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APPENDIX 13A. INTERIM MANUFACTURER IMPACT ANALYSIS INTERVIEW G UIDES

TABLE OF CONTENTS

13A.1 Interim Manufacturer Interview Guide for High-Intensity Discharge Lamps – Lamp Manu facturers ............................................................................................................. 13A-1

13A.2 I nterim Manufacturer Interview Guide for High-Intensity Discharge Lamps – Fixture Manufacturers ........................................................................................................... 13A-1413A -1

13A.1 INTERIM MANUFACTURER INTERVIEW GUIDE FOR HIGH-INTENSITY DISCHARGE LAMPS

– LAMP MANUFACTURERS

April 2012

Purpose: To gather information on the U.S. high-intensity discharge lamp market to assist in the De partment of Energy’s energy conservation standards analysis.

Method: Navigant Consulting, Inc. (Navigant) is circulating this interview guide to a limited number of manufacturers of high-intensity discharge lamps who operate in the U.S. market. Navigant will

c ombine all the responses from individual manufacturers to protect proprietary information of any one manufacturer. Individual responses to this questionnaire and any other data provided will all be covered under a non-disclosure agreement, which Navigant will enter into with each participating manufacturer. Navigant will handle all individual company data in the strictest confidence.

If you have any questions, please contact:

Matthew Walker Navigant Consulting, Inc. matthew.walker@navigant.com Tel: 202.481.8482 F ax: 202.973.240113A -2

In July 2010, the U.S. Department of Energy (DOE) published a determination that en ergy conservation standards for high-intensity discharge (HID) lamps are technologically feasible and

e conomically justified, and would likely result in significant energy savings. DOE is now

c onducting a rulemaking to consider establishing energy conservation standards for HID lamps. As the first step in this process, DOE published a framework document in February 2012 that describes the procedural and analytical approaches DOE anticipates using to evaluate potential energy conservation standards. 1

1 SCOPE OF COVERAGE

In the framework document, DOE considered covering only certain types of HID lamps, summarized in Table 1

. 1

.

Table 1. 1 HID Lamps Considered for Coverage
Lamp Type Rated Wattage Correlated Color Temperature (CCT) Metal Halide (MH)  50 and  2000 W  2500 and  6999 K Mercury Vapor (MV)  50 and  1000 W  3200 and  6800 K High Pressure Sodium (HPS)  50 and  1000 W  1900 and  27 00 K

Based on the small number of available products, DOE considered excluding the following lamp types:

 HID lamps designed and labeled for use with electronic ballasts only

 directional HID lamps

 self-ballasted HID lamps

 colored HID lamps

 specialty application mercury vapor lamps

1.1 DOE defines HID lamp as an electric-discharge lamp in which – (1) the light-producing arc is stabilized by the arc tube wall temperature; and (2) the arc tube wall loading is in excess of 3 watts/cm2, including such lamps that are mercury vapor, metal halide, and high-pressure sodium lamps.

Would electrodeless HID lamps (light emitting plasma) meet this definition? In what applications are electrodeless lamps most often used?

1.2 What differs between an “electronic ballast only” lamp and a lamp that can operate on

e ither an electronic or magnetic ballast?

1.3 Do you agree with the European Union’s definition of white-light source 2 that specifies a region of the chromaticity diagram? Could that definition be used to distinguish colored lamps (i.e

. , blue, green, orange, and magenta) from other product offerings?

1 The framework document is available on DOE’s website at: http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/hid_ecs_framework_document.pdf

. 2 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:076:0017:0044:EN:PDF13A -3

1.4 The Energy Policy Act of 2005 exempted specialty application MV lamp ballasts from the general ban of MV lamp ballasts. Why are MV lamps needed in some applications? Are there any technical characteristics that distinguish MV lamps operated by specialty application ballasts?

2 MARKET ANALYSIS

2.1 How do consumers select an HID lamp? What parameters are they most interested in? Do they weigh input power or light output more heavily?

2.2 What percentage of currently installed HID lamps are electronically ballasted? How does this percentage change for MV, HPS, or MH lamps?

