12A

- 1 APPENDIX 12A. MA NUFACTURER IMPACT AN ALYSIS INTERVIEW GUI DE



## Metal Halide Lamp Fixtures Rulemaking

Manufacturer Impact Analysis Interview Guide

September 29, 201012A

- 2 P ART 1. M ARKET , T ECHNOLOGY , AND E NGINEERING A NALYSIS

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 tha n 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 inc lude 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 f or 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 is sues 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))12A

- 3 **•** 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° C12A

- 4 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:12A

- 5 Rated Lamp Wattage Input Voltage CWA HX

HPF Linear

Reacto

r Magneticall

y Regulated

L ag 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 circuit12A

- 6 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 fixt ures 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 pul se

- 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?12A

- 7 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 thes e 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.12A

- 8 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 unde rtake to achieve the ballasts in

the table s below. In each case, start with a standard efficiency ballast, and list the necessary design changes 2 to enable it to become more efficient. For each design change, please also provide an estimate of your increme ntal 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 t he 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.12A

- 9 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

Ballast12A

- 10 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 Pulse

Sart Ballast

1 High Efficiency Magnetic Pulse

Sart Ballast

2 Maximum Technologically Feasible, Magnetic Pulse

Sart 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?12A

- 11 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

Ballast12A

- 12 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 answ ers 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?12A

- 13 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.

U sing 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 th e 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?12A

- 14 C. Distribution Channels, Lifetime and Operating Hours

DOE will need to develop a distribution chain model to understand how ballasts and fixtures migrate through t he 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

D istributor)? 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 w ell?

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 framewor k document public12A

- 15 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 high

frequency operation?

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

d. Do you offer, or plan to offer, electronic balla sts 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

-12A

- 16 HPF, CWA, Regulated Lag)?

b. Do different circuit topologies provide di fferent 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?12A

- 17 P ART 2

. P RELIMINARY M ANUFACTURER I MPACT A NALYSIS T OPICS

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 Costs12A

- 18 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? Ad ded 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 s tandards 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 particul ar 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?12A

- 19 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?