13A-i 

APPENDIX 13A. INTERIM MANUFACTURER IMPACT ANALYSIS INTERVIEW 

GUIDES 

TABLE OF CONTENTS

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

Manufacturers ............................................................................................................. 13A-1

13A.2 Interim Manufacturer Interview Guide for High-Intensity Discharge Lamps – Fixture 

Manufacturers ........................................................................................................... 13A-14
13A-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 

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 

Fax: 202.973.2401 
13A-2 

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 

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 2700 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 

either an electronic or magnetic ballast? 

1.3 Do you agree with the European Union’s definition of white-light source2 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:PDF 
13A-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 Increase

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 technology? 
13A-5 

4 EQUIPMENT CLASSES 

DOE separates equipment into categories called equipment classes based on differences in 

efficacy and consumer utility (i.e., features valued by consumers). DOE then conducts its 

analyses and establishes separate standard levels for each equipment class. DOE is considering 

separating 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

OmnidirectionalExternally 

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

8,001–12,000 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 lm

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 the 
13A-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 

differences? 

4.5 MV lamps are not always clearly labeled with open or enclosed fixture safety ratings. 

Does 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 wattage 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 

representative 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 

lamp 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

Candidate 

Standard Level 

(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 

Technologically 

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 

Feasible
13A-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 

Feasible
13A-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

Maximum 

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

CSL2

CSL3

CSL4 

Maximum 

Technologically 

Feasible
13A-10

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 

which 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-11

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 

exploring distribution channels for all three components. 

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 

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-12

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

estimate the lifetime 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 or 
13A-13

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 

features? 

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-14

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 

Fax: 202.973.2401 
13A-15

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 

describes 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 

new 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-16

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

1000 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 

Please 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 

significantly for the other applications? 
13A-17

Table 3.1 Fixture Engineering Analysis 

Technology Lamp Wattage Application(s) Manufacturer 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-18

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?