2.3 What motivates consumers to purchase coated lamps (resulting in reduced efficacy) when comparable clear bulbs are available? What is the market share between the two types?

In order to calculate the aggregate national energy savings, DOE needs data on shipment trends.

2.4 For each lamp type, what lamp wattages are most common? If possible, please provide an approximation of proportions of units shipped by wattage.

2.5 Are medium base lamps more common at lower light output than mogul base lamps and vice versa?

2.6 For MH lamps, what percent of lamp shipments are probe-start versus pulse-start? What percent of pulse-start shipments are quartz versus ceramic?

2.7 For HPS and MV lamps, what portion of shipments are standard efficacy versus high efficacy (or high output)?

DOE assumes that each lamp type is used in the following environments:

 Mercury Vapor

o 75% general application used in exterior applications

o 25% specialty application

 High -Pressure Sodium

o 90% - exterior applications

o 10% - interior applications

 Metal Halide

o 80% - exterior applications

o 20% - interior applications

2.8 Do you agree with the above estimates?

2.9 Roughly what portion of lamps shipped do you see as servicing existing equipment versus new construction/renovation?13A -4

2.10 What are general trends you see in the market? Do you foresee other technologies (e.g., linear fluorescent, induction, light-emitting diodes (LED)) impacting the future shipments of HID lamps? If so, how?

2.11 How would you expect future market shares for the most common HID lamp types to change in the presence of new energy conservation standards for HID lamps?

3 TECHNOLOGY ASSESSMENT

Measures that improve efficacy are called technology options, and they are based on technologies used in commercially available equipment, as well as working prototypes.

Table 3. 1 Technology Options for HID Lamps Lamp Type Technology Option Efficacy Incre ase MV

HPS

MH Arc Tube Geometry (pinched,

ovoid, arch) Arc Tube Material (quartz/ceramic) Fill Gas Composition Starting Method Others?

3.1 How are the color rendering index (CRI) and CCT increased/changed in an HID lamp?

3.2 Why do quartz MH lamps tend to have increased lumen depreciation relative to ceramic MH lamps?

3.3 How is lamp rated life increased? Why do MH lamps have a shorter rated life than most HPS and MV lamps?

3.4 What impact does electronic vs. magnetic ballast operation have on an HID lamp? Are there any impacts on lifetime, color, efficacy, or lumen maintenance? Do impacts differ based on lamp tec hnology?13A -5

4 EQUIPMENT CLASSES

DOE separates equipment into categories called equipment classes based on differences in efficacy and consumer uti lity (i.e., features valued by consumers). DOE then conducts its analyses and establishes separate standard levels for each equipment class. DOE is considering

se parating equipment classes based on CCT and lumen output.

Table 4. 1 Equipment Classes Under Consideration
Directionality Ballast

Location CCT Range Lumen Range Baseline Model for Representative Classes

Omni

directional Externally

Ballasted 1,500

- 2,500K 1

 3,000 lm 3,001

 5,000 lm 50 W HPS 5, 001

 8,000 lm 8,001

 11,000 lm 100 W HPS 11,001

– 20,000 lm 20,001

– 40,000 lm 250 W HPS 40,001

– 100,000 lm 400 W HPS 100,001+ lm

2,501

- 5,000K 1

– 3,000 lm

3,001

– 5,000 lm 100 W MV

70 W Pulse

- Start MH 5,001

– 8,000 lm
8,001

– 12,0 00 lm 175 W MV

150 W Probe

- Start MH
12,001

– 20,000 lm 250 W MV

175 W Probe

- Start MH
20,001

– 50,000 lm 400 W MV

400 W Probe

- Start MH 50,001+ lm 1000 W Probe

- Start MH

5,001K+ 1

– 3,000 lm

3,001

– 5,000 lm 5,001

– 8,000 lm 8,001

– 12,000 l m 12,001

– 20,000 lm 20,001

– 50,000 lm 50,001+ lm * Gray shading indicates representative equipment classes.

