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APPENDIX 12A. MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDE

Metal Halide Lamp Fixtures Rulemaking

Manufacturer Impact Analysis Interview Guide

September 29, 2010
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PART 1. MARKET, TECHNOLOGY, AND ENGINEERING ANALYSIS

A. Market Data

This section addresses market information of metal halide lamp ballasts that are included in 

fixtures. The Energy Independence and Security Act of 2007 1

(EISA 2007) set standards for 

metal halide lamp fixtures designed to be operated with lamps rated greater than or equal to 150 

watts (W) but less than or equal to 500W. For this metal halide lamp wattage range, metal halide 

lamp fixtures must contain:

(i) a pulse-start metal halide ballast with a minimum ballast efficiency of 88 percent;

(ii) a magnetic probe-start ballast with a minimum ballast efficiency of 94 percent; or

(iii) a nonpulse-start electronic ballast with—

(I) a minimum ballast efficiency of 92 percent for wattages greater than 250 

watts; and

(II) a minimum ballast efficiency of 90 percent for wattages less than or equal to 

250 watts.

(U.S.C 6292 (hh)(1)(A)) 

As discussed in the Framework Document, DOE is considering expanding the scope of energy 

conservation standards to include fixtures explicitly exempt from standards, which includes:

(i) fixtures with regulated lag ballasts;

(ii) fixtures that use electronic ballasts that operate at 480 volts; or

(iii) fixtures that—

(I) are rated only for 150 watt lamps;

(II) are rated for use in wet locations, as specified by the National Electrical Code 

2002, section 410.4(A); and

(III) contain a ballast that is rated to operate at ambient air temperatures above 50° 

C, as specified by UL [Underwriters Laboratories] 1029–2001 [“Standard for 

High-Intensity-Discharge Lamp Ballasts”].

(42 U.S.C 6292 (hh)(1)(B))

DOE is also considering expanding the scope of energy conservation standards ton include 

fixtures with ballasts rated for 50 watts (W) and above. The following are market related issues 

that DOE would like further clarification from individual manufacturers.

A.1 DOE welcomes input on estimates of market shares of the following ballasts sold in new 

fixtures, and how that market share may change in the future:

 

1 U.S.C 6292 (hh)(1)(A))
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• Ballasts of the following wattage and voltage groupings: 

Rated Lamp Wattage Input 

Voltage

Estimated 

Percent of Your 

Company’s Total 

Shipments

Estimated Percent 

of the Entire 

Fixtures Market

≥ 50W and < 150W

≤ 300V

>300V

≥ 150W and ≤ 250W

≤ 300V

>300V

> 250W and ≤ 500W

≤ 300V

>300V

> 500W

≤ 300V

>300V

• Ballast included in exempted fixtures:

Ballast Type

Estimated 

Percent of Your 

Company’s Total 

Shipments

Estimated Percent 

of the Entire 

Fixtures Market

Regulated Lag

Electronic operating 

at 480V

150W, rated for wet 

location, and operate 

at ambient air 

temperatures above 

50° C 
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A.2 Are there specific reasons why DOE should or should not cover metal halide fixtures 

from the proposed wattage range (including 50W and above)? Should DOE consider 

covering any additional wattages?

A.3 Are there specific reasons why DOE should or should not cover metal halide fixtures 

exempted by EISA 2007?

A.4 Is it technologically feasible to improve the efficiency of ballasts included in covered 

fixtures listed above?

A.5 For each wattage grouping listed in A.1 what percentage of fixtures are sold of the 

following circuit types and topologies:
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Rated 

Lamp 

Wattage

Input 

Voltage CWA HXHPF

Linear 

Reacto

r

Magneticall

y Regulated 

Lag

Low 

Frequen

cy 

Electroni

c

(up to 

400Hz)

High 

Frequen

cy 

Electroni

c

(above 

400Hz)

≥ 50W and 

< 150W

≤ 300V

>300V

≥ 150W 

and ≤ 

250W

≤ 300V

>300V

> 250W 

and ≤ 

500W

≤ 300V

>300V

> 500W

≤ 300V

>300V

A.6 How do expect the above market shares to change absent standards?

