Date: January 20, 2015

Case: Energy Conservation Standards Preliminary Analysis for General 

Service Lamps

Ace-Federal Reporters, Inc.

Phone: 202-347-3700

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 U.S. DEPARTMENT OF ENERGY

PUBLIC MEETING ON ENERGY CONSERVATION

 STANDARDS PRELIMINARY ANALYSIS FOR

 GENERAL SERVICE LAMPS (GSLS)

 TUESDAY, JANUARY 20, 2015

 9:00 A.M.

 1000 INDEPENDENCE AVENUE, S.W.

 FORRESTAL BUILDING

 ROOM 8E-089

 WASHINGTON, DC 20585-0121
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1 Speaker List Dept of Energy 

2

3 Doug Brookman-Chair 

4 Lucy deButts5 Noah Horowitz 

6 Aisha Husain 

7 Don Brundage 

8 John Cymbalsky9 Joe Howley 

10 Dave Gatto 

11 Mike McGaraghan 

12 Tom Stimac 

13 Alex Boesenberg 

14 Keith Cook 

15 Charlie Stevens 

16 Maureen Kienle 

17 Colleen Kantner 

18 Susan Callahan 

19 Alex Krowka 

20 Andrew Giallonardo 

21 Ken Rider (by Phone) 

22 Tom Eckman 
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1 Speaker List Dept of Energy

2

3 Andrew deLaski 

4 Brian Gerke 

5 Hayden Cook 

6 Joe Howley 

7 Jennifer Amann 

8

9 Webinar Participants 

10 Jordan Collins 

11 Erika Burns 

12 David Ryan 

13 Allison Ngo 

14 Shannon Baker-Branstetter 

15 Rick Ho 

16 Erik Page 

17 Andrea Alstone 

18 Jim McMahon 

19 Vagelis Vossos 

20 Robert Hosbach 

21 Liana Wallace 

22 Joseph Howley 
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1 Webinar Participants

2

3 Kevin Fuscus 

4 David Lis 

5 Xin Cao 

6 Taylor Jantz-Sell 

7 Kevin Dombrowski 

8 Claire Mizolek 

9 Mustaba Navvab 

10 Carol Tigges 

11

12

13

14

15

16

17

18

19

20

21

22
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1 P R O C E E D I N G S

2 MR. BROOKMAN: Okay let's begin happily. 

3 Good morning everyone welcome. This is the U.S.

4 Department of Energy's public meeting on energy

5 conservation standards preliminary analysis for

6 general service lamps. Today is Tuesday, January 20,

7 2015 here in the Forrestal Building, the Department

8 of Energy in Washington, D.C. My name is Doug

9 Brookman, Public Solutions Baltimore.

10 Nice to see you all this morning, sorry

11 for a slight delay in the start. We had audio

12 difficulty but I think they've now cleared that up. 

13 We are going to start with welcoming remarks from

14 Lucy deButts. 

15 MS. DEBUTTS: Hi everyone, thank you for

16 your patience and just like Doug said today we are

17 going to discuss the preliminary analysis for the

18 general service lamps. I called my colleagues from

19 Navigant Consulting and Lawrence Berkeley National

20 Lab and so Doug can go through the housekeeping

21 items.

22 MR. BROOKMAN: Thank you, we always start
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1 with introductions so I'll start to my immediate

2 left. You can get used to turning the microphones

3 both on and off.

4 MR. BOOK: Keith Cook with Philips

5 Lighting.

6 MS. CALLAHAN: Susan Callahan, Osram

7 Sylvania.

8 MR. BRUNDAGE: Don Brundage, Southern

9 Company.

10 MR. GATTO: Dave Gatto, Westinghouse

11 Lighting.

12 MR. STIMAC: Tom Stimac, GE Lighting.

13 MR. HOWLEY: Joe Howley, GE Lighting.

14 MR. STEPHENS: Charlie Stephens, Northwest

15 Energy Efficiency Alliance.

16 MR. HOROWITZ: Noah Horowitz, NRDC, the

17 Natural Resources Defense Council.

18 MR. MCGARAGHAN: Mike McGaraghan with

19 Energy Solutions here on behalf of the California

20 Investor Owned Utilities.

21 MR. GIALLONARDO: Andrew Giallonardo with

22 Canada's Department of Natural Resources.
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1 MR. ECKMAN: Tom Eckman, Northwest Power

2 and Conservation Council.

3 MS. SHER: Celia Sher, Department of

4 Energy, General Counsel's Office.

5 MR. BROOKMAN: Let's see if that works,

6 yes.

7 MS. KANTNER: Colleen Kantner, Lawrence

8 Berkeley National Lab.

9 MR. DESROCHES: Louis Desroches, Lawrence

10 Berkeley National Lab.

11 MR. GERKE: Brian Gerke, Lawrence Berkeley

12 National Lab.

13 MS. HUSAIN: Aisha Husain, Navigant.

14 MS. KIENLE: Maureen Kienle, Navigant.

15 MR. BALLO: Tim Ballo, Earthjustice.

16 MS. MCDONALD: Ali McDonald, Navigant

17 Consulting.

18 MR. COOK: Hayden Cook, Navigant

19 Consulting.

20 MR. BROOKMAN: Again welcome, so glad to

21 see you hear this morning for a good start on the New

22 Year here at the Department of Energy. Hopefully all
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1 of you received a packet of information as you

2 checked in this morning, I'm going to do a very brief

3 agenda review. Immediately following this agenda

4 review there's an opportunity for anybody that wishes

5 to make an opening remark, brief summary statements

6 about issues that matter to you here at the outset

7 that you would like to call to the floor. 

8 Following that we will move directly into

9 an Overview and then a Scope of Coverage, a Scope of

10 Metrics. We will take a mid-morning break roundabout

11 10:30 or so, following that Market Technology

12 Assessment Screening Analysis and then continuing on

13 from there, Engineering Analysis, Product Price

14 Determination. We will take lunch roundabout noon

15 and then returning from lunch, or when we get there

16 in Sequence, Energy Use Analysis, Life-Cycle Cost

17 Analysis, Shipments Analysis, National Impacts

18 Analysis, Preliminary Manufacturer Impact Analysis,

19 NOPR Analyses and then at the end of the day today,

20 which we anticipate it will be oh probably 2-ish or

21 sometime after lunch, Closing Remarks, an opportunity

22 again for anybody that wishes to raise additional
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1 issues that have not been covered sufficiently.

2 I recognize many of you, most of you and I

3 think you are of course familiar with the way we

4 typically run these meetings here at the Department

5 of Energy. If you could please speak one at a time,

6 please say your name for the record each time you

7 speak. There will be a complete transcript of this

8 meeting made available for you and everyone. If you

9 could be concise, share the air time, there's a lot

10 of content here to be covered and if you keep the

11 focus here, if you could turn your cell phones on

12 silent mode and limit side bar conversations.

13 Webinar participants we welcome you. The

14 Department of Energy is trying hard to make these

15 meetings totally accessible via the web. If you

16 would turn your telephones on mute that would help us

17 to limit feedback in the room and you can raise your

18 hand in the software provided to be recognized to

19 speak. Most of the time that seems to be working

20 here -- you raise your hand, we unmute you here in

21 the room and then we can hear you speak over the PA

22 system here in the room. So I think that is -- I
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1 would offer in addition to those via the webcast --

2 everyone, the Department appreciates and wants to

3 encourage everyone to provide detailed written

4 comments.

5 Those of you that are joining through the

6 web please send written comments in addition to what

7 you might join in the conversation here in the room. 

8 And do you want to do the purpose of the public

9 meeting?

10 MS. DEBUTTS: Sure.

11 MR. BROOKMAN: Yes, back to Lucy deButts.

12 MS. DEBUTTS: All right so the purpose of

13 today's public meeting is to discuss the preliminary

14 analysis. Just like Doug mentioned we invite

15 everyone to participate and remark on our analysis. 

16 We will also discuss the next steps and projected

17 deadlines for this rulemaking and as always we

18 encourage everyone to share the data if it is

19 available to help us to improve the analysis that we

20 have done so far.

21 Throughout the presentation while we are

22 having the discussion of the analysis we will see the
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1 issue boxes. These issue boxes are not going to be

2 -- they are going to correspond to the numbering

3 system that is provided in the executive summary of

4 the technical support documents and they are not

5 going to be in order because we are not going to

6 discuss every single issue, but only the major ones.

7 So you will see there may be some numbers

8 that go back and forth. When you provide comments to

9 us in written form, please follow the format that is

10 going to be discussed later and we would like to

11 comments to be submitted by February 9th of 2015 and

12 every document that is going to be available to the

13 stakeholders is located in the docket and the docket

14 link is provided on this slide.

15 In order to submit written comments, as

16 always you will provide several ways but we encourage

17 you to submit them via email and please mention the

18 title of the rulemaking, the docket number and the

19 rule number that is associated with this rule. You

20 can also send them by postal office and courier and

21 as I said our comment period will close on February

22 9th of 2015. And now we can go to the overview or
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1 opening remarks, sorry.

2 MR. BROOKMAN: As we had said an

3 opportunity for anyone to make opening remarks here

4 at the outset. Noah?

5 MR. HOROWITZ: Good morning this is Noah

6 Horowitz with NRDC. We would like to express our

7 appreciation to the Department of Energy for

8 considering the input of all the various stakeholders

9 and the advocates, and a lot of that was reflected in

10 the documents and we appreciate that.

11 In particular we want to highlight the

12 initial proposals for determinations by DOE that we

13 support. Firstly, proposing a smooth continuous

14 curve for studying efficiency requirements as a

15 function of light output, also your determination

16 that many of the currently exempt lamps do provide

17 overall illumination and therefore the exemptions

18 would go away for most but not all of the various

19 categories.

20 We also agree with your determination that

21 special treatment lamps such as shatter resistant,

22 vibration service, three-way and so forth, can be
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1 used in general applications. We also agree with

2 your view on modified spectrum there as well. In

3 terms of product classes, you simplified it which we

4 think was the right thing and we agree with your

5 technology-neutral approach.

6 And lastly we agree with your update to

7 the CFL quality parameters to take a look at those

8 and bring those up to speed, thank you.

9 MR. BROOKMAN: Thank you and I must say

10 it's nice when commenters, stakeholders say they like

11 what the Department's done, that's always a pleasant

12 sort of an outcome. Additional comments here at the

13 outset? Nothing additional? Then we are going to

14 move straight into the content provided starting with

15 the Overview, Lucy deButts.

16 MS. DEBUTTS: All right, so let's review

17 the regulatory history and so this rulemaking was --

18 the authority was given to DOE in 2007 when EISA was

19 enacted and to conduct two rulemaking cycles for the

20 evaluation of general service lamps. This rulemaking

21 constitutes the first cycle and we initiated it on

22 January 1st of 2014. We are mandated to publish the
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1 final rule by January 1st of 2017.

2 As was mentioned earlier we evaluated

3 existing exemptions for certain incandescent lamps,

4 but the scope is not limited to incandescent

5 technology only. We considered the phase in

6 compliance dates and of course, we considered the

7 minimum standard of 45 lumens per watt as EISA

8 instructed as a back stop criteria.

9 So with this rulemaking we are also

10 satisfying the requirements to review existing

11 standards for medium based fluorescent lamps and we

12 are addressing the stand-by and off mode as directed

13 by U.S. code.

14 The next slide represents the proposed

15 schedule for this rulemaking and as I mentioned on

16 December 9, 2013 DOE published a framework document. 

17 On December 11th of 2014 we published a Preliminary

18 Analysis the documents are posted in the docket in

19 the web. 

20 What we are hoping to do is to publish the

21 Notice of Proposed Rulemaking in December of this

22 year, 2015 -- with the final rule following in
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1 December of 2016 and the compliance dates -- the

2 compliance date for this rulemaking would be in

3 December of 2019 which is three years after final

4 rule publication. No questions? Okay.

5 So when we are doing our analysis, most of

6 you know we are considering 7 factors that deal with

7 economic impacts on consumers, lifetime operation

8 savings cost as compared to increased cost for the

9 products, total projected energy, impact on utility

10 and performance and lessening of competition, need

11 for national energy conservations and other factors

12 as the Secretary considers relevant.

13 And now we will move into Scope of

14 Coverage and Aisha will take up with that.

15 MS. HUSAIN: Hi my name is Aisha Husain,

16 I'm from Navigant. So in the next few slides we will

17 discuss in detail the scope of coverage for this

18 rulemaking. We will begin by the definition -- with

19 the definition of general service lamp which is shown

20 here. The definition notes specific lamp types that

21 are GSLs. It also specifies GSLs that are -- it

22 specifies that GSLs can be any other lamps
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1 identified by DOE to satisfy lighting applications

2 traditionally served by general service incandescent

3 lamps.

4 Finally it notes that lamp types that are

5 explicitly excluded from the GSL definition -- lamps

6 that are general service fluorescent lamps and lamps

7 that are incandescent reflector lamps are not GSLs.

8 So first we will discuss the GSLs

9 explicitly included in this definition and these are

10 listed here so the general service incandescent lamps

11 are GSLs, the compact fluorescent lamps, CFLs, the

12 general service light emitting diodes, LED lamps, the

13 organic light emitting diodes or OLED lamps.

14 Then we will discuss other lamps the DOE

15 has identified as GSLs and we will discuss lamp

16 types that are not considered GSLs and finally we

17 will go over the GSLs analyzed in this preliminary

18 analysis, yes?

19 MR. BRUNDAGE: I understand that -- Don

20 Brundage, Southern Company, incandescents are being

21 excluded from this rulemaking -- my understanding

22 this is some requirements from Congress. Could the
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1 Department comment on what their plans would be on

2 dealing with incandescents if these rules change and

3 you were allowed to -- how would you handle it if

4 hypothetically you are allowed to issue rules for

5 these again, would you start a separate rulemaking

6 for incandescents? 

7 MR. CYMBALSKY: This is John Cymbalsky

8 from DOE. So the original plan here was to include

9 all these lamps together in one rulemaking and if

10 Congress were to lift that rider prohibition we would

11 intend to bring that in once again. 

12 MR. BROOKMAN: Into this?

13 MR. CYMBALSKY: Correct.

14 MR. BROOKMAN: Into this rulemaking?

15 MR. CYMBALSKY: Yep.

16 MR. BROOKMAN: Okay, thank you. 

17 MS. HUSAIN: So that actually hits the

18 next slide here, you know as stated here that GSLs

19 include general service incandescent lamps and as we

20 were speaking before the Consolidated Appropriations

21 Act states that funds made available by the Act may

22 not be used to implement or enforce standards for
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1 GSLs, intermediate base incandescent lamps and

2 candelabra based incandescent lamps. Therefore DOE

3 is not considering these lamps in this rulemaking at

4 this time.

