and its contractors interviewed 

Valmont Electric having a place of business at 1770 Commerce Park Drive, El Paso, Texas 

79912, to discuss various engineering, consumer, national, and manufacturer issues relating to 

fluorescent lamp ballasts. The interview was conducted at Valmont's offices in El Paso"Texas. 

Thl; responses recorded are in italics below each interview question. 

Attendees. 

Valmont Electric 

Jerry Prideaux - Manager, Product DeveloPlIlent 

Howard Sachs - President and C.O.D. 

Paul Royalty - Vice President, Marketing and Sales 

W. T. (Bill) Busch - Director, Product Planning & Technical Services 

DoE and Contractors 

Anthony Balducci - DOE 

Barbara Twigg - DOE 

Steve Mariano - Arthur D. Little 

PARt Ai ENGINEERING ISSUES 

A.l Ballast Life. At the ballast workshop, held on June 20, 1996, there was sonie agreement 

that the \la11ast life currently used (33,000 hours) is.too low .. It was suggested thata life of . 

50,000 hours be used instead. TheUiuminatingEngineerilig Society (JES) Lighting Handbook, 

8th edition, lists a life of 45,000 hours for magnetic ballast. DOE is prepared to tisethis vallie for 

both magnetic and electronic biitlaSts and is planning to conduct sensitivity studies on unequal 

ballast lifetimes for magnetic aild~lectronic bl\llasts where. one type wotild have II 33,000 hOur life 

and the other ballast would have.a 45,000 hour lifil: What are your opinions on this approach? . " , , . 

CONFIDENI1AL 

54 
EE-RM-97-500 COMMENT OF 

A.2 Lamp Life Reduction with the Cathode Cutout Ballast. DOE has received several 

comments to the effect that cathode cutout ballasts redUce lamp life by 10-25%. There seems to 

be some agreement in the comments that a lamp life reduction of 15% is about average. There is 

also a June 1995 paper by Advance that supports a lamp life reduction of16% for T12 ballasts 

arid 8% for T8 ballasts. DOE is considering the values reported by Advance. Do you have any 

infonnation to support these or that would guide DOE to use some other values? 

Lamp life should come directly from lamp manufacturers. not Valmont (or any ballast 

manufacturer). Ballast manufacturers build and operate ballasts within specified parameters set 

by lamp manufacturers. The cathode cutout ballast was introduced by GE in 1982. Lamp life is 

dependent on the application. The cathode cutout ballast treats the lamp as a preheat which 

published data claims a 25% reduction in lamp life for T12. 

A.3 Incompatibility of Electronic Ballasts and 34 watt lamps. Is there an Incompatibility of , 

Electronic Ballasts and 34 watt lamps? Do you manufacture electronic ballasts for use with 34 

watt lamps. Are there price premiums for these ballasts? If so, can you provide pricing sheets? It 

appears that starting problems have a technical solution; therefore starting problems should not be 

used to rule out all electronic ballasts. Is this an accurate assessment? 

Yes. there is an incompatibility with the 34 watt TI2 and electronic ballasts. For a magnetic 

. ballast the lamp requires a tin coating (the more the better) for starting a 34 watt lamp. For an 

electronic ballast the 'less tin coating the better for starting. One major issue is the lamp 

manufacturers process control for applying the tin coating. If the tin coating is above or below 

a certain window. one or the other (magnetic or electronic) will have trouble sta.rting. Valmont 

electrOnic and magnetic will start and operate both 34 and 40 watt lamps; Problems do exist 

(i.e. lamp may not operate) but there are not many cases of (!lectronic ballasts with Ti2 - $4 watt 

lamps. Consumers usually use electronic ballasts and T8 - 32 watt lamps. (Insignificant issue). 

In the '82- '83 time frame, GE introduced a 34 watt lamp to be used with electronic ballasts (no 

coating), competition didn'tfollow. GE discontinued the lamp due to few people using TI2 

lamps with electronic ballasts. The 34 watt incompatibility isa major issue in the residential 

"Do it Yourself" market, 

A.4 Electronic BaUasts May Cause Interference with Building Electronic Systems. Are you 

aware of published accounts of retrofit situations where some type of interference has occurred 

with electronic ballasts? Are you aware of any electronic ballasts which do not cause this type of 

interference? Is it possible to design an electronic ballast using appropriate filters or shields, for 

example, which will not cause this interference? Is there a cost premium for a non-interfering 

dectronic ballast? Do cathode cutout ballasts cause this type of interference? What do you do 

when a customer complains that an electronic ballast interferes with one or more ofits building 

electronic systems? Do you provide guidelines to your distributors regarding interference effects 

with electronic ballasts? What portion of the U.S. building stock is affected by these interference 

problems? 

