APPENDIX 12A. MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDE



## Fluorescent Lamp Ballasts Rulemaking Manufacturer Analysis Interview Guide

October 23, 2008

12A-1P ART 1. M ARKET , T ECHNOLOGY , AND E NGINEERING A NALYSIS

A. Market Data

This section addresses informati on on the distribution of fluorescen t lamp ballast by efficiency and ballast type. At the framework meeting, DOE said that it would consider covering those ballasts that operate lamps covered in the lamps rulemaking while maintaining current exemptions (i.e, low power factor residential ba llasts, cold temperature F96HO ballasts used in outdoor signs, and dimming ballasts). The following lists those ballasts that cover those lamps proposed for coverage in the lamps ANOPR.

o 1-lamp, 2-lamp, 3-lamp, and 4-lamp ballasts that opera te 4-foot linear and 2-foot Ushaped medium bipin T8 and T12 lamps (e.g., F40T12, F34T12, F32T8, F30T8, F28T8, F25T8)

o 1-lamp and 2-lamp ballasts that operate 8-foot single pin slimline T8 and T12 lamps (e.g., F96T12, F96T12/ES, F96T8, F96T8/ES)

o 1-lamp and 2-lamp ba llasts that operate 8-foot rece ssed double contact high output T8 and T12 lamps (e.g., F96T12HO, F96T12HO/ES, F96T8HO)

DOE received written comments and comments at th e public meeting that DOE should cover the following ballast types:

o Low power factor, re sidential ballasts

o Dimming ballasts for T5, T8, and T12 lamps

o Cold temperature ballasts used in outdoor signs

o Ballasts that operate T5 lamps

o Mini ballasts

o Ballasts for straight and U-shaped lamps ranging in size from two to eight feet and T5 to T12

A.1 DOE seeks comment on the current market share of each of the balla st types listed above (e.g., low power factor, residen tial ballasts) and how that market share might change in the future.

A.2 DOE seeks comment on whether it is technologic ally feasible to improve the efficiency of the ballasts mentioned above.

A.3 Are there specific reasons why DOE should or should not cover any of the ballasts listed above? Should DOE consider covering any additional ballasts to those listed above?

DOE is considering analyzing the following ballasts in the engineering analysis:

o 2-lamp and 4-lamp F40T12, F34T12, and F32T8 ballasts

o 2-lamp F96T12, F96T12/ES, and F96T8 ballasts

12A-2o 2-lamp F96T12HO, F96T12HO/ES, and F96T8HO ballasts

A.4 DOE seeks comment on whether these are the mo st appropriate fluores cent lamp ballasts to study in detail.

A.5 For the ballasts identified, DOE seeks comment on the most common ballast sold in each of the ballast categories. Please describe ba llast attributes (i.e ., electronic/magnetic, starting method, ballast factor, i nput power, THD, power factor)

In order to calculate the aggregate national ener gy savings, DOE would need data on shipment trends. For each of the ballast types, DOE is in terested in obtaining shipment data by number of lamps operated and ba llast efficiency. DOE is also intere sted in understanding general market dynamics.

A.6 For each ballast type considered for coverage (e.g., for F32T8 ballasts, F40T12 ballasts, or F96T12 ballasts), what is the proportion of ballasts shipped that operate 1-lamp, 2

- lamp, 3-lamp, and 4-lamps? Do you expect these proportions to change overtime? If so, how?

A.7 For electronic F32T8 and F96T8 ballasts, what is the proportion of ballasts shipped that are high efficiency versus standard ef ficiency? Absent new energy conservation standards, do you expect these proportions to change overtime? If so, how?

A.8 For F32T8 ballasts, what is the proportion of ballasts shipped that are programmed start versus instant start? Absent new energy conservation standards, do you expect these proportions to change overtime? If so, how?

A.9 For F96T12HO and F96T12HO/ES ballasts, what proportion of ballasts shipped are magnetic versus electronic? Absent new en ergy conservation standards, do you expect these proportions to change overtime? If so, how?

A.10 For F32T8 ballasts, what propor tion of ballasts shipped are ma gnetic versus electronic? Absent new energy conservation standards, do you expect these proportions to change overtime? If so, how?