5 GSLs also include compact fluorescent

6 lamps which DOE has determined as comprising both

7 integrated and non-integrated CFLs. Integrated

8 medium based compact fluorescent lamps are currently

9 defined and subject to standards. The term compact

10 fluorescent lamp is not defined. DOE is proposing a

11 definition for the term compact fluorescent lamp and

12 other related terms in a forthcoming CFL test

13 procedure rulemaking.

14 Also DOE is not -- is considering not

15 setting standards for certain CFLs and we will

16 discuss those a little bit later. So general service

17 LED lamps are also GSLs and include both

18 non-integrated and integrated types. The term light

19 emitting diode is currently defined. The LED test

20 procedure supplementary NOPR which was published June

21 26th, 2014 is proposing to define integrated LED lamp

22 based on the ANSI & IESNA RP-16 definition.
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1 DOE is considering defining the term

2 general service LED lamp in this rulemaking as shown

3 here. And also just to note as with CFLs, it is

4 considering not setting standards for certain LEDs

5 and we will discuss this a little bit later as well.

6 OLED lamps are also GSLs, LEDs are a thin

7 filament light emitting device, usually with a series

8 of organic layers between two electrodes. DOE is

9 considering establishing a definition for OLED lamps

10 as shown here. DOE is not considering establishing

11 standards for OLED lamps as they are an emerging

12 technology with limited commercial availability and

13 it is also not clear if their efficacy can be

14 improved.

15 So issues over here asking for comment on

16 not establishing standards for OLED lamps.

17 MR. BROOKMAN: There you see the issue

18 box, comments on OLEDs, Joe?

19 MR. HOWLEY: GE and I believe most of

20 industry -- Joe Howley, GE -- believes it is too

21 early to set any type of regulation on OLEDs this is

22 a developing technology. There is simply not enough
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1 information yet about how this technology is going to

2 develop to begin to set regulations on it. I would

3 agree with DOE's position.

4 MS. HUSAIN: Thanks.

5 MR. BROOKMAN: Okay, additional comments

6 here? Nothing additional, okay.

7 MS. HUSAIN: So as noted previously GSLs

8 are also any other lamps that DOE finds satisfy

9 applications traditionally served by GSLs. DOE used

10 the following criteria to identify these lamps, DOE

11 determined that GSLs must have an ANSI base which

12 ensures that the lamp can be used in commonly found

13 sockets, that GSLs cannot be a light fixture and DOE

14 is defining the light fixture -- the term light

15 fixture in this rule making.

16 That GSLs can operate on any voltage,

17 that GSLs must provide overall illumination,

18 interior, exterior per definition of the general

19 lighting application. GSLs must have an output, 310

20 lumens greater or greater. DOE has determined that

21 lumens lower than 310 would not adequately satisfy a

22 general lighting application.
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1 So now we will discuss lamp types that DOE

2 has determined are not GSLs. As noted previously

3 the GSL definition explicitly excludes general

4 service fluorescent lamps and incandescent reflector

5 lamps. It also explicitly excludes the 22 exemptions

6 to GSILs stated in the GSL exemption and these are

7 listed in this table here.

8 DOE has the ability to evaluate whether

9 these 22 GSIL exemptions should be maintained,

10 however due to the Appropriation's rider it will not

11 be undertaking this evaluation in this rulemaking.

12 So DOE determined that the 22 exemptions

13 for GSILs do not automatically apply to all other

14 general service lamps. DOE evaluated exemptions that

15 are applicable to the other GSLs, such as CFLs and

16 LEDs. DOE based its determination of whether the

17 lamp type provided overall illumination and could

18 serve as a general lighting application.

19 The table here applies to all GSLs other

20 than the GSILs. The left side of the table shows

21 lamp types DOE determined should be exempt. The

22 right side of the table is a list of types that do
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1 not warrant exemption. 

2 Just a request for comments on the lamp

3 types DOE is considering to be exempt in particular,

4 requesting feedback on the three-way, vibration,

5 rough service and shatter-resistant.

6 MR. BROOKMAN: Let's go back to the

7 previous slide if you would Tom, pardon me, Dave,

8 sorry.

9 MR. GATTO: Not at all, Dave Gatto,

10 Westinghouse Lighting. You don't have to go back on

11 the slide, and I have to be honest because -- and I

12 knew you guys know that I have been very engaged in

13 the fan rulemaking -- I'm not as far along in getting

14 myself completely up to speed on the GSL rulemaking

15 although I've been reading it as quickly as I can.

16 One of the -- on the prior slide, operate

17 at any voltage -- I'm not sure that I understand how

18 you determined that lamps operating at any voltage

19 would fit general service lighting applications. I'm

20 not sure if you mean products that can be operated at

21 multiple voltages, like a dimmable product or if you

22 are talking about 3 volt, 6 volt, 12 volt, 24 volt,
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1 which tend to be more specialty. 

2 I want to understand that bullet on the

3 scope of coverage other lamps to make sure that I'm

4 clear what you are scoping in.

5 MS. HUSAIN: We are scoping in what you

6 noted the 12 volts would be included and we just

7 didn't use voltage as a specific criteria to restrict

8 the general lamp providing overall illumination. If

9 they are a specialty lamp, hopefully they have been

10 caught in the exemptions tables as we would probably

11 determine that they cannot provide overall

12 illumination. We didn't you know, take out lamps

13 specifically because of their voltage.

14 MR. GATTO: Dave Gatto, Westinghouse. 

15 Okay I think I understand that, right now that makes

16 sense to me so as we get there, there will be places

17 where if we see a product that is typically a

18 non-general service that happens to give an alternate

19 voltage, reading that line voltage it's most likely

20 already screened out and if not we would raise it up.

21 MS. HUSAIN: Yes.

22 MR. GATTO: Okay, thanks.
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1 MR. BROOKMAN: Thank you. Yes, Noah?

2 MR. HOROWITZ: Could you go to slide 18

3 please? Noah Harowitz with NRDC, I'd like your help

4 on the bullet that says utilize an ANSI base. How

5 would you think the agency would consider something

6 where you have an adapter that has a medium screw

7 base at the bottom and it could fit some new non-ANSI

8 base that's applied to some new bulbs by way of not

9 being covered by the regulations, so shouldn't it be

10 any base or why limit to ANSI and how would you treat

11 an adapter?

12 MS. HUSAIN: So the bulb would have a

13 non-ANSI base and you could fit -- have an adapter

14 that would fit it into an ANSI socket.

15 MR. HOROWITZ: Yes.

16 MS. HUSAIN: I think the idea was in this

17 criteria was to ensure that any lamp could fit in the

18 commonly found sockets so we can specifically look at

19 that scenario a little bit more closely.

20 MR. BROOKMAN: Any lamp would be included

21 in coverage.

22 MS. HUSAIN: Any lamp that would be
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1 included in coverage right now that would have an

2 ANSI base so technically if it has -- if it's able to

3 fit to an adapter that then can fit into an

4 ANSI-socket it would be included but I think we would

5 have to look at that more closely in that specific

6 scenario and we can provide clarification.

7 MR. BROOKMAN: Okay thank you, Dave

8 please?

9 MR. GATTO: David Gatto, Westinghouse. 

10 Actually it's -- maybe more for you to know are you

11 talking about a medium base socket adapter

12 specifically?

13 MR. HOROWITZ: What I'm getting at is you

14 know, today's conventional screw base fixture. Could

15 one create a bulb that has a non-ANSI base and have a

16 ten cent adapter that you put that into that then

17 goes into the existing fixture. And currently we are

18 not.

19 MR. GATTO: We make adapters so I can kind

20 of weigh in on this one and currently we are not

21 permitted to make any adapter that converts a medium

22 base socket to any other socket type. For that
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1 specific reason it was part of EPACT I believe.

2 MS. HUSAIN: Right.

3 MR. BROOKMAN: Lucy deButts?

4 MS. DEBUTTS: Sorry Lucy deButts, DOE. I

5 just found the guidance document on our guidance

6 database that says this is not allowed. 

7 MR. HOROWITZ: So maybe that could be

8 amplified in the following documents that would be

9 appreciated.

10 MS. HUSAIN: Sure.

11 MR. BROOKMAN: That's good, Joe Howley?

12 MR. HOWLEY: Joe Howley, GE Lighting. 

13 Just to further thoughts on this scope question DOE

14 seems to be applying an extremely large scope. Any

15 lamp that can provide general illumination is very

16 broad. The original intent of this was to look at

17 lamps that provided the highest volume and therefore

18 the highest potential for energy savings, that being

19 the medium screw-based lamps that are between 310 and

20 2600 lumens where the bulk of the general lighting

21 applications occur and where the largest potential

22 is. 
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1 So these are either products that go into

2 those medium screw-based sockets or can go into those

3 medium screw-based sockets, therefore CFLs and/or

4 LEDs that have the medium screw-based socket that

5 are meant to replace the huge number of sockets that

6 exist today that have medium screw bases in them so

7 in some extent and we will look at this further and

8 comment further but this approach we might argue is

9 actually too broad, too all-encompassing and it

10 really should be narrowed to where the large

11 potential for energy saving is and the large

12 potential for lamp use is.

13 MR. BROOKMAN: Okay, Don Brundage?

14 MR. BRUNDAGE: Don Brundage, Southern

15 Company. I would agree with this. I think the

16 intent of the legislation was for consumer products,

17 standard lighting. While there is a number of

18 exemptions in the EPACT that's not all-inclusive of

19 anything that produces light and if you do it too

20 broadly you may have some specialized industrial

21 applications with unintended consequences, thank you.

22 MR. BROOKMAN: Thank you. Additional
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1 thoughts yes Mike?

2 MR. MCGARAGHAN: Mike McGaraghan for the

3 California IOU's, I had a question about the term

4 general lighting application. It's defined in the

5 Federal Register as lighting that provides an

6 interior/exterior area with overall illumination and

7 I hate to get too far into the weeds here but does

8 anybody have a definition of overall illumination and

9 if the definition doesn't exist, can DOE provide its

10 own interpretation of overall illumination?

11 MS. HUSAIN: There isn't a definition of

12 overall illumination in the overall CFR. If it

13 would be helpful I think -- I guess we could look

14 into that.

15 MR. MCGARAGHAN: Thank you.

16 MS. HUSAIN: Did you have any specific

17 suggestions on what you were thinking of?

18 MR. MCGARAGHAN: No just the term comes up

19 a lot in the document and there's a lot of different

20 things it could mean so it would be great to hear

21 what -- you know how you are interpreting it.

22 MR. BROOKMAN: And what you're
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1 interpreting as well in your comments.

2 MS. HUSAIN: Yeah, what would be causing

3 like issues with someone mistaking it for something

4 that it shouldn't be or something.

5 MR. MCGARAGHAN: Understood.

6 MR. BROOKMAN: Additional thoughts here? 

7 A lot of content in these few slides, what is a

8 left-hand thread, just the other way huh? But why do

9 they do that? Sorry, I read that on here.

10 UNIDENTIFIED SPEAKER: South of the

11 equator.

12 MR. BROOKMAN: Okay, all right additional

13 thoughts on these that are exempted and not exempted? 

14 Okay, moving on.

15 MS. HUSAIN: So the lamp types identified

16 as GSLs DOE did not analyze certain ones in this

17 preliminary analysis. To determine which lamps to

18 analyze for each lamp type DOE looked at the

19 following criteria: whether the standards for a lamp

20 type would result in significant energy savings;

21 whether improvements in efficacy while maintaining

22 lamp utility were technologically feasible and
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1 whether the lamp is subject to restrictions from the

2 Appropriations rider.

3 So the next slide will summarize -- this

4 slide summarizes the different types of integrated

5 GSLs and specifies whether DOE analyzed them in the

6 preliminary analysis. The ones that are analyzed are

7 shown in dark green. 

8 Okay this slide shows the non-integrated

9 GSLs and again the ones that are analyzed are shown

10 in dark green, mainly the pin base CFLs.

11 MR. BROOKMAN: Don Brundage?

12 MR. BRUNDAGE: I think one general concern

13 I would have is with this caveat of not being able

14 to change standards on incandescents. Assuming that

15 continues forward in time it does -- the main thing

16 is you need to be cautious about setting standards

17 too high on CFLs and LEDs with the potential of

18 encouraging more people to use the incandescent

19 technologies. 

20 I mean you have no control over that it's

21 exempted and then afterwards it's some way treated as

22 a different class that you can't touch but there -- I
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1 did have concerns setting the standards on CFLs too

2 high will encourage more of the 72 watt incandescent

3 replacement type of bulbs which use more energy. 

4 That's just something to consider when you compare

5 the economics of alternatives, thank you.

6 MR. CYMBALSKY: This is John from DOE. 

7 Can you kind of quantify what you mean by too high it

8 would be helpful? A number would be good.

9 MR. BRUNDAGE: Well one of the problems I

10 have with just glancing through this analysis is I

11 feel like there is a lot of overly optimistic

12 assumptions embedded in the study. You have got lamp

13 lives of like 17 years in a home environment. I'm

14 not sure any lighting product is going to last 17

15 years. There are lots of reasons other than -- lots

16 of reasons lamps can fail or be replaced. I think --

17 I don't have a specific number but I've seen a lot of

18 optimistic assumptions how long the products will

19 last which are not realistic in this type of consumer

20 environment and just I would -- I don't have a

21 specific number but I think there needs to be caution

22 here.
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1 MR. BROOKMAN: Additional comments here,

2 yes Mike?

3 MR. MCGARAGHAN: Mike McGaraghan for the

4 California IOU's and I had that same concern

5 originally and I guess what I was thinking DOE's

6 response would be I want to throw into the mix here

7 to confirm it. But my understanding is that DOE

8 structured this whole analysis on the premise that

9 the back stop will kick in at 45 lumens per watt so

10 the concern that you raised would be taken care of by

11 the back stop. Please correct me if I'm wrong DOE.

12 MR. CYMBALSKY: Yes so the back stop is

13 the rock right so that happens if DOE doesn't do

14 anything so yes, that has to be factored into the

15 analysis. That's why the reason for my asking what

16 too high was.

17 MR. BROOKMAN: Thank you John. Additional

18 thoughts, comments here before we move on? 

19 MR. CYMBALSKY: I did I wanted to comment

20 on Don's lifetime question since we have a few

21 manufacturers here in the room. Are you suggesting

22 that the rated lifetime on some of the products is
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1 too high or are you saying that there are just kids

2 knock over a lamp and cause them to fail prematurely

3 or -- because I have some incandescent bulbs in my

4 house that are 14 years old now, came with the house,

5 they are in places that don't get used very often but

6 there's a 60 watt lamp in my attic that I turn on

7 once a year and it's 14 years old and still going so.

8 MR. BRUNDAGE: Don Brundage. It's not

9 that they don't last the rated condition, the lab is

10 that a consumer home environment is a more hostile

11 environment and I don't think lamps necessarily are

12 going to last as long as being shown in the analysis.