A.7 DOE welcomes input on manufacturers of covered equipment. If possible, please list 

some of your company’s key competitors. 

DOE is considering analyzing both electronic and magnetic ballasts of different circuit 
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topologies at wattage levels of 70, 250, 400, and 1000.

A.8 DOE seeks comment on whether these are the most appropriate metal halide lamp 

ballasts included in covered fixtures to study in detail.

A.9 For the ballasts identified, DOE seeks comment on the most common ballast sold in each 

of the ballast categories. Please describe ballast attributes (e.g., voltage, 

electronic/magnetic, starting method (probe-start versus pulse-start), circuit type, input 

power, THD, power factor).

DOE is considering analyzing the following fixture types as representative of units commonly 

combined with the analyzed ballasts to form luminaires:

• High- and Low-Bay

• Wall Pack

• Down/spotlight

• Canopy

• Parking/Area Light

A.10 DOE seeks comment on whether these are the most appropriate fixtures to study in detail 

and whether they cover the majority of fixture applications in the metal halide fixtures 

market. Are there additional fixtures which DOE should consider? 
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In order to calculate the aggregate national energy savings, DOE requires data on shipment 

trends. 

A.11 What are general trends you see in the market? Absent amended energy conservation 

standards, do you foresee other technologies (e.g., high pressure sodium (HPS), 

fluorescent, or light emitting diodes (LEDs)) increasing in market share over the next 

thirty-five years? If so, how?

A.12 Would you estimate what proportion of fixtures shipped are sold in the renovation 

market, the replacement market, the early retrofit market, and the new construction 

market?

A.13 For fixtures, what proportion shipped are of each application type (high-bay, low-bay, 

wall pack, downlight/spotlight, canopy, and parking/area light? Are these proportions 

expected to change over time? If so, how?

A.14 For each fixture application type, what lamp wattages are most common? If possible 

please provide an approximation of proportions of units shipped by wattage.
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B. Engineering Analysis

DOE would like to understand the incremental costs of reducing fixture energy consumption by 

understanding the design options involved in efficiency improvements of the ballasts included in 

fixtures. Please describe the discrete design steps you would undertake to achieve the ballasts in 

the tables below. In each case, start with a standard efficiency ballast, and list the necessary 

design changes2 to enable it to become more efficient. For each design change, please also 

provide an estimate of your incremental production cost over the baseline, as well as the total 

unit selling price to an OEM or distributor. If additional rows are needed to describe all the 

design changes you would make, please feel free to modify the tables. 

The column labeled “Incr. Cost (over Std. Ballast) per Imp.” represents the cost of the specific 

improvement described. The column labeled “Total Mfr. Unit Selling Price to OEM Fixture 

Mfr” is your final selling price to your OEM fixture manufacturer.

We recognize that detailed designs may be difficult to prepare; therefore, in the interests of 

generating reasonable results in a short space of time, we invite you to use your best judgment 

and experience when completing the following tables. For magnetic ballasts, please specify the 

circuit type (e.g., CWA, HPF, linear reactor).

 

2 Design changes could include using capacitors with low effective series resistance, diodes with low forward 

voltage drop or low conduction losses, low loss magnetic materials, or low loss DC to AC circuit topologies. 
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Table 1 Engineering Analysis for Magnetic Probe-Start Ballasts

# Ballast Type Input 

Power

Ballast 

Efficiency

Defining Design 

Characteristics

Incr. Cost 

(over Std. 

Ballast) per 

Imp.

Total Mfr.

Unit Selling 

Price to 

OEM 

Fixture Mfr.

0

Standard 

Magnetic Probe-Start 

Ballast

1

High Efficiency

Magnetic Probe-Start 

Ballast

2

Maximum 

Technologically Feasible 

Magnetic Probe-Start 

Ballast
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Table 2 Engineering Analysis for Magnetic, Pulse-Start Ballasts

# Ballast Type Input Power Ballast 

Efficiency

Defining Design 

Characteristics

Incr. Cost 

(over Std. 

Ballast) per 

Imp.

Total Mfr.

Unit Selling 

Price to OEM 

Fixture Mfr.