A.11 What are general trends you see in the market? Absent new energy conservation standards, do you foresee other technologies (e.g., HID or LED) increasing in market share over the next thirty-five years? If so, how?

12A-3A.12 What proportion of ballasts shipped are sold in the new renovation market, the replacement market, the early retrofit market, and the new construction market?

B. Engineering Analysis

DOE would like to understand the incremental costs of reducing ballast en ergy consumption by understanding the design options involved in e fficiency improvements. Please describe the discrete design steps you would undertake to achiev e the ballasts in the tables below. In each case, start with a standard efficiency balla st, and list the necessary design changes 1 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. The column labeled “Total Mfr. Unit Selling Price to Comm. or Ind. Sect.” is your final selling price to a distributor or contractor in the commercia l or industrial sector.

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.

1 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-4Table 1 Engineering Analysis for Electro nic Instant Start 2-lamp F32T8 Ballasts

Total Total Mfr. Mfr.

# Ballast Type Input Power, Ballast Factor Defining Design Characteristics Mfr. Production Cost Unit Selling Price to

OEM Fixture Unit Selling Price to Comm. or Ind. Mfr. Sect.

Standard

0 Instant Start 2

- Lamp F32T8 Ballasts

# Ballast Type Input Power, Ballast Factor Improvements over Standard Ballast Incr. Cost (over Std. Ballast) per Imp. Total Mfr. Unit Selling Price to

OEM Fixture

Mfr. Total Mfr. Unit Selling Price to Comm. or Ind.

Sect.

High Efficiency Instant Start, 2

- 1 Lamp F32T8 Ballasts

Maximum Technologically Feasible Instant 2 Start 2-Lamp, F32T8 Ballasts

12A-5Table 2 Engineering Analysis for Electroni c Programmed Start 2-lamp F32T8 Ballasts

Total Total Mfr. Mfr.

# Ballast Type Input Power, Ballast Factor Defining Design Characteristics Mfr. Production Cost Unit Selling Price to

OEM Fixture Unit Selling Price to Comm. or Ind. Mfr. Sect.

Standard

0 Programmed 2

- Lamp F32T8 Ballast

# Ballast Type Input Power, Ballast Factor Improvements over Standard Ballast Incr. Cost (over Std. Ballast) per Imp. Total Mfr. Unit Selling Price to

OEM Fixture

Mfr. Total Mfr. Unit Selling Price to Comm. or Ind.

Sect.

High Efficiency Programmed Star, 1 2-Lamp F32T8 Ballast

Maximum Technologically Feasible, 2 Programmed Start 2-Lamp F32T8 Ballast

D.1 For 2-lamp F40T12 or F34T12 electronic ba llasts, 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 improveme nts can be made and how would this impact the power consumed, th e cost to manufacture the ballast, and the selling price?

D.2 How would the answers given in Table 1 and Table 2 change for fluorescent lamp ballasts operating 4-lamps?
12A-6Table 3 Engineering Analysis for Electro nic Instant Start 2-lamp F96T8 Ballasts

Total Total Mfr. Mfr.

# Ballast Type Input Power, Ballast Factor Defining Design Characteristics Mfr. Production Cost Unit Selling Price to

OEM Fixture Unit Selling Price to Comm. or Ind. Mfr. Dist.

Standard,

0 Instant Start 2

- Lamp F96T8 Ballast

# Ballast Type Input Power, Ballast Factor Improvements over Standard Ballast Incr. Cost (over Std. Ballast) per Imp. Total Mfr. Unit Selling Price to

OEM Fixture

Mfr. Total Mfr. Unit Selling Price to Comm. or Ind.

Sect.

High Efficiency, Instant Start 2

- 1 Lamp F96T8 Ballast

Maximum Technologically 2 Feasible 2-Lamp F96T8 Ballast

D.3 For 2-lamp F96T12 or F96T12/ES 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 improveme nts can be made and how would this impact the power consumed, th e cost to manufacture the ballast, and the selling price?