13 MR. BROOKMAN: Keith?

14 MR. COOK: Keith Cook with Philips. The

15 problem we have got is the fact that so much is

16 predicated upon lumen maintenance and the life has

17 been tied into this lumen maintenance even though the

18 rest of the electronics, there's no standards yet for

19 measuring the life of those and so the result I think

20 some of the products they are coming out today where

21 they are trying to get the cost down, I don't know

22 that they are going to last a long, long time. 
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1 They may have good lumen maintenance but

2 the rest of the electronics is suspect and until we

3 come up with a standard on how to measure that I

4 can't tell you how long they are going to last.

5 MR. BROOKMAN: Yes please Dave?

6 MR. GATTE: Dave Gatte, Westinghouse. 

7 Yeah, I think I'm kind of where Keith is in there's a

8 component issue that we are still working out and

9 there are some -- I saw some of our Caliper results

10 last week. In real life a fixture might get

11 replaced, some consumers will keep the bulb that they

12 had some of them won't. Some of them will be buying

13 integrated SSL fixture so that bulb may not go into

14 another socket because they don't have another socket

15 to put it in.

16 I do think and it just came up in the fan

17 rulemaking that as DOE finalizes standards, Keith

18 talked about this in the last lamp meeting, there's a

19 balancing act that we all kind of follow which is

20 life, lumen maintenance, component cost, consumer

21 price. Consumer price for LED, particularly LED is

22 the single largest obstacle to adoption. It doesn't
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1 have all the hair CFL does, people want to buy it so

2 as prices come down consumer adoption goes up.

3 One of the ways prices come down is if you

4 are going to put 15,000 hours on the lamp or 25,000

5 hours on the lamp instead of 50 or 100 you can select

6 components that might fail sooner in a not once a

7 year application like you described John, where maybe

8 they are in an outdoor light that is on 10 hours - 12

9 hours a day or in a commercial application so I would

10 just kind of reiterate what Don said it isn't that I

11 think that product won't last we should be cautious

12 in setting standards that we can find that balance of

13 product quality, energy savings and a price consumers

14 can live with because I think that's what is going to

15 make the difference on the energy savings you guys

16 want to derive.

17 MR. BROOKMAN: Okay Joe?

18 MR. HOWLEY: So just one last and Joe

19 Howley, GE -- one way to think about it is a lamp

20 might last 17 years but you can't assume that every

21 lamp placed in a socket will last 17 years. So if

22 the analysis is based on every single lamp that goes
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1 in goes 17 years that analysis is probably a stretch

2 in terms of what you are really going to experience.

3 What the overall market is really going to

4 experience over that time period so there has to be

5 some allocation for the fact that some will last a

6 much shorter period of time then that length of time.

7 MR. BROOKMAN: Keith you have additional

8 comment? Noah?

9 MR. HOROWITZ: Noah Horowitz with NRDC. 

10 In terms of how long a bulb is going to last, a bulb

11 might be rated to last 25,000 hours hence how the

12 person uses it, did they leave it on all the time or

13 3 hours a day. We are talking about averages here in

14 general and to the extent Don you are right that the

15 bulb is taken out at year 12 instead of year 17 for

16 whatever reason. I don't think that should change

17 the assumptions we are making here because what bulb

18 -- 12 years from now if that bulb was replaced it's

19 probably going to be replaced with a bulb as

20 efficient or even more efficient in the future as

21 LEDs become more efficient and lower cost so I don't

22 think we need to throw out all the assumptions here
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1 and make them much shorter.

2 MR. BROOKMAN: Yes Tom Eckman? We have a

3 comment from --

4 MR. GERKE: Yeah this is Brian Gerke from

5 LBNL. Most of the issues that have been brought up

6 so far in this discussion about lifetime are

7 considered in developing the lifetime model and we

8 will discuss that more this afternoon.

9 MR. BROOKMAN: Okay, thank you for that

10 Tom Eckman?

11 MR. ECKMAN: Yeah I just want to note that

12 if in fact cost reduction is the driver that also

13 plays into the economics because if costs go down,

14 the lifetime can go down and you still get the same

15 lifetime result. So there's a trade-off between

16 maintaining one life and reducing the cost. If that

17 goes down linearly the results are unchanged

18 economically so there's that connection between the

19 two. I don't know whether it is or not but if the

20 principal driver is costs which I think I agree it

21 is, then whether the lifetime sustains itself or not

22 becomes less important.
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1 MR. BROOKMAN: Alex Boesenberg?

2 MR. BOESENBERG: Alex Boesenberg, NEMA. 

3 One addendum to that statement is that if the cost

4 spurs increased adoption we offset more less

5 efficient sockets so it does have an overall benefit. 

6 I mean it happens in my own home, I didn't start

7 buying LEDs until this year when they got below

8 $8.00.

9 MR. BROOKMAN: Okay, additional thoughts

10 on this subject matter noting that more detail is

11 coming later on in the presentation, okay, Aisha?

12 MS. HUSAIN: Okay we also wanted to note

13 that in general for all types of GSLs, DOE is not

14 considering standards for GSLs with lumens greater

15 than 2600 because the GSLs with luminants greater

16 than 2600 are currently exempt and DOE cannot

17 re-evaluate this exemption setting standards are in

18 this rulemaking.

19 Setting standards for other lamp types

20 with high lumens could result in a shift to the

21 exempt high lumen GSLs potentially increasing energy

22 consumption.
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1 Okay so we have a few requests for comment

2 here, a request for comment on not including lamps

3 that are covered in other rulemakings which is one of

4 the criteria that we used. We also -- we didn't

5 discuss this but we also assessed that's the LED MR16

6 lamps are currently not suitable replacements for the

7 incandescent and halogen MR16 lamps and would request

8 comment on that.

9 Also, any data on market share for

10 integrated lamps with bases other than screw bases

11 and then the last request comment and market share

12 data for non-integrated lamps with bases other than

13 screw bases and pin bases would be helpful.

14 MR. BROOKMAN: Yes please Dave?

15 MR. GATTO: Dave Gatto, Westinghouse

16 Lighting. Well something else I just want to thank

17 and acknowledge to you we agreed with not considering

18 products that are covered under another rulemaking. 

19 This is already complicated enough without making it

20 even worse.

21 MR. BROOKMAN: Okay, Joe Howley?

22 MR. HOWLEY: And further so that's issue
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1 5. Issue 6 we would also agree that MR16 lamps

2 should not be covered in this rulemaking and there

3 are still being developed to be a suitable

4 replacement for the other technologies and on the

5 non-integrated lamps, there are certain types like

6 the GU24 pin based that are designed to go in similar

7 fixtures, integrated GU24's as screw base lamps. 

8 However, the pin based lamp category for CFLs

9 generally are not a replacement for a screw based

10 integrated lamp. 

11 Pin based go in dedicated fixtures and

12 dedicated ballasts are mostly for the most part

13 commercial products. Consumers are not buying these

14 and these have been around for probably 20 years or

15 so and they have never been used to any large extent

16 by homeowners, nor are they easy for use as a

17 replacement. You would have to buy a dedicated

18 fixture to use them and these fixtures just are not

19 that popular. They are popular commercially but they

20 are not that popular residentially and we would not

21 support including these -- I know you proposed this

22 as one of your classifications but this is not an
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1 area that we think makes sense as a reasonable

2 replacement for again screw based lamps that are

3 between 310 and 2600 lumens, operating 120 to 130

4 volts, these pin-based technologies just are not a

5 good replacement for that or they would have been

6 used in those applications many years ago. There are

7 a lot of reasons why they are not used in those

8 applications.

9 MR. BROOKMAN: Okay Keith Cook?

10 MR. COOK: Yes it's really what Joe said. 

11 This is Keith Cook from Philips. It's not money you

12 can't take a conventional layout that's got a screw

13 in base and replace it with one of these pin bases,

14 you just physically cannot do it so it doesn't really

15 meet the definition of general service.

16 MR. BROOKMAN: Additional thoughts,

17 comments here. Did we address issue 7 sufficiently? 

18 Additional thoughts, okay.

19 MS. HUSAIN: So in summary DOE is

20 considering establishing standards for the following

21 GSLs: the integrated non-reflector medium screw

22 base lamps with the lumen output between 310 and 2600
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1 lumens; the GU24 base lamps with the same lumen

2 output; the non-integrated, non-reflector pin based

3 CFLs with the same lumen output range.

4 MR. BROOKMAN: Yes Noah?

5 MR. HAROWITZ: Noah Harowitz with NRDC. 

6 We understand the rulemaking is complicated by the

7 existence of the rider. To overstate the obvious to

8 the extent the rider goes away we would expect DOE to

9 review the coverage here of other base types, lumen

10 outputs above 2600 for example and other things.

11 MR. BROOKMAN: Okay. 

12 MS. HUSAIN: So here we wanted to note

13 some of the definitions that we are considering in

14 this rulemaking to support the standards. These are

15 listed here and we would request comment on these

16 definitions for the terms in particular DOE requests

17 comments on the definition of colored lamp which DOE

18 is considering defining as a lamp having a CRI less

19 than 40 or having a CCT that is less than 2200K or

20 greater than 7000K.

21 MR. HOWLEY: So on the colored lamp

22 specifically we will have more comments, we need to
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1 review these definitions more within the industry and

2 will provide some comments in our written comments

3 but just a reaction on the colored definition. That

4 definition has been used successfully for linear

5 fluorescent lamp technology since I think '95 and it

6 does tend to push lamps into areas that define the

7 colored space or what people view as not white light

8 anymore but colored light and so it would seem

9 logical that it would continue to work for either

10 compact fluorescent and/or for LED for similar

11 reasons.

12 MR. BROOKMAN: Additional thoughts on

13 definitions at this point? Noting that this is the

14 kind of thing that DOE really appreciates your

15 detailed written comments on, yes additional thoughts

16 before we move on? Okay.

17 MS. HUSAIN: So now we get into the

18 metrics for medium based CFLs. As mentioned there

19 are already standards in place for medium based CFLs

20 in addition to efficacy these include lumen

21 maintenance at 1,000 hours, lumen maintenance at 40%

22 of rated life, rapid cycle stress test and lifetime.
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1 In this rulemaking DOE has the ability to

2 revise these existing 5 metrics and can consider

3 adding CRI, power factor, operating frequency, start

4 time and also any other metrics that would save

5 energy, be cost effective and improve consumer

6 satisfaction. So DOE is considering changes to

7 medium base CFL metrics and these are shown in this

8 table so the existing standard column is what is

9 existing and the next column shows what is being

10 considered.

11 As a change in this rulemaking DOE is

12 considering revising the existing efficacy

13 requirements for medium based CFLs and will outline

14 these more in the engineering discussion. We are

15 also considering maintaining the current lumen

16 maintenance requirements and they adequately capture

17 issues of lumen depreciation. 

18 DOE is considering updating the rapid

19 cycle stress test requirements and lifetime

20 requirements. Additionally DOE is considering adding

21 requirements for power factor, CRI and start time and

22 DOE has found that the majority of medium based CFLs
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1 on the market meet these requirements and further the

2 updated and new metrics also align with Energy Star

3 and the market tends to shift towards products that

4 can meet Energy Star requirements.

5 So issue 8 is a lot of requests for

6 comments on these changes, the metrics.

7 MR. BROOKMAN: Dave? Let's go back to the

8 preceding slide.

9 MR. GATTO: Thanks you did it, so Dave

10 Gatto, Westinghouse. Just a question can we define

11 or has it been defined, and it might be in the TSD I

12 apologize I haven't finished the whole thing but

13 what you mean by fully illuminated because one

14 second start times per CFL is fine but to be at 100%

15 of rated lumens I have to go back and look at that. 

16 Energy Star thinking -- somebody may be

17 more familiar, I think it's 80% you are for instant

18 start is 80% of lumen output at 1 second or less so I

19 just want to make sure that if we use that definition

20 that we are real clear about what we mean by it or

21 you are going to find that there aren't any products

22 that meet it anymore.
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1 MR. BROOKMAN: Okay thank you. Joe do you

2 want to --

3 MR. HOWLEY: Yeah again this is something

4 I think we need to have more discussion within the

5 industry on these points. I will note that

6 traditionally we have set the life -- the minimum

7 federal life a couple of thousand hours under Energy

8 Star. So for many years it was 6,000 hours minimum

9 to sell an 8,000 for Energy Star. Energy Star is

10 supposed to be promoting a higher quality type of

11 product and we may want to still continue to leave

12 some space on the lifetime of 2,000 hours since

13 Energy Star currently is at 10,000 and perhaps a

14 better minimum life to sell would be 8,000 again

15 leaving some separation between some of the minimum

16 qualities to sell versus the Energy Star premium

17 qualities to sell. We will discuss this in industry

18 and have more on our written comments.

19 MR. BROOKMAN: Okay Noah?

20 MR. HOROWITZ: Noah Horowitz, NRDC. We

21 support the updating of the performance requirements

22 for CFLs and the intent of aligning with Energy Star
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1 we think is the right one. In terms of power factor

2 we will be providing additional comments regarding

3 the proposal of .5. Not shown here is to take a look

4 at the test methods, the current language I believe

5 often used is the sample size of 5 and Energy Star is

6 up to 10 so we need to reference the current test

7 methods not the one that was based on earlier

8 legislation, thank you.

9 MR. BROOKMAN: Thank you, okay. Yes

10 Keith?

11 MR. COOK: Keith Cook with Philips. I'm a

12 little concerned with what Noah just stated. He

13 pointed out that there is alignment with Energy Star

14 and my concern is the fact that Energy Star by

15 definition is supposed to only represent the top 25%

16 of the marketplace as far as performance is concerned

17 so now all of a sudden we have thrown away 75% of the

18 products. This is a major concern I think.

19 MR. BROOKMAN: You see the comment boxes

20 there on slide 31.

21 MR. HOROWITZ: Doug if I can offer a

22 follow-up to that?
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1 MR. BROOKMAN: Please Noah.

2 MR. HOROWITZ: Noah Horowitz with NRDC. I

3 appreciate Keith's comments. Hopefully as part of

4 the analysis DOE could take a look at the CFL market

5 and see what the market share of Energy Star

6 qualified products are but I think we will see it's

7 very much higher than 25%, it's probably 75% or some

8 number like that.

9 MR. HOWLEY: Joe Howley, GE. Just to

10 follow-up on that I believe that probably was true in

11 the past but Energy Star just went into lamps 1.0 or

12 1.1 now, it's a brand new specification. I think

13 it's unclear today as we move into application of

14 this new standard what percentage it is going to

15 represent so maybe a lower percentage, but that's an

16 evolving issue right now.

17 MR. BROOKMAN: Okay, thanks. Yes Don

18 Brundage?

19 MR. BRUNDAGE: One final comment on Energy

20 Star. There are times that Energy Star has a high

21 percentage of the products on the market before they

22 re-do their standards but their long-term goals on
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1 the Energy Star program is priced on the market

2 closer to the 20% range so that you need -- there

3 needs to be some room for Energy Star.