DOE does not consider lamp technology (MV, HPS, MH) to be a class-setting factor. Rather, DOE considers MH lamps to be a more efficacious replacement for MV lamps. However, given the range of CCT values, DOE does not consider HPS lamps to be a more efficacious replacement for MH lamps.

4.1 Do you agree with the lumen output and CCT ranges under consideration?

4.2 DOE does not believe HPS lamps are appropriate substitutes for MH lamps. Is this consistent with industry trends? Are there any other shifts in customer preference between HID lamp technologies?

4.3 Should other parameters be considered as class-setting factors? In particular, should the13A -6

following parameters be considered? Please explain.

 Base type

 Lamp shape

 CRI

 Open vs. enclosed safety rating

 Coated vs. not coated

 Lamp orientation (vertical, horizontal, universal)

4.4 Open rated lamps are usually less efficacious than enclosed rated lamps due to a protective film added to the open rated lamps. How is overall fixture efficiency affected by these diff erences?

4.5 MV lamps are not always clearly labeled with open or enclosed fixture safety ratings. Do e s this fixture safety rating apply to MV lamps?

4.6 Does shape ever prevent a lamp from being used as a replacement for another lamp with similar characteristics? Are lamp shapes specific to certain applications?

4.7 DOE selects certain equipment classes (called representative equipment classes) to analyze in detail. The representative equipment classes are selected primarily based on shipment volume, so that categories of lamps with higher market share are analyzed in detail. Do you agree with the representative equipment classes under consideration?

4.8 DOE also selects baseline models within a representative equipment class. The baseline model typically represents the most common, least efficacious lamp available . Do you agree with the w attage and lamp technology selected?

5 ENGINEERING ANALYSIS

The following tables seek information on more efficacious replacements for the representative equipment classes. DOE seeks information on efficacy and typical characteristics of the baseline model, in addition to design pathways for achieving higher efficacy. The tables correspond to the

re presentative equipment classes from Table 4

. 1 . For example, the first table below corresponds to omni -directional lamps 1,500 to 2,500 K, 3,001-5,000 lumen equipment class. The 50 W HPS la mp is the lamp under consideration for the baseline model.13A -7

Table 5. 1 50 W HPS Engineering Analysis Level Lamp Type Efficacy Key Design Characteristics Price Baseline 50 W HPS

C andidate S tandard L evel ( CSL) 1 CSL2 Maximum Technologically Feasible

Table 5. 2 100 W HPS Engineering Analysis Level Lamp Type Efficacy Key Design Characteristics Price Baseline 100 W HPS

CSL1

CSL2 Maximum Techno logically Feasible

Table 5. 3 250 W HPS Engineering Analysis Level Lamp Type Efficacy Key Design Characteristics Price Baseline 250 W HPS

CSL1

CSL2 Maximum Technologically Feasible

Table 5

. 4 400 W HPS Engineering Analysis Level Lamp Type Efficacy Key Design Characteristics Price Baseline 400 W HPS

CSL1

CSL2 Maximum Technologically Feasible13A -8

Table 5. 5 70 W Metal Halide Engineering Analysis Level Lamp Type Efficacy Key Design Characteristics Price Baseline 100 W MV

Baseline /CSL1 70 W Pulse

Start MH
CSL2

CSL3 Maximum Technologically Feasible

Table 5. 6 150 W Metal Halide Engineering Analysis Level Lamp Type Efficacy Key Design Characteristics Price Baseline 175 W MV

Baseline /CSL1 150 W Probe

Start MH

CSL2

CSL3

CSL4 Maximum Technologically Feasible13A -9

Table 5. 7 175 W Metal Halide Engineering Analysis Level Lamp Type Efficacy Key Design Characteristics Price Baseline 250 W MV

Baseline /CSL1 175 W Probe

Start MH

CSL2

CSL3

CSL4 Maxi mum Technologically Feasible

Table 5. 8 400 W Metal Halide Engineering Analysis Level Lamp Type Efficacy Key Design Characteristics Price Baseline 400 W MV

Baseline /CSL1 400 W Probe

Start MH

C SL2

CSL3

CSL4 Maximum Technologically Feasible13A

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Table 5. 9 1000 W Metal Halide Engineering Analysis Level Lamp Type Efficacy Key Design Characteristics Price Baseline 1000 W Probe

Start MH

CSL1

CSL2

CSL3 Maximum Technologically Feasible

5.1 Is HID lamp efficacy expected to change over time? Are R&D efforts focused on these products?

DOE intends to pair each lamp with an appropriate ballast, as the lamp and ballast operate together as a system in practice.