12A-7Table 4 Engineering Analysis for 2-lamp F96T12HO Ballasts

Total Total Mfr. Mfr.

# Ballast Type Input Power, Ballast Factor Defining Design Characteristics Mfr. Production Cost Unit Selling Price to

OEM Fixture Unit Selling Price to Comm. or Ind. Mfr. Sect.

Magnetic, Rapid 0 Start 2-Lamp F96T12HO Ballast

# Ballast Type Input Power, Ballast Factor Improvements over Standard Ballast Incr. Cost (over Std. Ballast) per Imp. Total Mfr. Unit Selling Price to

OEM Fixture

Mfr. Total Mfr. Unit Selling Price to Comm. or Ind.

Sect.

Electronic, Rapid

Start 2-Lamp 1 F96T12HO Ballast

Maximum Technologically 2 Feasible 2-Lamp F96T12HO Ballast

D.4 For 2-lamp electronic F96T8HO 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 manufacturer selling price?

12A-8D.5 If there are additional ballasts you feel DOE should cover, 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?

C. Distribution Channels, Lifetime and Operating Hours DOE will need to develop a distribution chain model to understand how ba llasts migrate through the market from manufacturer to end-user. DOE is interested in understanding both the proportion (volume) of products th at move through certain channe ls and the mark-ups applied. The following figure displays the distributi on chain provided by NEMA in the 2000 Ballast Rule. According a comment provided by NE MA in the 2000 Ballast Rulemaking, 63% of ballasts moved through channel A while 37% moved through channels B and C. DOE also assumed that a 13% contractor markup was applied from the Contr actor/LMC to the End User of the Lighting System.

Figure 1: 1999 NEMA Ballast Distribution Channels

12A-9C.1 Is the distribution chain displayed in Figure 1 an accurate representation of how ballasts reach the end user? If so, what proporti on of shipments move through the various channels (e.g., A, B, or C), and 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 on the sector of the end-user of the lighting system? If so, how? Assumptions used in th e 2000 Ballast rulemaking for some of these estimates are provided above.

C.2 DOE is intending to consider fluorescent lamp ballasts operating in different sectors. For the fluorescent lamp ballasts under consideration in this rulemaking, can you provide an estimate of the proportion of fluorescent lamp ballasts sold into the commercial, industrial, and residential sect ors? What proportion of ballast shipments to the residential sector are low power factor, residential balla sts versus high power factor ballasts? According to our analysis using EIA data and data from the U.S. Lighting Market Characterization, Volume I (DOE, 2002), the aver age annual operating hours for GSFL is 3,435 hours for the commercial sector, 4,795 hours for th e industrial sector and 789 hours for the residential sector.

C.3 Are these reasonable estimates? If not, wh at is the average annual operating hours by sector? Does the average annual operating hours vary significantly by fluorescent lamp ballast type? In the fluorescent lamp ANOPR analysis, DOE assumed that the most common T8 lamp operating on an instant start electronic balla st had a lifetime of 20,000 hours at 3 hours on 20 minutes off.

C.4 What would the lamp lifetime be when operating on a programmed start electronic ballast at 3 hours on 20 minutes off? at 1 hour on, 15 minutes off? In the fluorescent lamp ANOPR analysis and in the 2000 Ballast Rule, DOE assumed that lifetime of a ballast was approximately 50,000 hours. Us ing average operating hours in the commercial sector, industrial, and residential sector, one calculates a ballast life of approximately 15 years, 10 year s, or 63 years respectively.

C.5 DOE understands ballasts are some times replaced before they fa il due to lighting retrofits or renovations. On average, how often are ballasts replaced in each sector (i.e, what is their average useful lifetime)? Does this li fetime vary by starting method, efficiency, or ballast type?

C.6 What is the average fixture lifetime in each sector? In general, why are fixtures replaced (e.g., fixture “failure”, renova tion, or ballast failure)?

D. Test Procedure and Energy Conservation Standards At the framework meeting, NEMA recommended that DOE may want to change the energy conservation standard metric from ballast efficacy factor (BEF) to ballast efficiency in part because of the inherent variance of the BEF measurement due to the use of fluorescent lamps.