4 MR. CYMBALSKY: This is John from DOE, so

5 there's nothing preventing DOE from setting standards

6 either at or beyond Energy Star. We've done this for

7 other products so the standards analysis takes into

8 account what Energy Star is, but the analytics and

9 the numbers will be what they be in the standards

10 setting process so it could be that we go higher than

11 Energy Star, there's nothing preventing us from doing

12 that.

13 MR. BROOKMAN: I want to make sure that we

14 cover as much as possible, all these points, any

15 additional thoughts especially on the final

16 paragraph, okay additional here Joe Howley?

17 MR. HOWLEY: Just one last thought, Joe

18 Howley GE. So DOE is setting energy efficiency

19 regulations and we recognize DOE wants to set similar

20 levels or why you might want to do that on energy

21 efficiency, but on these quality metrics I guess

22 that's where you see a separation with Energy Star
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1 and industry position would be that you would be at

2 or below any of these quality metrics which tend to

3 separate Energy Star. 

4 The quality metrics don't necessarily

5 affect the energy use of the product but they are

6 there for other reasons. I don't know if that

7 affects DOE's thinking or not or if they separate how

8 they view the energy efficiency metrics versus these

9 other non-energy efficiency related quality metrics.

10 MS. HUSAIN: I just wanted to note that

11 for lifetime we did look at products on the market

12 regardless of Energy Star qualifications and we did

13 find them at that 10,000 but a lot of the other

14 quality metrics aren't reported in like marketing

15 information for the lamps so if you have any input

16 there you can provide where the industry is for the

17 majority of the market or you think it is for those

18 other metrics, that would be helpful in your

19 comments.

20 MR. BROOKMAN: Thank you, okay we are

21 moving on.

22 MS. HUSAIN: Okay so the next slides will
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1 present methodology and results for the analyses

2 conducted in this preliminary analysis and these are

3 shown here in this diagram. And we will start with

4 the market technology -- the Market and Technology

5 Assessment and Screening Analysis, I keep going. So

6 the purpose of the Market and Technology Assessment

7 is to identify technology options that improve lamp

8 efficacy and to also determine product classes. 

9 Technology options identified are then evaluated

10 against four criteria which are that the option is

11 technologically feasible, that it is practical to

12 manufacture, and install, service on a commercial

13 scale. It doesn't have any adverse impacts on

14 utility to consumers or availability. It does not

15 have any adverse impacts on health or safety. 

16 Those technology options that are not

17 screened out are analyzed as design options in the

18 Engineering Analysis. 

19 So let's start with product classes. DOE

20 divided covered products into classes by type of

21 energy used, capacity of product or any other

22 performance related features such as those that might
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1 impact consumer utility. A separate standard has

2 been set for each of the categories of products.

3 In its rulemaking DOE is considering

4 separate product classes for integrated and

5 non-integrated GSLs. An integrated lamp contains

6 all components needed for starting and stable

7 operation while a non-integrated lamp can have

8 components that are external to it and designed to be

9 replaceable. 

10 Integrated lamps offer consumers a utility

11 in that they are compact in size and require one lamp

12 unit replacements. There is also an impact on

13 efficacy due to the additional components and

14 circuitry in integrated CFLs for example, which are

15 self-ballasted are likely less efficacious than

16 non-integrated CFLs which have an external ballast. 

17 DOE is considering establishing

18 definitions for integrated lamp and non-integrated

19 lamp as shown here in this rulemaking. 

20 MR. HOWLEY: Again, the industry will

21 provide more detailed comments on this but just my

22 first reaction on your non-integrated lamp is that
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1 that definition is way too broad. I mean saying that

2 it's not an integrated lamp means it's anything else

3 in the world and I think we need to provide within

4 the scope of what we are covering here what a

5 non-integrated lamp is, not just any other lamp

6 thanks.

7 MR. BROOKMAN: Thank you that will be

8 useful. Additional thoughts on these definitions?

9 MS. HUSAIN: For the integrated product

10 class DOE is also considering a product class

11 division based on lumen package. DOE found that high

12 lumen lamps currently on the market are not at the

13 same level of efficacy as the lower lumen lamps. 

14 High lumen lamps offer a utility in general lighting

15 application so DOE is considering a high lumen

16 product class for lamps between 2,000 and 2,600

17 lumens and the lower lumen product class would be

18 between 310 and 1,999 lumens. 

19 For the high lumen product class DOE

20 determined the lower bound of 2,000 based on the

21 lumens equivalent to 120 watt -- 125 watt

22 incandescents and this also aligns with the Energy
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1 Star 1.1 which defines 125 watt incandescent to be in

2 the lumen range of 2,000 and 2,549 lumens.

3 MR. BROOKMAN: Dave?

4 MR. GATTO: Dave Gatto, Westinghouse

5 Lighting. We -- so I would say I would agree that

6 lumen bins is the right way to go. I'm a little

7 concerned that and we can definitely within the

8 formal comments. I'm a little concerned with up to

9 1999 might be a little high, it's really for LED it's

10 a size issue so you can hit those numbers but clearly

11 you have found that for a general service application

12 you can't even find a lamp above 2,000 or likely you

13 can't find very many that's a medium base socket.

14 But even when you get above 1,600 - 1,800

15 lumens the physical size is the concern, it's not

16 going to fit so I just would ask DOE to consider to

17 try to provide some comments back through NEMA but

18 you might have set the bar a little too high just

19 because of the physical size considerations.

20 MR. BROOKMAN: Thank you, Joe?

21 MR. HOWLEY: I also note that the current

22 regulations also use a lumen bin type of approach but
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1 they have 4 lumen bins which more logically follows

2 the common lumen buckets used by consumers, that

3 being lumens at 40 watts, lumens at what were

4 traditionally provided by a 40 watt lamp, lumens

5 provided by a 60 watt, lumens provided by 75 watt and

6 lumens provided by 100 watt.

7 Although 2 bins are being proposed here,

8 it may be more logical to look at the 4 bins that are

9 being used today versus just 2 bins. Again we will

10 look at this more and provide some further comments,

11 thanks.

12 MR. BROOKMAN: Thank you Noah?

13 MR. HOROWITZ: Noah Horowitz with NRDC. 

14 We support the approach that is shown here. We are

15 open to further discussion and refinement if needed

16 of the upper-bound should it be 1999 or some slightly

17 lower number to match the market, we are not opposed

18 to that. We are opposed to the comment made by my

19 colleague from GE of going for 4 bins. We think

20 that's a mistake, the current standards have these 4

21 bins and we have seen a lot of gaming that's resulted

22 in the same of dimmer bulbs so we would as stated
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1 earlier prefer adoption of this approach and also

2 that the use of a smooth continuous curve for the

3 regulations, thank you.

4 MR. BROOKMAN: Thank you additional

5 thoughts, contributions on these points?

6 MS. HUSAIN: So now we will discuss

7 technology options. The following are technology

8 options DOE is considering for improving the efficacy

9 of CFLs. These include options such as highly

10 emissive electrical coatings, efficient fill gases

11 and phosphors. DOE also considered options of

12 improving the ballast components and ballast circuit

13 design which in turn improve lamp efficacy.

14 Another technology option is also a change

15 to a more efficient lamp technology such as LEDs. 

16 Of these options for CFLs DOE is screening out

17 multi-photon phosphors which is in red which consist

18 of emitting more than one visible photon for each

19 incident of UV photon -- this technology option is

20 screened out based on technological and feasibility

21 as it's still in the research phase. 

22 So also on this slide are technology
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1 options that can improve the efficacy of LEDs. 

2 These include options such as more efficient down

3 converters which convert the narrow wavelengths

4 emitted by LEDs into white light.

5 Another technology option is improved

6 package architecture. There is also technology

7 options aimed at improving the thermal management of

8 LEDs, improving driver efficiency and minimizing or

9 removing the use of secondary optics.

10 Of these LED technology options the ones shown in red

11 have been screened out so while efficient down

12 converters remain a design options, the use of

13 quantum dots as efficient down converters is screened

14 out due to technological infeasibility as it seems to

15 be still in the research phase.

16 Improved emitters were also screened out

17 based on technological infeasibility as research into

18 improving green emitter efficiency is still ongoing. 

19 AC powered LEDs which integrate power conversion

20 into the package that is requiring fewer additional

21 components and minimizing efficiency losses. 

22 Because AC LEDs are not currently
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1 integrated into lamps DOE screened out this

2 technology option due to practicability to

3 manufacturer install and service. 

4 So the next slide is just comments on

5 technology options, product classes, design options,

6 you can go back to this slide. 

7 MR. BROOKMAN: Yes Mike?

8 MR. MCGARAGHAN: Mike McGaraghan, one of

9 the California IOU's. My, excuse me, my read of the

10 TSD was that DOE did not screen out quantum dot and

11 nanophosphor technologies, has this changed since

12 the publication of the document or am I misreading

13 it, it says on page 2-47 there's a paragraph at the

14 top of that page that talks about various

15 technologies that have been introduced to the market

16 that DOE has confidence in.

17 MS. HUSAIN: I don't have it in front of

18 me but what I did hear was the efficient down

19 converters as a whole weren't screened out but the

20 specific use of quantum dots as an efficient down

21 converters were screened out because they were still

22 in the research phase. If it's -- I'm not sure if
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1 that's what maybe you are confusing. I would also

2 look at Chapter 3 it has a greater explanation.

3 MR. MCGARAGHAN: Okay thank you.

4 MS. HUSAIN: And Chapter 4 as well.

5 MR. BROOKMAN: And perhaps members of

6 industry could comment whether this is getting more

7 mainstream or whether it is still Joe?

8 MR. HOWLEY: Just an overall comment is

9 that CFL technology, many of these technology options

10 listed have been used over the years to improve the

11 efficiency of CFLs but they are certainly an older

12 technology now and there's very little space left in

13 that technology to continue to make large

14 improvements.

15 LEDs obviously are a newer technology

16 where there may be more technology advancements that

17 will occur but CFLs many of these have already been

18 attempted and optimized, general comment.

19 MR. BROOKMAN: Joe do you or someone else

20 want to comment on the LED technology options that

21 are listed? Noah?

22 MR. HOROWITZ: Noah Horowitz with NRDC. 
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1 In terms of quantum dots, new TV's are starting to

2 use quantum dots and have LED back lights so I

3 encourage the DOE to take a look at the availability

4 of quantum dot technology in LEDs and TV's. It's

5 not in the research phase those are starting to hit

6 the market are those technologies applicable to

7 general lighting applications, I don't know the

8 answer but it would be good to consider that.

9 MR. BROOKMAN: Charlie?

10 MR. STEPHENS: Charlie Stephens, NEEA. We

11 are talking here about a standard that is going to go

12 into effect in pretty much 2020, you know the

13 beginning of 2020 so I think in spite of the fact

14 that some of these technologies are early in the game

15 as Noah just pointed out they are in use in some

16 places, they are being developed and we've got

17 another year here to go between now and when DOE

18 publishes a NOPR and I think the stuff is moving fast

19 enough and being commercialized fast enough that

20 there will be more information available long before

21 the final rule becomes an issue so I would encourage

22 DOE to kind of keep an eye on all of this stuff and
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1 at least take into account all the information that

2 is developed between now and the NOPR.

3 MR. BROOKMAN: Okay thank you yes Keith?

4 MR. COOK: Keith Cook with Philips. Noah

5 is right quantum dots is being used in TV's. It is

6 being very closely monitored within the lighting

7 industry. The trouble is I can't sell a lamp for

8 thousands of dollars which they do on TV's. The

9 problem we got faced with is that we are trying to

10 maximize the adoption of this technology and by

11 increasing the cost we now go in the exact opposite

12 direction of where we need to be. 

13 As we try and look out further downstream

14 we don't know where quantum dots are going to be from

15 a cost perspective. Today it is prohibitive, but

16 somehow we have got to maximize energy efficiency

17 versus the market adoption of these technologies and

18 cost is number one in the market.

19 MR. BROOKMAN: Okay yes Mike?

20 MR. MCGARAGHAN: Mike McGaraghan, the

21 California IOU's and I appreciate Keith's comment. I

22 agree that cost is a really important consideration. 
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1 I just think that at this stage the screening

2 analysis cost is not one of the parameters that DOE

3 is supposed to consider in terms of whether or not a

4 technology option makes it even into the analysis.

5 And from my read maybe there's more detail

6 in Chapter 3 which I didn't see but in Chapter 2 DOE

7 makes that pretty clear. In all of these actually --

8 well I haven't found AC LEDs yet but quantum dot and

9 phosphor are proved emitter materials DOE has several

10 paragraphs outlining the reasons why it is including

11 them in this analysis and we support those reasons

12 for the same points that Charlie and Noah made. We

13 would encourage you to keep these at least at this

14 stage in the running for technology options.

15 MS. HUSAIN: Yeah all of these listed on

16 the table are included as technology options. The

17 ones -- the distinction is the ones in red are not

18 then included as design options and they are screened

19 out. From the design options are not based on cost,

20 but they are based on actually seeing a prototype or

21 finding these technology options used in lamps.

22 So like for quantum dots if they are used
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1 in other applications and can be used in lamps to

2 improve efficacy they would be considered as a

3 technology option, but we would want to see that they

4 can also be used in lamps or there is some prototype

5 or information available that could indicate that to

6 be considered a design option.

7 MR. MCGARAGHAN: So DOE found an R30 LED

8 lamp from Nexxus Lighting using quantum dots.

9 MS. HUSAIN: Yeah I think the issue with

10 that was that was no longer -- it was discontinued as

11 well.

12 MR. MCGARAGHAN: Okay.

13 MR. BROOKMAN: Additional thoughts on

14 these technology options?

15 MS. HUSAIN: So that is actually then the

16 end of Market and Tech.

17 MR. BROOKMAN: We may have covered the

18 comment boxes sufficiently.

19 MS. HUSAIN: Yeah sure.

20 MR. BROOKMAN: Why don't you put the

21 comment box back up there take a peek see if there

22 is any additional thoughts on these before we move
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1 on, okay let's move on.

2 MS. HUSAIN: So I'll hand it over to

3 Maureen for Engineering.

4 MS. KIENLE: All right good morning my

5 name is Maureen Kienle and I'm with Navigant. We are

6 going to get started with the Engineering Analysis

7 now. Sure -- DOE used the following general

8 methodology to develop the engineering for GSLs. Of

9 the product classes identified DOE first selected

10 representative classes to directly analyze. DOE then

11 selected baseline lamps for each representative 2*

12 product class to use as reference points.

13 After that for each baseline lamp DOE

14 identified more efficacious substitutes based on

15 design options identified in the Screening Analysis. 

16 DOE then developed candidate standard levels or CSLs

17 that span the range of efficacy from baseline to the

18 maximum technologically feasible level. 

19 Finally DOE would then scale results to

20 product classes not directly analyzed if needed. 

21 However, in this preliminary analysis DOE directly

22 analyzed all product classes and therefore no scaling
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1 was necessary.