0

Standard 

Magnetic PulseSart Ballast

1

High Efficiency

Magnetic PulseSart Ballast

2

Maximum 

Technologically 

Feasible, 

Magnetic PulseSart Ballast

D.1 For magnetic probe- and pulse-start ballasts, what are the defining design characteristics 

and the total manufacturing selling price? Can the efficiency for these commercially 

available ballasts be improved? If so, what improvements can be made and how would 

this impact the power consumed, the cost to manufacture the ballast, and the selling 

price?
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D.2 How would the answers given in and Table 2 change across wattages and circuit types?

Table 3 Engineering Analysis for Electronic Ballasts

# Ballast Type Input 

Power

Ballast 

Efficiency

Defining Design 

Characteristics

Incr. Cost 

(over Std. 

Ballast) per 

Imp.

Total Mfr.

Unit Selling 

Price to OEM 

Fixture Mfr.

0

Standard, 

Electronic 

Ballast

1

High Efficiency,

Electronic 

Ballast

2

Maximum 

Electronic 

Ballast
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D.3 For electronic ballasts, what are the defining design characteristics and the total 

manufacturing selling price? Can the efficiency for these commercially available ballasts 

be improved? If so, what improvements can be made and how would this impact the 

power consumed, the cost to manufacture the ballast, and the selling price?

D.4 How would the answers given in Table 3 change across wattages and operating 

frequencies (high versus low frequencies)?

D.5 If there are additional ballast technologies you feel DOE should investigate, what are 

defining design characteristics and total manufacturer selling price? Can the efficiency of 

these ballasts be improved? If so, what improvements can be made and how would this 

impact the power consumed, the cost to manufacture the ballast, and the manufacturer 

selling price?

D.6 How do you apply markups to your production costs in order to arrive at an OEM and 

distributor selling price?
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D.7 DOE typically calculates manufacturer selling prices by applying a multiplier to the 

manufacturer production cost to account for corporate non-production costs and profit. 

Using publically available information, it is estimated that the manufacturer markup for 

metal halide ballasts is approximately 1.50. Could you please comment on this figure? Is 

it representative of the industry in general?

D.8 Considering fixtures with the least options installed and not including the ballasts, could 

you provide estimates on the manufacturer selling prices for the following types?

High-Bay

Low-Bay

Wall Pack

Down/spotlight

Canopy

 Parking/Area Light

D.9 What are typical manufacturer markups for metal halide fixtures? Does the markups vary 

by fixture type?
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C. Distribution Channels, Lifetime and Operating Hours

DOE will need to develop a distribution chain model to understand how ballasts and fixtures 

migrate through the market from manufacturer to end-user. DOE is interested in understanding 

both the proportion (volume) of products that move through certain channels and the mark-ups 

applied. The following displays the distribution chain provided presented in the metal halide 

lamp fixtures rulemaking framework document. 

Ballast Manufacturer  Original Equipment Manufacturer (OEM) or Fixture 

ManufacturerElectrical Wholesaler (Distributor)  Contractor  End-User of 

Lighting System

C.1 Is the distribution chain displayed above an accurate representation of how ballasts reach 

the end user? What are the typical mark-ups applied by organizations or individuals in 

those channels (e.g., mark up applied by the OEM Fixture Manufacturer to the 

Distributor)? Do your answers vary by type of fixture sold (e.g., high-bay versus a 

wallpack)? If so, how? 

C.2 DOE is investigating metal halide lamp fixtures operating in different sectors. For the 

wattage range under consideration in this rulemaking, can you provide an estimate of the 

proportion of metal halide lamp fixtures sold into the commercial, industrial, and 

residential sectors? Can you provide a breakdown of magnetic versus electronic ballasts 

contained in covered fixtures for each sector as well?

C.3 What is the average fixture lifetime in each sector? In general, why are fixtures replaced 

(e.g., fixture “failure”, renovation, or ballast failure)?

D. Engineering Issues

DOE would like to understand specific issues arrived from the framework document public 
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meeting as well as from its own research.

D.1 Dimming in Ballasts

a. How is it accomplished? Is there an efficiency penalty at full-load?

b. Is extra circuitry needed? If so, is the added cost significant?

c. How does dimming affect arc stability?