5.2 DOE has found that lamps of one type can be used as retrofits with ballasts designed for a different lamp type (e.g., HPS lamp retrofit for an MV ballast). Is this type of substitution common in practice?

5.3 Can fixtures typically be used with multiple lamp technologies? If not, how do the fixtures differ?

6 EQUIPMENT PRICE DETERMINATION

DOE is considering estimating end-user price directly by collecting manufacturer suggested price lists (“blue books”) and applying a discount based on the distribution channel through

w hich the lamp is purchased. DOE plans to gather price information from State procurement contracts, large electrical supply distributors, home-improvement/hardware stores, and other sources of publicly available end-user prices such as Internet retailers, to estimate the appropriate discounts.

6.1 Do you agree with this methodology for determining lamp price? If not, why?

6.2 Has the limited availability of certain rare earth elements impacted the cost of HID lamps ?

6.3 Is the above methodology appropriate for determining ballast prices? If not, why?13A

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6.4 Do fixture prices vary between MV, HPS, and MH systems?

7 MARKUP ANALYSIS

Although DOE is developing end-user prices in the equipment price determination, DOE will need to derive manufacturer selling prices (MSPs) for the manufacturer impact analysis (MIA). To that point, DOE is interested in understanding both the proportion (volume) of equipment that moves through distribution channels and the mark-ups applied. Because replacement options for HID lamps may involve a new ballast and fixture in addition to a lamp, DOE is

e xploring distribution channels for all three components.

L amp Distribution Channel 1: Lamp Manufacturer  Electrical Wholesaler (Distributor)  Contractor  EndUser of Lighting System

Lamp Distribution Channel 2: Lamp Manufacturer  Electrical Wholesaler (Distributor)  End-User of Lighting System

Ballast Distribution Channel: Ballast Manufacturer  Electrical Wholesaler (Distributor)  Contractor  EndUser of Lighting System

Fixture Distribution Channel: Fixture Manufacturer  Electrical Wholesaler (Distributor)  Contractor  EndUser of Lighting System

7.1 Are the distribution channels above an accurate representation of how the different lighting components reach the end user? What are the typical mark-ups applied by organizations

or individuals in those channels?

8 LIFETIME AND OPERATING HOURS

8.1 DOE intends to use catalog data to determine the lifetime of representative lamps selected in the engineering analysis. Do you agree with this approach?

In the metal halide lamp fixture preliminary analysis, DOE used average annual operating hours for the sectors below:

 Commercial – 3,720 hours per year

 Industrial – 4,748 hours per year

 Outdoor Stationary – 4,098 hours per year

8.2 DOE is considering using the same operating hours for all HID lamps. Do you agree with this assumption? Do the operating hours differ for MV and HPS lamps?13A

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8.3 Because a higher efficacy replacement may require a new ballast, DOE must also

e stimate the life time of a ballast. DOE is considering using 50,000 hours for magnetic ballasts and 40,000 hours for electronic ballasts for all HID lamp types. Are these estimates representative of the market?

8.4 DOE estimates that average life of interior fixture is 20 years and an exterior fixture is 25 years. Do you agree with these estimates?

9 PRELIMINARY MANUFACTURER IMPACT ANALYSIS

Key Issues

9.1 In general, what are the key issues for your company regarding energy conservation standards and this rulemaking?

9.2 Are there any patent, technology, or other issues that you are aware of that would prevent your company or competitors from implementing higher-efficacy designs?