2 As stated earlier DOE is considering

3 standards for three product classes. Integrated

4 GSLs with lumen output from 310 to 1,999 lumens,

5 integrated GSLs with lumen output from 2,000 to

6 2,600 lumens and non-integrated GSLs with lumen

7 output from 310 to 2,600 lumens.

8 DOE is considering directly analyzing all

9 product classes based on market volume and unique

10 technical characteristics. DOE next identified

11 baseline lamps for each product class. The baseline

12 lamp typically represents the most common least

13 efficacious model on the market that just meets

14 existing energy conservation standards when

15 applicable.

16 On this slide the baseline lamps with the

17 integrated low lumen and integrated high lumen

18 product classes are listed. On this slide sorry --

19 DOE first determined the most common characteristics

20 of the product classes such as lumen output range,

21 CCT and lifetime. 

22 Then among lamps with those
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1 characteristics DOE selected the least efficacious

2 product that met existing standards for medium based

3 CFLs as the baseline in each product class.

4 The baseline lamp for the integrated low

5 lumen product class which is listed on this slide

6 first is the 60 watt equivalent replacement lamp

7 which typically has a lumen output in the range of

8 700 to 900 lumens. The baseline lamp for the

9 integrated high lumen product class is a 125 watt

10 equivalent replacement which generally has a lumen

11 output in the range of 2,000 to 2,600 lumens so

12 that's the second one listed. 

13 On this slide the baseline lamp for the

14 non-integrated product class is listed. The same

15 methodology was used as the integrated product

16 classes to select the baseline lamp. DOE identified

17 the common characteristics of the non-integrated

18 product class and then among those lamps selected the

19 least efficacious product on the market, since the

20 product class does not have any applicable existing

21 standards.

22 In Issue 13 DOE requests comment on the
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1 baseline unit selected for each of the product

2 classes. 

3 MR. BROOKMAN: What are your thoughts on

4 these baseline units? Nothing here, yes Noah?

5 MR. HOROWITZ: If you could go to Slide

6 42. Noah Horowitz, NRDC. I'm curious for the

7 integrated low lumen row is that meant to be the

8 equivalent of the conventional 60 watt light bulb and

9 if so you are showing initial lumens of 750?

10 MS. KIENLE: Yes.

11 MR. HOROWITZ: And the conventional

12 incandescents were 800 - 850 lumens?

13 MS. KIENLE: We found that in general as a

14 range so like I mentioned around 700 to 900 lumens

15 was about where we were seeing the traditional 60

16 watt incandescents and their equivalent replacements

17 so this is on the I guess the lower end of that range

18 but it still seemed to be generally acceptable.

19 MR. BROOKMAN: Additional thoughts on

20 these baseline units? 

21 MR. HOWLEY: This is just a question about

22 how this would work so if you go into the lower lumen
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1 ranges you are going to have lower efficiency. Does

2 the curve that you are creating is it sort of

3 centered then this part of the curve is set up at the

4 750 lumen range or how does that work?

5 MS. KIENLE: Right so we actually have a

6 graph of the curve later so it's probably a bit

7 easier to see. We have the lamps plotted against

8 that but what you will see is that it is continuous

9 and it picks up you know starting at -- we don't

10 actually graph where the baseline lamp is but it does

11 account for that, what that wattage is so all of the

12 wattages are covered which is lumen output in this

13 case on our X axis.

14 MR. HOWLEY: So where that lumen output is

15 that matches the curve. Or the curve matches this

16 efficiency I guess for a 750 lumen lamp.

17 MS. KIENLE: Right so like I said we don't

18 draw a curve at the baseline but it will account for

19 you know that range of lumen output yes.

20 MR. BROOKMAN: Okay.

21 MS. KIENLE: Okay so DOE next identified

22 more efficacious substitutes for each baseline lamp
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1 selected. When identifying more efficacious

2 substitutes DOE selected lamps that either saved

3 energy or did not increase energy consumption

4 compared to the baseline, had light output within 10%

5 of the baseline lamp or lamp system when possible

6 and had characteristics similar to the baseline lamps

7 such as the base type.

8 In the integrated product classes the DOE

9 also ensured that more efficacious LED substitutes

10 were omnidirectional in order to maintain the even

11 distribution of light output and ensure that the

12 lamps can be used in the same application as the

13 baseline lamps.

14 The table on the slide presents the more

15 efficacious substitutes for the integrated low lumen

16 and the integrated high lumen product classes. The

17 baseline lamps for each product class are the lighter

18 shade of green and the substitute lamps are shaded

19 darker green. As you can see on the integrated low

20 lumen product class the baseline and the first

21 substitute lamp are CFLs the remaining more

22 efficacious substitute in the product class are LED
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1 lamps.

2 In the integrated high lumen product class

3 the baseline and its more efficacious substitutes are

4 all CFLs. In both product classes wattage decreases

5 for each more efficacious lamp replacement. 

6 The more efficacious of the two identified

7 in the non-integrated product class are presented on

8 this slide. The baseline lamp again here is the

9 lighter shade of green. The baseline lamp and its

10 substitutes are a double tube, non-integrated CFLs

11 with G24Q-33 bases. The first more efficacious

12 substitute was the same wattage as the baseline but

13 has a higher lumen output and the second more

14 efficacious substitute has a lower wattage and a

15 slightly lower lumen output. The reduction in lumen

16 output from the baseline lamp to this reduced wattage

17 substitute is actually slightly greater than 10%.

18 And in Issue 14 DOE requests comment on

19 the criteria used in selecting more efficacious

20 substitutes and the characteristics of the lamps

21 selected. In particular, DOE is requesting comment

22 on the assumption that more efficacious substitutes
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1 may have lumen output within 10% of the baseline lamp

2 or lamp and ballast system.

3 And then for the integrated product class

4 DOE also requests comment on its assumption that more

5 efficacious substitutes must be omnidirectional. And

6 the last part of this request for a comment is for

7 the non-integrated product class. DOE requests

8 comment on its assumption that the base type must be

9 maintained for the more efficacious substitutes.

10 MR. BROOKMAN: Joe Howley?

11 MR. HOWLEY: Okay so a couple of comments,

12 Joe Howley GE. A couple of comments on the proposal

13 -- first I note that since your baseline lamp is a

14 covered CFL it seems like the next most efficient

15 lamp that you are listing there is a spiral CFL so

16 they are used in different applications for different

17 purposes and of course removing the cover from a CFL

18 lamp will increase its efficiency. You will get more

19 light out of it but a standard that basically removes

20 a lamp type you don't think is an appropriate

21 standard to go from a covered to a spiral and

22 basically claim energy savings based on that. They
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1 are two different lamps used for two different

2 purposes.

3 Then further having the class of CFLs and

4 LEDs in the same classification, not having them

5 separated, as you move up the chain you basically

6 eliminate the entire CFL technology, only LEDs can

7 meet those higher classes. It would seem more

8 appropriate to have 2 separate classes, one for CFLs

9 going to what their maximum technology would be and 1

10 for LEDs because they would have different baseline

11 lamps, they certainly would have different

12 efficiencies or projected efficiencies over time.

13 Putting them together essentially almost

14 says that you are looking at a situation again where

15 you eliminate a product class and I believe that's

16 one of the criteria is not to eliminate an entire

17 product class with this regulation.

18 On the pin based, I note that there are 2

19 options there. One has slightly higher lumens but

20 the same exact wattage with that kind of calculation

21 no energy is saved. You do get a slightly more

22 efficient lamp but a 26 watt lamp for a 26 watt lamp
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1 is still 26 watts.

2 Then going to the next stage where you

3 simply drop the wattage to a lower wattage lamp and

4 lower lumens beyond 10% we also don't believe it is

5 an acceptable substitute. A lot of these are

6 commercial applications that are designed to very

7 specific light levels for specific application needs. 

8 There may be the OSHA requirements for light levels

9 in these hallways or wherever these are used which is

10 very common.

11 Dropping them below 10% also is not a

12 viable option from our standpoint. That being said

13 we clearly do not believe there are significant

14 opportunities to save energy in a pin based area and

15 also continue to have the view that the pin based

16 lamps really should not be included in this analysis

17 which is aimed at primarily screw based medium screw

18 based lamps.

19 MR. GATTO: Dave Gatto, Westinghouse

20 Lighting. I kind of second Joe on the CFL piece

21 having two product classes might make more sense. 

22 One of the concerns I would have in the way this is
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1 laid out and it's even in the TSD that you are

2 considering LED as a replacement option -- it's one

3 of the technology options to replace CFL. The volume

4 of integrated CFLs, screw based CFLs, is in those

5 lower lumen bins so the challenge that you would

6 create there is that if you eliminate that product

7 class but you still need the higher lumen bins to be

8 available to consumers, I don't know that from a

9 manufacturing standpoint whether the economy of scale

10 still exists because you are taking that really the

11 13 watt is the biggie but the 13, 18, 23 watt away

12 but you are still expecting the manufacturers and

13 consumers to have availability of 32 watt lamps so I

14 would just be cautious of that.

15 I hadn't really thought about it until I

16 heard Joe speak it and it hit me that you could end

17 up eliminating so much of the volume associated with

18 these particular products that the one that you want

19 to preserve gets kind of caught in the backlash.

20 The other thing is on pin based and I'm

21 not the expert here but you either have no energy

22 savings in the first example or I don't believe 10%
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1 of more is acceptable to consumers but even if it is

2 these are ballast driven products so I don't know

3 particularly in the 2 pin application if you can

4 actually put a reduced wattage lamp in and have it

5 operate properly.

6 4 pin lamps they can be dimmed so I'm

7 assuming that there's a little bit more flexibility

8 there but the 26 watt 2 pin that you selected that

9 moving toward the lower wattage might not actually be

10 technically feasible.

11 MR. BROOKMAN: Additional thoughts.

12 MS. KIENLE: Okay non-integrated CFLs

13 operate on a ballast in practice therefore DOE

14 analyzed lamp and ballast systems in the Engineering

15 Analysis in order to capture real world energy use

16 and light output.

17 As discussed in the scope section DOE is

18 not currently considering establishing standards for

19 non-integrated LED lamps and therefore only considers

20 non-integrated CFL and ballast systems in those

21 analyses. DOE used manufacturer input and conducted

22 a survey of the market to determine the most common
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1 non-integrated CFL ballast by starting method number

2 of lamps operated, and mode of operation.

3 As a result of this assessment DOE

4 determined that one lamp program start electronic

5 ballast are the most common ballast type paired with

6 non-integrated CFLs in the market today.

7 When developing lamp and ballast systems

8 DOE tried to select a ballast model to pair with

9 lamps that would be representative of the system that

10 would most likely to be installed in 2020. The same

11 ballast model was paired with each of the

12 representative units analyzed. 

13 When identifying a ballast model DOE found

14 that the vast majority of non-integrated CFLs had a

15 normal ballast factor and therefore selected a

16 ballast model with a ballast factor of around 1 as

17 noted on the slide. 

18 DOE also selected a ballast model of

19 average efficiency measured in terms of ballast

20 luminous efficiency or BLE. After selecting the

21 ballast model DOE then calculated the input powers of

22 the systems which are shown on the slide here. 
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1 In Issue 15 DOE requests comment on the

2 lamp and ballast systems selected for the

3 non-integrated product class.

4 MR. BROOKMAN: Joe?

5 MR. HOWLEY: Joe Howley, GE. I just will

6 note on these systems is that the ballasts are

7 usually paired with the lamp so the ballast is

8 designed to either operate a very specific wattage 4

9 pin lamp or a very specific 2 pin lamp. They often

10 would have a very specific base and this is to keep

11 lamps from being improperly put on the wrong ballast

12 because the ballast is expecting to see a 26 watt

13 lamp or an 18 watt lamp and so the base are pinned in

14 such a way and keyed in such a way that they don't

15 fit within one another so it prevents a maintenance

16 person from sticking or putting an 18 watt lamp --

17 let's say on a ballast or on a fixture that is

18 designed for a 26 watt lamp because it would

19 overdrive that lamp and produce other potential

20 safety and performance issues.

21 And so the key -- there's a fairly

22 sophisticated key way system used in these pin based
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1 lamps to keep them from being interchangeable so they

2 are not interchangeable which gives you again very

3 little opportunity, very few options to save energy

4 in this pin based ballast application area.

5 MR. BROOKMAN: Keith?

6 MR. COOK: Keith Cook with Philips. If

7 you are assuming and rightly so that a ballast has to

8 go with a particular lamp, if you then are requiring

9 that if you replace the lamp with a more efficacious

10 lamp you have to replace the ballast. A large

11 percentage of these things are in can lights and it's

12 almost impossible to get to that ballast so this

13 would be a major problem.

14 MR. BROOKMAN: Okay thank you. 

15 MS. KIENLE: Yes so I just wanted to

16 clarify quickly just for this example. Our

17 representative system, we insured that that ballast

18 was compatible with the 26 watt and the 21 watt that

19 was used so we are assuming that you wouldn't

20 actually have to replace the ballast but we can

21 certainly take that into consideration that if you

22 had an application where you would that it would be
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1 pretty difficult.

2 MR. BROOKMAN: Dave?

3 MR. GATTO: Dave Gatto, Westinghouse

4 Lighting. I think the concern I have there is that

5 we would be expecting the user to know and that's

6 almost impossible. It's not the kind of information

7 that they readily have available especially in an

8 installed fixture system. One to one they

9 understand, when you send somebody in and now they

10 have to pick a lamp that may or may not work with

11 their ballast, and may or may not present a safety

12 issue if it doesn't work that would be a big concern

13 for me.

14 That you are making an assumption here, at

15 least it seems like you are that the consumer would

16 know whether or not they could swap out lamps and if

17 a standard is passed where the original wattage isn't

18 available then to Keith's point you are now in a

19 situation where the consumer would be forced to put a

20 new fixture in. These are not typically field

21 replaceable ballasts.

22 MR. BROOKMAN: Charlie Stephens?
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1 MR. STEPHENS: Charlie Stephens, NEEA. I

2 guess I have to ask a question then what I am looking

3 at here is -- or what I saw was nominal rated or

4 rated wattage and nominal wattage and I'm looking at

5 a G24Q-3 base and I'm looking at a lumen -- a nominal

6 lumen range so if I own one of these cans and I go to

7 my local wattage supplier are we suggesting that if

8 he hands me one of these lamps it might not work?

9 MR. BROOKMAN: Dave?

10 MR. GATTO: Dave Gatto, Westinghouse. 

11 Yeah Charlie I'm not 100% sure but I believe and this

12 is in the TSD typically consumers -- because of that

13 concern whether to a maintenance guy, an electrician,

14 this is not really a consumer product or residential

15 product, they are replacing wattage for wattage

16 because they either know they can or they are afraid

17 to try, does that make sense?

18 MR. STEPHENS: It kind of does except you

19 know I own some of these and when I go to replace the

20 lamps I'm looking for a G24Q-3, 4 in my case, base. 

21 I'm looking for a particular base and a particular

22 lumen range to replace what I have. I don't actually
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1 look at the wattage.