55 
EE-RM-97-500 COMMENT OF 

We are aware of numerous cases of interference causing problems. Valmont has· "many" 

engineers fUll time providing support to OEM's, ins.tallers etc. Interference with infrared 

devices (TV. VCR remote controls) bar code readers, magnetic field interrupters, energy 

management systems, simplex clocks, and medical equipment in hospitals are frequent topics. 

Although all systems meet FCC standards, this may not be enough to prevent all interference. 

Magnetic ballasts operate at 60 Hz, while electronic ballasts operate above 20,000 Hz; 

For retrofit applications you need to know what is in the building that is sensitive.toIR, Simplex 

clocks, etc;. There are cases where the inteiference is not acceptaQle at all. Forexample, the 

Pentagon used cathode cutout ballasts for the relighting, 

We can design around specific problems, but the~e is no one ballast that solves all the problems. 

We estimate that 20% of electronics could have 0; problem, but typically don't because the 

installer anticipates potential problems and recoTilmJ!'3ds solutions (i.e. magnetic ballast) prior 

to specifYirig ballast type. We can't determine how many people avoid electronic ballasts 

because of inteiference issue. 

PART B: CONSIJMER ANDNATIONM, ISSUES 

B.l BaDast Prices: Cwrent ballast pricing info~ation was obtained from a 1993 survey 

conducteci by the Lighting Research Institute. ACEEE believes the survey overstates the current 

price of electronic mociCls. DOE intends to.reduce electronic ballast prices useq in the February 

1996 draft rCJX?rt by .IS%.This is based on an a comparative analysis of shipments and value data 

from Bureau of Census (BoC) 1993 and.1995 reports. Additionally, DOE will perform price 

sensitivity studies at + 15% and -10% of the new price. po you agree with DOE's approach? 

We;y~ggest that DOE not change the bal/astprices ill the anqlysis .. Wesuggestusing the prices 

from theLRI slIIdy. The DoC numbersrlfflectthe prict;S to OEM's; what the ballast 

manufacturer sells them for. Census data is not statisticallyac;curate ·(ValmontreportS acCUrate 

numbers but others may not) Census data dqes not reflect whatthe enduserispayingfor t1!e 

ballast. We suggest using the 199J numbers from the L!1l study. 

B.2 Energy Prices: The Energy Information Agency (EIA) energy price for.ecastsdo not 

consider the possible in)pacts of utility restruct\lling; . The Gas ReSearch Instit\lte (GR!) bas a 

future price scenario showing 29% lower cOm.tnercial~lectricity prices by 2015 •• DOE: will use the 

most recent EIAelectricity price forecast for the year 20(11 in.the engineering and life-cycle cost 

analysis. . . .. 

Forthe PUlllose of calcUlating national benefits the Dep~ent wiUperform life-cycle-cost 

sensitivity analyses at -12.5% and ·25% of the EIA foreCast In an additional sensitivity analysis 

the Department will determine. the rate of decrel.lse in electricity price needed to reduce net 

present value of the r~uced life-cycle-cost to zen;). Do you agree with this approach? Do you 

have any suggestions for an alternative electricity price projection for the 30 year period? 

DOe needs to talk to the National AssoCiation of Energy Service Companies (NAESCO). They, 

56 
EE-RM-97-50DCOMMENT OF 

NAESCO, do not believe that the deregulation of the electric industry will have significant 

impact on the price of electricity. Contact person is Terry Singer (202) 371-7812. We, Valmont, 

agree with the sensitivity'analysis. We sell our ballasts on how much people can save, not what 

it costs them. 