12A-10Unfortunately, DOE may not be able to legally change the metric from BEF but it can change the test procedure to measure BEF. One way to acco mplish this is to use resistors instead of lamps to determine the ballast factor and input power of a ballast. In order for DOE to determine whether or not to change the test procedure fo r ballasts, it must understand whether the new test procedure would improve upon the old test procedure.

D.7 For each of the ballasts described above, what is the variability in input power and ballast factor for any given ballast under the current test procedure?

D.8 For the F30T8, F28T8, F25T8, and F96T8/ES there are no ANSI standards specifying which lamp to use when testing a ballast. What are the qualities of the lamps you use to test ballast factor and i nput power for these ballasts? These qualities will help DOE establish a new test procedure measuring ba llast efficacy factor using resistors. In the framework document, DOE proposed that it may establish product classes for fluorescent lamp ballasts regardless of lamp wattage or lamp diameter. To account for the variance in BEF by lamp wattage, DOE could develop an equati on from which manufacturers would calculate the minimum BEF energy conservation standard based on the fluorescent lamps’ wattage.

D.9 Can you describe how ballast efficacy factor varies by lamp wattage for the following fluorescent lamp ballasts?

• 4-lamp and 2-lamp ballasts that operate 4-foot linear and 2-foot U-shaped medium bipin lamps

• 2-lamp ballasts that operate 8-foot single pin slimline lamps

• 2-lamp ballasts that opera te 8-foot recessed double contact high output lamps

The Team is considering extrapolating energy conservation standards from the analyzed fluorescent lamp ballasts to other product classes.

D.10 Can you describe how this ex trapolation might be applied to the following fluorescent lamp ballasts?

• From 4-lamp ballasts to 3-lamp ballasts that operate 4-foot linear and 2-foot Ushaped medium bipin T8 and T12 lamps

• From 2-lamp ballasts to 1-lamp ballasts that operate 4-foot linear and 2-foot Ushaped medium bipin T8 and T12 lamps

• From 2-lamp ballasts to 1-lamp ballasts that operate 8-foot single pin slimline T8 and T12 lamps

• From 2-lamp ballasts to 1-lamp ballasts that opera te 8-foot recessed double contact high output T8 and T12 lamps

12A-11P 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 fluorescent lamp ballast rulemaking?

1.2 Are there any patent, technology, or other issu es that you are aware of that would prevent your company or competitors from implementing higher-efficiency designs?

2 Shipment Projections

2.1 What is your company’s approximate market share for the fluorescent lamp ballasts DOE is considering covering?

2.2 Would you expect your market share to change once standards become effective? Does your outlook change with higher efficiency levels?

2.3 How would you expect shipments to change for the industry as a whole as a function of standards and why?

2.4 Looking at price/cost effects only, how woul d you expect shipments to change for a 25%, 50%, 100% or 200% manufacturer price/cost increase?

3 Conversion Costs

3.1 What level of capital expenditu re 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 new energy conservation standards affect capacity, utilization and manufacturing assets at your domestic production fac ilities? Would a new standard result in stranded capital assets? Would any facilities be closed or downsized? Added or upgraded?

3.3 How might a new standard impact product innovation?

4 Product Mix and Profitability

4.1 How would your company’s product mix and mark eting strategy change with changes in the efficiency standard?

12A-124.2 Generally how would new product standards impact your customer mix, distribution channels, and corresponding profit margins?

4.3 What is the approximate percenta ge of shipments (i.e., market share) for each ballast type?

4.4 Do you enjoy consistent profitability across all fluorescent lamp ballast types?

5 Market Shares and Industry Consolidation

5.1 In the absence of new standards, do you expect any industry consolidation?

5.2 How would new standards affect your ability to compete?

5.3 Could new standards dispropor tionately advance or harm the competitive positions of some firms?

5.4 Are there concerns over intellectual property?

5.5 Could new standards result in disproportiona te economic or performance penalties for particular consumer/user subgroups?

5.6 Beyond price and energy efficiency, could ne w standards result in products that will be more or less desirable to consumers due to changes in pr oduct functionality, utility, or other features?

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?

12A-13