D.2 Multiple Input Voltage

a. How does efficiency vary across input voltages?

b. Is a single-voltage ballast more efficient than the most efficient voltage of a 

multi-voltage ballast?

D.3 Electronic Ballasts

a. How do cost and efficiency vary between high- and low-operating frequency 

units?

b. Are there non-efficiency benefits (e.g., CRI, lamp life) associated with highfrequency operation?

c. How does potting affect cost and efficiency? Other factors (e.g., noise)?

d. Do you offer, or plan to offer, electronic ballasts at wattages above 400? Are 

there any design constrains as wattage is increased?

D.4 Magnetic Ballasts

a. How do cost and efficiency vary between different circuit topologies (e.g., HX-
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HPF, CWA, Regulated Lag)?

b. Do different circuit topologies provide different utility (e.g., voltage 

regulation)? How much?

c. Apart from the ignitor circuit, are there notable differences between probe- and 

pulse-start ballasts?

D.5 Fixtures

a. Do electronic ballasts require larger ballast housings? Is it possible to design 

electronic ballasts to fit ballast housings that previously held magnetic ballasts?

b. What specific costs are associated with changing fixture size due to a switch in 

ballast type (e.g., magnetic to electronic ballast switch)?

c. Do you offer multiple versions of the same fixture application for magnetic and 

electronic ballasts? Can any fixtures take either type of ballast?

d. Is teardown-based cost modeling reliable for fixtures? Ballasts?
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PART 2. PRELIMINARY MANUFACTURER IMPACT ANALYSIS TOPICS

1 Key Issues

1.1 What are the key issues for your company regarding this metal halide lamp fixture 

rulemaking?

1.2 Are there any patent, technology, or other issues that you are aware of that would prevent 

your company or competitors from implementing higher-efficiency designs?

2 Shipment Projections

2.1 Would you provide historical shipment estimates for your company for the following:

Rated Lamp Wattage

Metal Halide Fixtures Shipments by Year

2005 2006 2007 2008 2009

≥ 50W and < 150W

≥ 150W and ≤ 250W

> 250W and ≤ 500W

> 500W

2.2 What is your company’s approximate market share for the metal halide ballasts/fixtures 

DOE is considering covering?

2.3 Would you expect your market share to change once standards become effective? Does 

your outlook change with higher efficiency levels?

2.4 How would you expect shipments to change for the industry as a whole as a function of 

standards and why?

2.5 Looking at price/cost effects only, how would you expect shipments to change for a 25%, 

50%, 100% or 200% manufacturer price/cost increase?

3 Conversion Costs
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3.1 What level of capital expenditure and product conversion costs would you anticipate to 

make at higher standard levels? Please describe what they are and provide your best 

estimate of their respective magnitudes.

3.2 How would the imposition of amended energy conservation standards affect capacity, 

utilization and manufacturing assets at your domestic production facilities? Would 

amended standard result in stranded capital assets? Would any facilities be closed or 

downsized? Added or upgraded?

3.3 How might amended standard impact product innovation?

4 Product Mix and Profitability

4.1 How would your company’s product mix and marketing strategy change with changes in 

the energy conservation standard?

4.2 Generally how would new product standards impact your customer mix, distribution 

channels, and corresponding profit margins?

4.3 What is the approximate percentage of shipments (i.e., market share) for each ballast and 

fixture type?

4.4 Do you enjoy consistent profitability across all metal halide ballast or fixture types?

5 Market Shares and Industry Consolidation

5.1 Who are your key competitors in the market?

5.2 In the absence of amended standards, do you expect any industry consolidation?

5.3 How would amended standards affect your ability to compete?

5.4 Could amended standards disproportionately advance or harm the competitive positions of 

some firms?

5.5 Are there concerns over intellectual property?

5.6 Could amended standards result in disproportionate economic or performance penalties for 

particular consumer/user subgroups?

5.7 Beyond price and energy efficiency, could amended standards result in products that will 

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

other features?
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6 Cumulative Regulatory Burden

6.1 Are there recent or impending regulations on your specific product or other products that 

impose a cumulative burden on the industry?

6.2 If so, what is the total expected impact of those other regulations?