2 MR. GATTO: But I guess my question would

3 be are you looking at lumen range?

4 MR. STEPHENS: Yeah.

5 MR. GATTO: Typically the packaging has

6 that information but wattage is the -- my

7 understanding of it again I can let anybody explain

8 here that the average replacement purchase it is

9 wattage based, at least that's my understanding and

10 that's suggesting that that's not always the case and

11 possibly not yours but I think where I get a little

12 nervous is we are assuming everyone is as

13 knowledgeable and educated as you are and that should

14 be a call to service.

15 MR. STEPHENS: Well actually I think I

16 agree with you when it comes to screw ins but you

17 know you discover fairly quickly if you own one of

18 these things that if you don't get the base right you

19 know what Joe was eluding too with all of these --

20 the questions knobs and things that stick out and

21 have to fit in the slot and everything else. If you

22 don't get that right it doesn't work but if you do
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1 get it right I presume it's going to work so to me if

2 it's got the right base and it fits into the socket

3 and the lumen range that's why I use that if it's got

4 the right base and it fits in there then I assume

5 it's going to work with my ballast and if it's got

6 the right -- approximately the right lumens then it's

7 the right lamp.

8 What I'm hearing right now is that maybe

9 it's not.

10 MR. GATTO: Yeah Dave Gatto, Westinghouse. 

11 As I said earlier I'm definitely not the expert here. 

12 We make the lamp but not the ballast. My experience

13 has been that we have had customers try and fit the

14 wrong bulb in the wrong ballast and had the bulb come

15 back so I don't make ballasts, I don't know whether

16 or not it's always true that if it fits the base it

17 works with the ballast. I'm just telling you that my

18 guess is not 100% and my experience is that you get

19 lamps back.

20 MR. BROOKMAN: Tom?

21 MR. STIMAC: Tom Stimac, GE. I think

22 that's one thing that we all have to understand is
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1 the assumption that if it fits in the slot it

2 automatically is exactly the same thing and that's

3 just not true. So we have to be very careful and

4 when you start dealing especially with energy

5 efficiency you start changing technologies or how

6 everything is made, performance is automatically

7 going to be a trade-off.

8 So if you think that every CFL that is a

9 G24Q-3 and I just put it back in there, chances are

10 will it work when you first turn it on yes, but if

11 you have it on a dimmer or it's on a different type

12 of situation or a system associated with it, it might

13 -- you can't guarantee that it will be 100%

14 compatible. That's why a lot of these are paired

15 together and they are sold paired because that's --

16 from a commercial point of view they try to keep them

17 in that vein.

18 MR. BROOKMAN: Noah?

19 MR. HOROWITZ: Noah Horowitz, NRDC. I

20 think we need to challenge or take a harder look at

21 the assumption that the lamp won't work with the

22 installed ballast and base if the wattage is slightly
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1 different and I think in this case if anything the

2 replacement lamp if you went to the bottom CSL level,

3 the wattage would be lower rather than higher so we

4 are not imposing a safety risk here.

5 And in terms of consumers hey it's not 26

6 watts it's 21 watts, they are not going to buy it. 

7 Industry is very used to and doing a very good job

8 guiding consumers with screw based bulbs. 72 watts

9 equal 100 watts so you could do some equivalency

10 there. Again I agree with Charlie.

11 What's the shape or the configuration of

12 the base, will it fit or not. They often bring that

13 pin based lamp to the store and say I want one of

14 these and if the watts are slightly different I think

15 it shouldn't be an issue, thank you.

16 MR. BROOKMAN: Yeah Joe, go ahead.

17 MR. HOWLEY: So my concern on safety

18 wasn't the compatibility. Generally if it fits the

19 key way it will likely be compatible for most

20 applications. The issue is more of safety with

21 regard to OSHA requirements or minimum light level

22 requirements. If these are used in stairwells or
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1 hallways, the original designer, these are designed

2 typically by professionals because this is mostly a

3 commercial lamp, not residential, residential is much

4 more flexible and typically not designed rather than

5 just placed in a space.

6 But they are designing it to meet certain

7 requirements that are required in those commercial

8 facilities for safety and if it drops the light

9 level, you may have a safety concern with regard to

10 meeting OSHA exit lighting requirements, things of

11 that nature that you are running into when you drop

12 this light level, just to save energy. That's my

13 concern more about the safety issue.

14 MR. BROOKMAN: Charlie a final comment

15 before we move on?

16 MR. STEPHENS: Yeah just to respond to

17 Joe's comment. I'm Charlie 

18 Stephens, we have been doing lighting programs now

19 for almost 30 years and most of the buildings we are

20 in, almost every one of them is grossly over lit to

21 start with. By definition even when they are

22 designed right they are over lit because they are
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1 designed to meet those safety requirements even if

2 you don't change the lamp when the lumens reach 70%

3 of their rated -- initial output so almost every

4 space we come into that's been designed is grossly

5 over lit to start with.

6 So we see possible lumen reductions if you

7 actually design it right, of 20 and 30% sometimes so

8 I can pretty much be assured that a 10% or an 11%

9 reduction is not going to put anybody in jeopardy or

10 put you in any kind of a common situation where you

11 are not putting enough light on the floor or in the

12 stairwell or whatever, they are grossly over lit to

13 start with.

14 MR. BROOKMAN: Joe?

15 MR. HOWLEY: My only comment to that is I

16 am referring to the spaces that are not grossly over

17 lit so there's going to be a variety of spaces so I

18 am concerned about those not the ones that are over

19 lit.

20 MR. BROOKMAN: Okay well I'm moving on,

21 okay Mike go ahead.

22 MR. MCGARAGHAN: Mike McGaraghan,
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1 California IOU's. I just had a question about how

2 DOE structures its analysis when it does -- and this

3 table is a little bit different format than the last

4 few because it lists CSL1 on multiple rows so you

5 have identified 2 candidates or reference, you know,

6 lamps that would be available at CSL1 so how does

7 that feed into other stages of the analysis? 

8 You do it 50/50 just to assume -- do all

9 the calc's with one lamp and then all the calc's with

10 the other lamp?

11 MS. KIENLE: So I think my colleagues at

12 LBNL will get into that a little bit more later on

13 but no I don't think it's an even distribution

14 between the 2 lamp options. There's a shipment

15 percentage designated.

16 MR. BROOKMAN: Yes Maureen, no Colleen

17 please?

18 MS. Kantner: Colleen Kantner, Lawrence

19 Berkely National Lab. Just to answer your question: 

20 we illustrate the lifecycle costs for both lamp types

21 separately, but when calculating the LCC savings and

22 the national impact we do take into account the
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1 expected market share of each type and we did find

2 that the lower-lumen-output lamps were much less

3 likely to be adopted, so that's reflected in those

4 analyses.

5 MR. BROOKMAN: Thank you Colleen. 

6 MR. MCGARAGHAN: Okay then I have a tack

7 on comment that's actually -- it applies to 2 tables

8 prior but it will come up again when we get to that

9 section and that is for the primary product class

10 that we are talking about, the non -- or integrated

11 low lumen -- this table. So I think when we get

12 there later each of those rows there's going to be a

13 different CSL but my comment would be that there are

14 -- each CSL can have multiple lamp types that meet it

15 so CSL1 can be met by a CFL or an LED and CSL2 even

16 though it's identified as LED here could also be met

17 by a CFL.

18 As far as I know there are products at 67,

19 68, 69 lumens per watt that are CFLs so hopefully

20 DOE can talk about that later but I would -- my

21 comment or suggestion would be that your analysis of

22 CSL1 isn't just looking at that CFL because there are
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1 other products that would meet CSL1 that would be

2 sold there, the same for CSL2, thank you.

3 MR. BROOKMAN: Okay thank you, now we are

4 moving on.

5 MS. KIENLE: Okay so we will get into the

6 CSLs now that DOE is considering. So DOE used

7 commercially available lamps and their associated

8 catalogue efficacies to determine the CSLs, then to

9 establish final minimum efficacy requirements for

10 CSLs DOE evaluated 2 things, whether any adjustments

11 were necessary to the initial CSLs to insure lamps

12 were available across the entire lumen range

13 represented by the product class and also publically

14 available compliance and testing verification

15 databases to ensure that the CSLs were achievable.

16 For the non-integrated product class DOE

17 also confirmed that the CSL under consideration would

18 not force a fixture change or a base type change for

19 consumers. 

20 For the integrated product class DOE is

21 considering establishing CSLs based on the equation

22 for efficacy that uses lumens as the input. DOE
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1 utilized a data base of the catalogue efficacies of

2 commercially available lamps to evaluate efficacy

3 trends across a range of lumen output in order to fit

4 a curve.

5 DOE confirmed the curve matched product

6 performance particularly in the low and high ends of

7 the GSL lumen range -- the resulting equation form

8 which is a decaying exponential as shown on the first

9 bullet on the slide.

10 After identifying more efficacious

11 substitutes DOE calculated the A value of the

12 equation which shifts the curve up or down using the

13 catalogue lumen output and the catalogue efficacy for

14 each representative lamp unit that was selected. 

15 DOE then evaluated the equations against lamps with

16 the same design option as the representative lamp

17 unit for each CSL and made slight adjustments to

18 capture the efficacy of lamps with those design

19 options across the entire lumen output range.

20 This allowed for continuous CSLs across

21 the integrated product classes. The resulting

22 equations for the integrated low lumen and integrated
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1 high lumen product classes are presented in a table

2 on this slide.

3 And on this slide the CSLs for the

4 integrated product classes are graphed. The vertical

5 dash line represents the division between the low

6 lumen and the high lumen product classes, and as you

7 can see CSL1 and CSL2 are continuous across the

8 product classes and so at CSL1 in the low lumen and

9 high lumen product classes, that can be achieved by

10 an improved CFL with more efficient phosphors and

11 improved ballast components.

12 CSL2 is represented by a basic LED lamp in

13 the low lumen product class and an advanced CFL in

14 the high lumen product class. CSL2 is the maximum

15 technologically feasible level for the high lumen

16 product class. 

17 CSL3 is represented by an improved LED

18 lamp with characteristics such as improved package

19 architecture, optics and high efficiency driver. 

20 CSL4 is represented by an advanced LED lamp which

21 improves upon these characteristics even further and

22 CSL5 is represented by the most efficacious LED lamp
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1 currently available on the market.

2 MR. BROOKMAN: Noah?

3 MR. HOROWITZ: Noah with NRDC. Could you

4 please go to Slide 45? I think that spells out the

5 comments by my colleague Michael to my left. If you

6 look at the second row for spiral, that's the CFL and

7 that's I think although not shown here CSL1 and the

8 row below it is CSL2 and whether you add another CSL

9 whether it's 1A or 2A or 2B, we think there should be

10 a high efficacy so call it 66.7. Some CFLs could

11 meet it and leave the lifetime at 10 or 12,000 hours,

12 don't jump to 25,000. This gets to the comment from

13 my colleague from the Southern Company.

14 We don't think the intention here is to

15 eliminate CFLs and we think that there's another

16 more efficacious option for CFLs beyond those that

17 are shown here. So in summary we would like to see

18 consideration of a high efficacy call it the 66.7 but

19 at the lifetime that's in CSL1, thank you.

20 MR. BROOKMAN: Thank you.

21 MS. KIENLE: Okay for the non-integrated

22 GSL product class DOE is also considering
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1 establishing CSLs based on an equation for efficacy

2 that uses lumens as the input. DOE used the rated

3 efficacy which is initial lumen output divided by

4 ANSI rated wattage for the non-integrated product

5 class. 

6 DOE used a similar methodology as the

7 integrated product class to develop the CSLs. Again

8 DOE first utilized a data base of commercially

9 available lamps to evaluate the efficacy trends

10 across a range of lumen outputs in order to fit the

11 curve, the resulting equation form is in the first

12 bullet here.

13 DOE then confirmed the curve that matched

14 product performance particularly in the low end and

15 the high end of the lumen range. After identifying

16 more efficacious substitutes DOE calculated the A

17 value of the equation for each of the representative

18 lamp units.

19 DOE also ensured that the impacts of CSL1

20 are consistent across the lumen output range of the

21 entire product class. The resulting CSL for the

22 non-integrated product class is presented in this
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1 slide.

2 MR. BROOKMAN: Susan?

3 MS. CALLAHAN: Susan Callahan, Osram

4 Sylvania. What data base did you use?

5 MS. KIENLE: So we compiled the data base

6 of -- and it was like I mentioned before it was based

7 on catalogue data first so we used the lumen output,

8 the initial lumen output and then for this particular

9 product class the ANSI rated wattage to calculate

10 efficacy.

11 MS. CALLAHAN: Susan Callahan, Osram

12 Sylvania. So with a product that doesn't have a test

13 procedure we're using catalogue data as opposed to

14 any other data-base where we know that everyone did

15 the measurements the same way?

16 MS. KIENLE: Right so catalogue data was

17 used for all of the products here as a basis of the

18 analysis. Okay and then on this slide the CSL for

19 the non-integrated product class is graphed. CSL1 is

20 represented by a full wattage, improved CFL with more

21 efficient phosphor and a more efficient reduced

22 wattage CFL.
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1 So as you can see the A value of the full

2 wattage representative lamp unit is used to set the

3 minimum efficacy requirements of CSL1 because it

4 represents the maximum technologically feasible level

5 that applies across all lumen packages within this

6 product class.

7 Okay and we have a few issues for comment

8 on this slide. In Issue 16 DOE requests comment on

9 the CSLs under consideration for the integrated and

10 non-integrated product classes including the max-tech

11 levels. In Issue 17 DOE request comment on the

12 methodology used to develop the CSL equations and in

13 particular DOE requests comment on the use of a

14 lumens-based equation and the equation form itself.

15 And Issue 18 DOE requests comment on its

16 assumption that fixture compatibility would not be a

17 common issue for non-integrated replacements. DOE

18 also requests comment on its assumption that consumer

19 utility will not be lost with the base types that

20 remain at CSL1.

21 And Issue 12 DOE requests comment on the

22 data approach including additional data-bases that
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1 should be considered.

2 MR. BROOKMAN: Mike?

3 MR. MCGARAGHAN: Mike McGaraghan,

4 California IOU's. I just want to comment the

5 Commission -- the Department on its curved approach,

6 the equations are a much more appropriate way to

7 regulate these lighting products than the bins so

8 thank you.

9 MR. BROOKMAN: Thank you, yes Keith?

10 MR. COOK: Keith Cook from Philips. When

11 you put together this data-base and you summarized it

12 in these charts like on number 45, when you chose a

13 maximum let's say efficacy of let's say 75.9 you show

14 a lifetime of 12,000 hours is that for the same lamp

15 or did you just sort out the maximum efficacy and

16 that was one manufacturer and then the maximum

17 lifetime was a different manufacturer but you still

18 put them into this chart?

19 MS. KIENLE: No, those would be the

20 characteristics of one particular model that was

21 looked at as a representative unit.