Shipment Projections

9.3 What is your company’s approximate market share for the HID lamps DOE is considering including in coverage?

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

9.5 Do you expect shipments to change for the industry as a whole as a function of standards? If so, why?

9.6 Do you expect an increased purchase price for HID lamps to result in reduced demand or shipments (price elasticity)? If so, how sensitive do you think shipments will be to price changes? Does it vary with equipment class?

9.7 What is the proportion of domestically consumed HID lamps shipped by the National Electrical Manufacturers Association (NEMA) companies versus non-NEMA companies?

Conversion Costs

9.8 What level of capital expenditure and product conversion costs would you anticipate making at higher standard levels? Please describe what they are and provide your best estimate of their respective magnitudes.

9.9 How would the imposition of new energy conservation standards affect capacity utilization and manufacturing assets at your domestic production facilities? Would a new standard result in stranded capital assets? Would any facilities be closed or downsized? Added or13A

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upgraded?

9.10 How might a new standard impact product innovation?

Product Mix and Profitability

9.11 How would your company’s product mix and marketing strategy change with changes in the efficiency standard?

9.12 Generally, how would new standards impact your customer mix, distribution channels, and corresponding profit margins?

9.13 Is your profitability consistent across all HID lamp types?

Market Share and Industry Consolidation

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

9.15 How would new standards affect your ability to compete?

9.16 Could new standards disproportionally advance or harm the competitive positions of some firms?

9.17 Could new standards result in disproportionate economic or performance penalties for particular consumer/user subgroups?

9.18 Beyond pricing and energy efficiency, could new standards result in products that will be more or less desirable to consumers due to changes in product functionality, utility, or other fe atures?

Cumulative Regulatory Burden

9.19 Are there recent or impending regulations on your specific products or other products that impose a cumulative burden on the industry?

9.20 If so, what is the total expected impact of those regulations?13A

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13A.2 INTERIM MANUFACTURER INTERVIEW GUIDE FOR HIGH-INTENSITY DISCHARGE LAMPS

– FIXTURE MANUFACTURERS

April 2012

Purpose: To gather information on the U.S. high-intensity discharge lamp market to assist in the Department of Energy’s energy conservation standards analysis.

Method: Navigant Consulting, Inc. (Navigant) is circulating this interview guide to a limited number of manufacturers of high-intensity discharge lamps who operate in the U.S. market. Navigant will combine all the responses from individual manufacturers to protect proprietary information of any one manufacturer. Individual responses to this questionnaire and any other data provided will all be covered under a non-disclosure agreement, which Navigant will enter into with each participating manufacturer. Navigant will handle all individual company data in the strictest confidence.

If you have any questions, please contact:

Matthew Walker Navigant Consulting, Inc. matthew.walker@navigant.com Tel: 202.481.8482 F ax: 202.973.240113A

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In July 2010, the U.S. Department of Energy (DOE) published a determination that energy conservation standards for high-intensity discharge (HID) lamps are technologically feasible and economically justified, and would likely result in significant energy savings. DOE is now conducting a rulemaking to consider establishing energy conservation standards for HID lamps. As the first step in this process, DOE published a framework document in February 2012 that de scribes the procedural and analytical approaches DOE anticipates using to evaluate potential energy conservation standards. 3

1 MARKET ASSESSMENT

1.1 What types of technology do customers transition between during renovation (e.g. HPS to ceramic MH, probe MH to pulse MH, high wattage to reduced wattage, etc.)? What percentage of customers specifies HPS versus MH for new construction?

1.2 What portion of customers replaces MV technology with HPS versus MH technology?

1.3 To what extent do you see HPS technology being replaced with MH technology and vice versa?

1.4 What percent of fixtures sold are for use with open-fixture-rated lamps versus enclosed?

1.5 How common is it for customers to purchase a new fixture during/following:

 Lamp failure

 Lamp and ballast failure

1.6 When switching from probe- to pulse-start MH technology, do customers typically buy a

ne w luminaire (new fixture, lamp, and ballast) or retrofit the existing fixture (new lamp, ballast, starter, wiring, and socket)? Does this vary by wattage?