B.3 New Market Shares: DOE will graph the annual ballast installations according to three 

segments: new construction, conversions and replacements. Mad:et share (electronic as a 

percent of total installations) as a function of time will also be displayed. The graphs will show 

the synergistic effects of conversions, replaCements and new construction to make the discussion 

, easier to follow. The electronic share of total ballast sales is approximately the same for the first 

half of 1996 as it was in 1995. Do you believe these shares should increase 1 decrease through 

2000? If so, by how much? " 

CONFIDENTIAL 

B.4 Conversion Rates - Retrofit: The cUITent high efficiency base case assumes a constant 

conversion rate qf 5.5% after 2000. ACEEE claimed that a conversion rate based on the 

1992/1993 time period is unrealistic for future years. The low efficiency base case assumed no 

conversions after 1995. Workshop participants suggested that sensitivity studies on conversion 

rates be performed. What conversion rates should be considered? 

CONFIDENTIAL 

B.5 Future Ballast Sales Levels: Stakeholders disagree with the CUITent forecast of total future 

ballast sales which is based on 1993 data. The ballast shipments for '93, '94 and '95 are nearly flat 

at 80 million per year. What do you project the future ballast shipments to be? 

CONFIDENTIAL 

B.6 Incorporating Voluntary Programs: The cUITent analysis assumes that utility DSM. 

programs will diminish after 1995. DOE will review some DSM, FEMP, EPA, and EPRI data to 

develop an upper bound and best estimate of the effects of voluntary programs. Information on 

these or other voluntary programs would be appreciated. 

CONFIDENTIAL 

B.7 Transition Technology - Cathode 'Cutout: Why has this technology captured only 1% 

market share? 

57 
EE·RM·97 ·500 COMMENT OF 

CONFIDENTIAL 

PART C: BALLAST INDUSTRY CHARACTERIZATION 

C.I What axe the relevant chaxacteristics that could be used to divide ballast manufacturers into 

meaningful subgroups for the purpose of evaluating the impacts of standards? (i.e. finn size, plant 

location,product mix, etc.) 

CONFIDENTIAL 

C.2 How would you chaxacterize your finn relative to the previous characteristics? 

CONFIDENTIAL 

C.3 What changes have occurred in the .. ballast industry in recent yeaxs (such as the shift to 

electronic ballasts), and how liave these changes impacted your company? 

CONFIDENTIAL 

PART D: MANUFACTURER COST IMPACTS 

For each of the efficiency levels described in Section 3.6 of the "Draft Report on Potential Impact 

of Possible Energy Efficiency Levels for Fluorescent Lamp· Ballasts", Febhiary 1996. (Included 

below): . 

0.1 Are the manufacturing costs described i)l. the LBNL engineering analysis· labor, 

materials/paIts, shipping/p(ICkaging, and tooling/equipment· representative of your manufacturing 

costs? Please explain. 

CONFIDENTIAL 

0.2 Is there a 18Igevariation in costs between different ballast manm(ICturers? If so,~ow laxge, 

and what elements might account for these variations? . 

CONFIDENTIAL 

0;3 What would be the effect on the value of your current assets in'such axeas as plant, . 

equipment, and tooling? 

CONFIDENTIAL 

58 
EE·RM·97·500 COMMENT OF 

PART E: IMPACTS ON PRODUCT SAJ,ES AND PRICE 

For each of the efficiency levels described in Section 3.6: 

E.l Would the total number of ballasts sold by your firm increase or decrease from current 

forecasts? Why? 

CONFIDENTIAL 

E.2 Would theprice.on ballasts increase or decrease? Why? By how much? 

CONFIDENTIAL 

E.3 Would the gross profit margin on ballasts increase or decrease? Why? By how much? 

CONFIDENTIAL 

E.4 Are you aware of other factors that could influence the price and quantity variables for your 

firm? (changes in distribution channels, changes in suppliers, etc.) 

CONFIDENTIAL 

PARI F: OTHER ISSUES 

For each of the efficiency levels described in Section 3.6: 

F.I What might be the effect on current employment lev~ls at your domestic manufacturirig 

plants? Please explain and quantify if possible. . 

CONFIDENTIAL 

F.2 What might be the effect on your company's return on investment and overall economic 

value? Please elaborate. 

CONFIDENTIAL 

F.3 How might your competitive position in the industry be affected? 

CONFIDENTIAL 

F.4 What other federal product regulations are likely to impact your firm in the near future? 

CONFIDENTIAL 

59