22 MR. COOK: Good thank you.
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1 MS. KIENLE: Um-hum.

2 MR. BROOKMAN: Yes Dave?

3 MR. GATTO: Dave Gatto, Westinghouse

4 Lighting. I'm kind of coming off of where Keith and

5 I think Susan might have been. I guess the use of

6 catalogue data always makes me a little nervous when

7 we are setting a standard. So it's that whole

8 outlier conversation if you have one particular

9 manufacturer that's you know, being a bit aggressive

10 with their feature benefits storied and capture

11 market share to set themselves apart, that isn't

12 necessarily what the product performance is and

13 without actual test data, you know it's really tough

14 to know if what we are setting is a legitimate number

15 in any of those, you know categories, whether it be

16 CRI you know LPW or lifetime so I just would ask DOE

17 to be considerate of making sure that either

18 excluding the outliers which I know you have done in

19 the past or making sure that the final standard

20 allows room for common differences between you know

21 manufacturers and also high volume manufacturing.

22 If you have somebody that's a specialty
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1 house that does one thing and does it really well,

2 that doesn't always translate to high volume

3 manufacturing. The only other thing I would say is

4 that I kind of just want to second I think where Noah

5 was. I don't know what the right CSL is but if it's

6 possible to preserve CFLs, I said CSL the first time

7 and I did just repeat myself, I think that would be

8 good for consumers and I think for the industry as

9 well and would allow a wider product assortment.

10 The only thing I would say is the reason I

11 don't know which the right CSL is is because of the

12 spiral versus covered lamp like Joe talked about. 

13 There are efficiency differences simply because you

14 are capturing some of that light output from the

15 internal spiral and I would suggest that we want to

16 find a level that allows covered products to be

17 manufactured. There are applications where they are

18 necessary.

19 MR. BROOKMAN: Okay Noah?

20 MR. HOROWITZ: Noah with NRDC. If you

21 could please go to Slide 52, the general comments

22 here, we are hoping that DOE is able to think in a
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1 forward looking way in terms of LEDs they are

2 evolving very, very quickly. They are becoming more

3 efficacious and lower cost at the same time which is

4 not the usual way one thinks that these things are

5 working. As the individual LED becomes more

6 efficient you don't need as many of them, you don't

7 need as much heat sink, you can get rid of the heat

8 sink.

9 A smaller form factored all of these

10 things result in lower cost and more efficient

11 products. So as you do this analysis we are hoping

12 you are not taking a static picture of where things

13 were today or 6 months ago, but looking forward.

14 And the reason that I bring that up is if

15 you look at this chart, CSL3 to 5 it's implied that

16 only LEDs would make it and yet you are not

17 predicting that LEDs will get any better or be able

18 to deliver more than 2,000 lumens. If you go back 2

19 years ago the typical LED capped out at 800 lumens so

20 the 60 watt equivalent.

21 Then the 75 watt equivalent came into the

22 market. Now we have lamps that are 100 watt
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1 equivalents so about a 1,650 lumens and one could

2 well expect that well before 2020 we will see lamps

3 that can hit 2,000 and above as LEDs thank you.

4 MR. BROOKMAN: Thank you Joe.

5 MR. HOWLEY: Joe Howley, GE. I'll just

6 note that both Dave's comments and Noah's comments

7 support this idea that CFLs and LEDs should be in 2

8 separate product classes because of the vast

9 difference in technology that both of those areas

10 represent, one being very mature and one being still

11 in an evolving stage, thank you.

12 MR. BROOKMAN: Okay thank you. Let's

13 return to 55 --

14 MS. KIENLE: Sorry can I just add one

15 request. If you could just submit in written comment

16 any type of utility that would support an argument

17 for creating 2 separate product classes for CFLs and

18 LEDs that would be really helpful.

19 MR. BROOKMAN: Noah?

20 MR. HOROWITZ: Just sorry to get us off

21 track here. I just one to respond to Joe's comment

22 as NRDC and the other advocates we're not necessarily
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1 suggesting there should be 2 separate classes, we are

2 just stating that we need to think of how LEDs will

3 evolve.

4 MR. BROOKMAN: Yeah, Don Brundage?

5 MR. BRUNDAGE: Don Brundage, Southern

6 Company. I think one of the things that I'm a little

7 concerned with is to use things like lifetime hours

8 or we are saying lumens in such a way to eliminate

9 the CFLs. I mean there may come a day that they are

10 an obsolete technology but we are not there yet and

11 there are enough differences and performance

12 characteristics, things like low temperature, high

13 temperature operation that they need to both be in

14 the market. I don't know that there's enough

15 differences to justify a separate class, but I think

16 that you need to be careful to not set the criteria

17 where you don't have a broad -- you are not allowing

18 both the products and the broad range of the products

19 to exist, thank you.

20 MR. BROOKMAN: Okay thank you, take a peek

21 at these comment boxes and see if there is anything

22 additional. Nothing additional let's take a break. 
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1 We have covered a lot of ground this morning already. 

2 It's now almost 11:00 so we are going to take a 15

3 minute break. I think those of you are -- most of

4 you are familiar with the way things work here in the

5 Forrestal Building, you must have some sort of

6 identification badge visible above your waist. There

7 are restrooms on both sides of the hall, there's a

8 coffee shop on the ground floor, almost directly

9 beneath us on the other side of the hall. If you are

10 going to go for coffee please go quickly and we will

11 resume back here at 11:15 okay thanks for a good

12 start on the day.

13 (BREAK 11:00 a.m.)

14

15

16

17

18

19

20

21

22
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1 MR. BROOKMAN: Okay please take your

2 seats. As I said before we went to break we have

3 really covered a lot of ground and really appreciate

4 the quality of the comment and we are going to

5 continue in that same vein and take it back to

6 Maureen Product Price Determination.

7 MS. KIENLE: Okay so we will now cover the

8 Product Price Determination.

9 MR. BROOKMAN: Noah?

10 MR. HOROWITZ: Noah Horowitz. A quick

11 process question, we did introductions would it be

12 possible to know who is on the line and have them

13 introduce themselves?

14 MR. BROOKMAN: Maybe we could read off the

15 individuals by name, Alex yes? Wait, we need a

16 microphone for Alex. And there are a few individuals

17 in the room that did not get a chance to introduce

18 themselves at the outset so maybe we will do that as

19 well, Alex you are next.

20 MR. KROWKA: Alex Krowka, Energetics

21 Incorporated. On line right now we have 18

22 attendees, Andrea Alstone, Brendan Cassidy, Claire
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1 Mizolek, Dominic Wannakay, Erik Page, Jim McMahan,

2 Johnny Green, Karen Ryder, Kevin Dombrowski, Liana

3 Wallace, Linda Wilson, Michael Meyer, Rick Ho, Robert

4 Hosback, Robert Lingold, Sharon Baker-Branstetter,

5 Taylor Janetz-Sell.

6 MR. BROOKMAN: Thank you Noah?

7 MR. HOROWITZ: I was also curious what the

8 organization is if that's not too time consuming.

9 MR. BROOKMAN: That will be in the record. 

10 A few individuals did not get a chance to introduce

11 themselves at the onset.

12 MR. FOSTER: Chuck Foster representing the

13 Edison Electric Institute.

14 MR. BROOKMAN: Thank you Andrew?

15 MR. DELASKI: Andrew deLaski, Appliance

16 Standards Awareness Project.

17 MR. BROOKMAN: Anybody else who would like

18 to introduce yes please?

19 MS. AMANN: Jennifer Amann, ACEEE.

20 MR. ROSENBERG: Alex Rosenberg, National

21 Electrical Manufacturers Association.

22 MR. BROOKMAN: Great and so Brenda has
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1 already handed out a copy of the business cards that

2 were obtained when you checked in, that's probably

3 almost complete, close to being complete. And once

4 again the Department of Energy is pleased to have so

5 many individuals joining the meeting via the web. I

6 was speculating that I think DOE should get some

7 credit for scope 3 emissions reductions or something

8 like that, anyway, something. Okay to Maureen.

9 MS. KIENLE: So we are going to cover the

10 Product Price Determination now. For this analysis,

11 DOE estimated the end user prices of GSLs directly

12 rather than developing manufacturer selling prices. 

13 Because lamps are difficult to break down to discreet

14 components and reverse engineer.

15 Because blue book price data was not

16 available for all GSLs DOE instead used publically

17 available retail prices to develop end user prices

18 for each CSL. Retailer's prices were collected and

19 averaged for each representative lamp unit and

20 corresponding lamps with similar characteristics at

21 each CSL.

22 Using these lamp prices, an average price
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1 for each distribution channel was developed because

2 DOE observed a large range in end user prices

3 depending on the distribution channels through which

4 the lamp was purchased.

5 DOE identified 4 main distribution

6 channels. Specifically small consumer based

7 distributors including internet retailers, grocery

8 stores and drug stores. Large consumer based

9 distributors including home centers, hardware stores

10 and mass merchants, electric distributors and state

11 procurement contracts. Based on estimated shipments

12 through each channel a weighting was applied to each

13 of the distribution channel prices to help develop an

14 average weighted end use price for lamps at each CSL.

15 DOE used different shipment percentages

16 for integrated lamps and non-integrated lamps because

17 integrated lamps are more commonly used in the

18 residential sector and non-integrated lamps are more

19 commonly commercial products. 

20 In Issue 19 DOE requests commend on the

21 methodology and results for estimating end user

22 prices for GSLs. DOE also requests comment on the
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1 distribution channels and estimated percentage of

2 shipments through each channel and those shipment

3 percentages are shown on this slide. 

4 MR. BROOKMAN: Yes please Noah?

5 MR. HOROWITZ: I don't know if this

6 comment is appropriate now or later. If you go to

7 Slide 66 you are showing a base cost for CSL, zero

8 for a CFL of $6.00 and if you go to retail big box

9 stores which dominate your analysis which we think is

10 appropriate, those are $1.50 or $2.00 in a multi-pack

11 and then when you go to the more efficient CFL the

12 cost is lower not higher and I'm wondering what the

13 assumptions were there.

14 MS. KIENLE: So to answer the second point

15 with the lower cost at CSL1, so the product at the

16 baseline is a covered product which was pointed out

17 earlier as well and we did find that there is a

18 difference in price between covered lamps and spiral

19 lamps so that is what you are seeing there.

20 MR. HOROWITZ: If I understand this right

21 then CSL1 is you are assuming today what a bare

22 spiral meeting CSL1 would cost?
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1 MS. KIENLE: That's correct.

2 MR. HOROWITZ: Okay thank you.

3 MR. BROOKMAN: And what about the

4 multi-packs? I've seen them too?

5 MS. KIENLE: Yeah so we factor in prices

6 on a per unit basis and we would gather prices from

7 all of the retailers that we discussed already so

8 prices should be accounted for but it is a per unit

9 cost.

10 MR. BROOKMAN: Okay, let's return to Slide

11 57, question please Don Brundage?

12 MR. BRUNDAGE: Since you do have some

13 functional differences i.e. fashion and where you can

14 actually use a lamp difference between a covered and

15 a bare spiral, is there any consideration of setting

16 up a different product class for the covered versus

17 the -- covered in this case means a covered lamp not

18 a covered under CFR 430 which is kind of confusing. 

19 MR. BROOKMAN: Below a configuration

20 or something?

21 MR. BRUNDAGE: But it would seem like

22 since there is some different consumer utility
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1 between the two that you might consider setting up a

2 separate class for those which would avoid this very

3 weird CSL1 cheaper than CSL0 thank you.

4 MS. KIENLE: So we talked about this a

5 little bit previously and I think in the last public

6 meeting as well we did consider a separate product

7 class for covered lamps at the framework stage but

8 then removed it this time around and a few of the

9 reasons given we welcome you know additional comments

10 if you have something else but in particular there

11 are LED lamps which are more efficient that have that

12 covering as well, so we look you know pretty similar

13 so if there is something else besides that utility or

14 just the aesthetics we welcome that in comment.

15 MR. BROOKMAN: Keith?

16 MR. COOK: Keith Cook with Philips. And

17 you know you need to understand that one of the

18 biggest advantages is now to the covered CFL is the

19 fact that it eliminates the concerns about the

20 mercury because they are almost unbreakable and so

21 you can drop them without any problems. That doesn't

22 apply in LED cases. It's unique to the CFL and
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1 there's really a huge market for them.

2 MR. BROOKMAN: Thank you yes?

3 MR. BRUNDAGE: But your statement

4 indicates that it's sort of trivial that there's an

5 aesthetic difference. So that it's fundamental if

6 you have a bare spiral there are many applications

7 consumers will not be using them where they would

8 whereas a visible lamp. So it's not a trivial

9 consideration to consumers, and I think that there's

10 been separate product classes set up for less

11 sub-standard issues than this, thank you.

12 MR. BROOKMAN: Thank you Mike?

13 MR. MCGARAGHAN: Mike McGaraghan,

14 California IOU's. Can you talk a little bit about

15 how you collected price data from retailers and you

16 know specifically how much you collected and from

17 which retailers? Is that all published in the TSD?

18 MS. KIENLE: So I would say a lot of that

19 information is published in the TSD but I can speak

20 to it a little bit more now too. In general we

21 collected information from a vast majority of the

22 different distribution channels that we mentioned so
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1 I know your big box retailers, online, I think

2 there's close to 50 different internet retailers. 

3 All of the big box stores like I mentioned, state

4 procurement contracts, basically anything that we

5 could find the publically available price for it was

6 taken into consideration for any of the lamps that we

7 have collected catalogue information for as well.

8 MR. MCGARAGHAN: And are there specific

9 data points in the TSD or just the averages rolled

10 up?

11 MS. KIENLE: It would just be the averages

12 in the TSD.

13 MR. BROOKMAN: We haven't received any

14 comment yet on the distribution channels, the

15 percentages, could someone comment about whether

16 these are on the right track here or not? Joe?

17 MR. HOWLEY: Just, we haven't looked at

18 these exactly but I think your statement of on the

19 right track is probably appropriate. They seem to be

20 reasonably on the right track without looking at the

21 exact sales data.

22 MR. BROOKMAN: Okay thanks for that,
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1 Andrew deLaski?

2 MR. DELASKI: I want to come back to the

3 question of so we have a bunch of sources for price

4 data and then I guess the next question is how did

5 the 

6 Department weight them? How do you figure out how to

7 weight them because it's the sales data that is hard

8 to get a hold of, figure out how to weight them and

9 go back to all of our observation that we lost in

10 CFLs typically if you want to get some CFLs you get

11 5 in a multi-pack for ten bucks or something like

12 that.

13 So the price points are higher than what I

14 think many of us have observed in the real

15 marketplace for your average price.

16 MS. KIENLE: Sure so for the -- we are

17 talking about I think the low lumen integrated GSLs

18 right now in particular. The integrated GSL is the

19 first row here so these are the weightings that we

20 used so the small consumer based distributors would

21 put in things like the internet retailers, grocery

22 stores would be within there and the large consumer
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1 base so your Home Depots, Walmart, Target were in

2 that 75% weighting right there.