1.7 When changing from one technology to another (such as MV to HPS or MH), is it more common to buy a new luminaire or retrofit the existing fixture?

2 TECHNOLOGY ASSESSMENT

Measures that improve efficacy are called technology options, and they are based on technologies used in commercially available equipment, as well as working prototypes.

2.1 What are the physical differences between HPS, probe-start MH, pulse-start MH, and MV fixtures when used in the same application? Are they similar sizes? Are they constructed of similar materials? Are any fixtures typically used with multiple lamp technologies? Please explain.

3 The framework document is available on DOE’s website at: http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/hid_ecs_framework_document.pdf

.13A

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2.2 Are different fixtures used for different lamp orientations? If so, please explain.

2.3 Can a fixture typically be retrofitted with a reduced wattage lamp and ballast of the same technology? For example, is it feasible for a reduced-wattage pulse-start MH system (lamp, ballast, starter, wiring, and socket) to retrofit an existing probe-start MH lamp fixture? Why or why not?

2.4 Do you agree with the following estimates of average ballast efficiency of installed ballasts?

Table 2. 1 Ballast Efficiency of Installed Fixtures Ballast Type Lamp Wattage (Watts) Ballast Efficiency (%) HPS 50 76

100 79 150 81 250 84 400 86 1 000 92 MV 50 74

100 83 175 86 250 87 400 89 1000 92 Probe

- start MH 175 83

250 86 400 86

3 ENGENEERING ANALYSIS AND PRICE DETERMINATION

P lease indicate the application(s) for each lamp wattage, including which is the most common. What is the MSP of the fixture used in the most common application? Does this price vary sig nificantly for the other applications?13A

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Table 3. 1 Fixture Engineering Analysis Technology Lamp Wattage Application(s) Manufac turer Selling Price of Fixture ($) HPS 50 W

100 W

150 W

250 W

400 W

1000 W

MV 50 W

100 W

175 W

250 W

400 W

1000 W

3.1 Does fixture price vary between probe and pulse start systems of the same wattage and application?

3.2 Does fixture price vary between quartz and ceramic metal halide pulse-start systems?

3.3 Are HPS fixtures of similar wattage and application approximately the same cost as MH fixtures?

3.4 Do ballast prices vary significantly by lamp technology? For example, are magnetic HPS ballasts priced similarly to pulse-start magnetic MH ballasts (with approximately the same characteristics such as wattage and efficiency)?

3.5 What are your suggestions for methods of assigning prices to fixtures? Would estimating end -user price by collecting manufacturer suggested prices lists and developing discounts from that list based on distribution channel be a possibility? Can MH fixture prices be adapted for other technologies?

4 MARKUP ANALYSIS

DOE is interested in understanding both the proportion (volume) of equipment that moves through distribution channels and the mark-ups applied. Because replacement options for HID lamps may involve a new ballast and fixture in addition to a lamp, DOE is exploring distribution channels for all three components.13A

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Lamp Distribution Channel 1: Lamp Manufacturer  Electrical Wholesaler (Distributor)  Contractor  EndUser of Lighting System

Lamp Distribution Channel 2: Lamp Manufacturer  Electrical Wholesaler (Distributor)  End-User of Lighting System

Lamp Distribution Channel 3: Lamp Manufacturer  Fixture Manufacturer  Electrical Wholesaler (Distributor)  End-User of Lighting System

Ballast Distribution Channel: Ballast Manufacturer  Electrical Wholesaler (Distributor)  Contractor  EndUser of Lighting System

Fixture Distribution Channel: Fixture Manufacturer  Electrical Wholesaler (Distributor)  Contractor  EndUser of Lighting System

4.1 Are the distribution channels above an accurate representation of how the different lighting components reach the end user? What are the typical mark-ups applied by organizations or individuals in those channels? Are there any additional distribution channels you would add? What is the most common channel?

4.2 What percentage of fixtures is shipped with a lamp, using Lamp Distribution Channel 3 from above?