3 And then the electric distributors were

4 10%, state procurement were the 5% so we gathered all

5 the prices for each of those distributions channels

6 and then calculated the average and weighted the

7 prices by that.

8 MR. DELASKI: And just to follow up, you

9 walk into Lowe's or Home Depot or Target whatever,

10 you see CFLs at a bunch of different price points,

11 you know including multi-packs we are talking about

12 or single packs and there's a whole bunch of

13 different flavors. How do you deal with all these

14 different flavors and you can buy one for as I said

15 the multi-pack or you can buy a single for $8.00 or

16 $9.00, you know, the bulk of this in the market.

17 MS. KIENLE: Right so what we would do is

18 look at just their representative units and then

19 similar lamps. So we collected those prices so

20 anything that's similar to that 60 watt equivalent at

21 CSL1 that we talked about already. We would collect

22 that price and then the prices for comparable lamps
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1 so similar CCT, CRI, lifetime, and things that would

2 factor into the prices and we tried to normalize for

3 that and then computed an average. 

4 So we collected you know the high end of

5 the range and the low end of the range and computed

6 an average price.

7 MR. DELASKI: So it's straight average

8 then?

9 MS. KIENLE: It's an average that -- it's

10 kind of average of an average, but it is an average

11 of all the different you know, different places you

12 can get that lamp from is computed as an average and

13 then the weighted average is also applied.

14 MR. BROOKMAN: Based on distribution

15 channel, Dave go ahead.

16 MS. KIENLE: And there's more detail in

17 the TSD too if I am not explaining it great right

18 now.

19 MR. GATTO: Dave Gatto, Westinghouse, I

20 think this might be where you are Andrew. You are

21 calling it an average but really you are talking

22 about a mean of the number but I guess did you apply
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1 any outlier segregation? I'm thinking about you are

2 talking about Home Depot and Lowe's where I agree

3 with you Andrew you might have the same bulb, could

4 range in price with a $10.00 difference. On-line it

5 could be even worse, you might see a product that may

6 or may not be what it says it is and may or may not

7 be on -- market on clearance.

8 But when I looked at TSD you mentioned

9 that you got online and then big box and you gave

10 that 75% weighting, how did you deal with outliers,

11 if you have an item, you know for example the spiral

12 and it's 25 cents and $19.00 did you just call that

13 $10.00 is that what you are suggesting?

14 MS. KIENLE: So we did consider outliers

15 so if something looked unreasonable we did kind of a

16 reasonableness check. We really did kind of filter

17 through each price individually and then we also

18 excluded lamps that we thought were rebated as well

19 so that would sometimes factor in on a really low

20 price as well.

21 MR. BROOKMAN: Charlie Stephens?

22 MR. STEPHENS: Charlie Stephens. I think
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1 what Michael might have been trying to get at and

2 some other people maybe is that if I go to a -- I'm

3 not going to name the names here but if I go to a big

4 box retailer who has got multiple choices of the same

5 lamp essentially, a 13 watt CFL let's just say. You

6 can buy the 6 pack or you can buy a 2 pack and you

7 could buy 1 and the price per unit will be different

8 for each one of those. How did you weight that big

9 box retailer's price for that lamp?

10 MS. KIENLE: Right so we would have

11 collected all of those prices and they all would have

12 been going into that average price.

13 MR. STEPHENS: But you didn't weight them

14 differently so you didn't weight that if a consumer

15 comes in and buys a 6 pack and the same number of

16 people come in and buy a 2 pack, you didn't weight

17 the 6 pack price at 3 times the weight of the 2 pack

18 price?

19 MS. KIENLE: It would have been just a

20 yeah -- the per unit cost so we would have calculated

21 what that cost was for you know, for each lamp.

22 MR. STEPHENS: So it's not sales weighted
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1 at a particular retailer and how did you separate the

2 online sales for those same big box retailers versus

3 the in store sales?

4 MS. KIENLE: So those were considered as

5 the in store price, in particular for the big stores

6 so if Home Depot had prices online those were

7 considered in the large consumer based distributor so

8 it really wasn't considered like an internet

9 retailer. Which when we think of internet retailers

10 we typically consider those like the convenience

11 channel, people just going online on like an Amazon

12 or E Light Bulbs or something like that and just

13 paying maybe a higher cost because it's more

14 convenient for them.

15 So we separated those out from those

16 internet retailers. If you have information too on

17 some kind of way to weight how many consumers would

18 go for a 6 pack versus a 2 pack we would certainly be

19 welcome for that but we didn't weight for that

20 specifically no.

21 MR. BROOKMAN: Noah?

22 MR. HOROWITZ: Noah Horowitz with NRDC. I
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1 want to echo what my colleagues Andrew and Charlie

2 have mentioned that to the extent you can come closer

3 to a sales weighted average even if you don't have

4 the individual sales of all these model numbers and

5 the example Charlie was driving at let's say the

6 thing is offered in a 4 or a 5 pack which is very

7 common, that price is $1.50 or $2.00 ballpark where

8 if you buy a 1C for whatever reason that's $5.00 -

9 $6.00 a bulb for the exact same bulb.

10 If you just took those two models and said

11 okay it's $2.00 and 6, the average is 4 we think

12 that's incorrect because you are getting -- even

13 though you just bought one package you are getting 4

14 bulbs so there's a 4 to 1 ratio and there should be

15 some -- that weighting should be taken into account.

16 A separate, more difficult question maybe

17 you can't get this far is what percent of the time

18 did people buy a 4 pack versus a 1 pack. You might

19 not have that but you definitely need to weight more

20 towards the 4 pack cost, thank you.

21 MS. KIENLE: Okay.

22 MR. BROOKMAN: Okay are we ready to move
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1 on? I think so okay.

2 MS. KIENLE: Okay so I'm actually going to

3 turn this over now to Colleen who will take up Energy

4 and LCC.

5 MS. KANTNER: Thanks, Maureen. My name is

6 Colleen Kantner, I'm from Lawrence Berkeley National

7 Lab, and I'll be presenting the Energy Use and

8 Life-cycle Cost Analyses. The purpose of the energy

9 use characterization is to develop estimates of

10 average annual site energy use representative of

11 consumers in the U.S. Annual energy use is

12 determined for each efficiency level established in

13 the Engineering Analysis, and is based on the product

14 of annual operating hours and lamp input power, the

15 latter of which was developed in the Engineering

16 Analysis.

17 The impact of lighting controls on energy

18 use was taken into account and treated by reducing

19 overall energy use for lamps that operate with

20 controls, as will be discussed in a couple of slides. 

21 In the residential sector, average hours

22 of use were developed for 27 regions of the U.S.,
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1 using data from metering studies conducted in

2 various locations across the U.S.

3 Chapter 7 of the TSD details how these

4 data were extrapolated to each of the regions

5 analyzed. 

6 An important context to keep in mind is

7 that, due to the Appropriations Rider GSILs are not

8 in the scope of this rulemaking, and without the

9 inclusion of these lamps, DOE has assumed that a

10 potential GSL final rule would not yield sufficient

11 energy savings to avoid triggering the EISA 2007

12 backstop. 

13 Therefore, DOE has assumed the backstop

14 will take effect January 1, 2020. Given this

15 context, DOE has assumed that during the analysis

16 period, which begins January 1, 2020 simultaneous --

17 with the compliance date for the back stop -- the

18 average hours of use for all GSLs will be the same as

19 the current average hours of use for all GSLs.

20 This is based on the assumption that the

21 current, higher hours of use that some metering

22 studies have found for CFLs are the result of the
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1 disproportionate installation of CFLs in sockets

2 with higher hours of use. This would no longer be

3 the case during the analysis period where CFL and LED

4 GSLs will be filling all of the sockets currently

5 filled by GSLs. 

6 Furthermore, DOE has assumed, at least for

7 the reference scenario, that CFL and LED GSLs will

8 have the same hours of use and that hours of use will

9 not vary by efficiency level. Alternative scenarios

10 for rebound were considered in the National Impact

11 Analysis.

12 DOE found that the national, weighted13 average daily operating hours for the residential

14 sector are 2.3 hours per day. And we have a couple

15 of items for comment. First, DOE seeks comment on

16 its assumption that GSL operating hours will not vary

17 by light source technology during the analysis

18 period. And Issue 21: DOE requests any data

19 suggesting that the EISA 2007 back-stop criteria will

20 not be met.

21 MR. BROOKMAN: Joe Howley?

22 MR. HOWLEY: Joe Howley, GE. Just a
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1 question on that 2.3 hours a day. Is that based then

2 on the CFL and LED operation you found or is that

3 based on the incandescent plus the halogen plus the

4 CFL plus the LED operation that you found?

5 MS. KANTNER: It's based on the current

6 average use -- hours of use of all GSLs so that

7 would include incandescents, CFLs and LEDs.

8 MR. HOWLEY: Can you tell us how much

9 higher just the CFL was in this?

10 MS. KANTNER: 10 to 15% higher. I mean it

11 varied a little bit from study to study, but it was

12 in that range.

13 MR. HOWLEY: So like 2.5 hours a day,

14 something like that.

15 MS. KANTNER: Something like that.

16 MR. HOWLEY: Thank you.

17 MR. BROOKMAN: Don Brundage?

18 MR. BRUNDAGE: Don Brundage, Southern

19 Company. I realize you're rather hamstringed by the

20 Appropriations Rider but your assumption for Issue 20

21 is not assuming rational economic behavior by

22 consumers. You would assume that consumers who know
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1 the GSLs are -- that CFLs are more expensive and

2 last longer, tend to buy them for applications where

3 there is greater hours of use and continue to use

4 incandescents or fail to replace existing

5 incandescents in very infrequently used applications

6 such as John Cymbalsky's example earlier of a

7 basement light or something used a few hours of the

8 year.

9 So I realize you are somewhat hamstrung on

10 doing analysis but this does not seem to be a common

11 sense assumption that you would not think that CFLs

12 would not have higher operating hours.

13 MR. BROOKMAN: Keith Cook?

14 MR. COOK: Keith Cook with Philips. I

15 guess I would have to take exception to your

16 assumption here that the hours would be the same in

17 2020 as they are today. The reason that I'm saying

18 that is two-fold. One is there is increased adoption

19 of ASHRAE standards which has increased controls

20 which does affect residential lighting and also Title

21 24 and its impact in California would be significant

22 and will drive these numbers down going forward so I
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1 think the numbers should change.

2 MS. KANTNER: Just to clarify, the impact

3 of controls will be discussed in a slide or two so

4 this is not yet taking into account the impact of

5 controls, but they were taken into account in the

6 Energy Use Analysis.

7 MR. BROOKMAN: Okay we'll wait for that,

8 Charlie?

9 MR. STEPHENS: Can I just add I suspect

10 you probably took advantage of the data that we have

11 on residential use so I won't belabor that point but

12 --

13 MR. BROOKMAN: Consistent?

14 MR. STEPHENS: Pardon me?

15 MR. BROOKMAN: Are these consistent?

16 MR. STEPHENS: I think they are, you can

17 slice it. There were 2,200 sensors in the data that

18 we collected so you can slice it pretty thin and kind

19 of analyze it from whatever you want including

20 controls. But one of the things I wanted to point

21 out is I am assuming that everybody assumes, based on

22 your Issue 21 here that the back-stop criteria will
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1 be met and I think that's one of the reasons you can

2 assume that once households and businesses pretty

3 much have the same level of efficiency to choose from

4 across the board, no matter what the light bulb is,

5 if it's a GSL there isn't going to be that much

6 difference in efficiency. I mean there will be some

7 difference and there may be some difference in price,

8 but I suspect a lot of the price differences will

9 shift the efficiency differences will shift and the

10 differences between your choices are not going to be

11 all that big by 2020. So I don't think that some of

12 what we see today in the data is going to hold after

13 2018 so at least we don't assume they will, so I

14 don't find these assumptions to be too

15 inappropriate.

16 The other thing is that lighting controls

17 from what we have discovered in the field don't

18 necessarily translate to energy savings. In the

19 worst case we found in California the control system

20 for the house used 900 watts when the -- all the

21 lights were off and so it's you know, this is not you

22 know, controls are not necessarily an energy saver we
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1 have discovered, collecting more and more one minute

2 data on this stuff to kind of determine where it goes

3 so I would be wary of any assumptions that there will

4 be energy savings from controls.

5 MR. BROOKMAN: Any other comments on the

6 back stop assumption?

7 MS. KANTNER: If I could just ask a quick

8 follow up question. I think the commenter earlier

9 was explaining that he thought that there would be

10 different hours of use for CFLs versus

11 incandescents. Do you think there will be different

12 hours of use between CFLs and LEDs?

13 MR. BROOKMAN: Don Brundage?

14 MR. BRUNDAGE: Perhaps but and for some of

15 the same reasons, LEDs I think at the present time

16 are more expensive than CFLs so in concept. 

17 Although I think actually with LEDs it's a bigger

18 consumer criteria, and this is just anecdotal, this

19 is probably going to be things like they are much

20 longer lifetime, or hard to reach fixtures being able

21 to use them in cold weather conditions better than

22 CFLs.
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1 But I think clearly if you have a bulb

2 that's not going to be used very often the logical

3 thing would be to go to the cheapest thing available

4 which at the present time is still going to be the

5 modified incandescent. What it will be in 2020 is

6 pure speculation.

7 MR. BROOKMAN: Charlie?

8 MR. STEPHENS: One other thing I would add

9 here based on our own data, and I think Tom can back

10 me up on this if I'm wrong, but I think these lamps

11 -- we did this by fixture type by room among other

12 things and so you will find that most of the lamps

13 that we are talking about here are used in portable

14 fixtures which were a significant fraction of

15 residential use. But the next most significant

16 fraction of residential use was using lamps that are

17 not subject to this rulemaking so I don't -- once you

18 get away from portable fixtures and outdoor lighting,

19 there's quite a few of these used in outdoor

20 lighting, you are outside this rulemaking.

21 And then after that most of the rooms,

22 closets, hallways, those sorts of things, the hours
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1 are very low so I think this number is mostly

2 weighted by outdoor and portable fixtures if I am not

3 mistaken.

4 MR. BROOKMAN: Ken Rider who is joining us

5 via the web has a comment. Ken un-mute your phone

6 and hopefully we will hear you in the room.

7 MR. RIDER: Hello can you hear me?

8 MR. BROOKMAN: You sound good.

9 MR. RIDER: I just want to repeat some of

10 the comments we have submitted in writing to the

11 framework on this issue, which is that the question

12 isn't whether CFL or LED will replace one of these

13 sockets, but when, in the case of an EISA back stop. 

14 In that case you have just the lamps that you guys

15 considered as a replacement option, so when a lamp

16 breaks in the closet or whether it is in the kitchen

17 or bedroom, when it breaks you have to find something

18 to replace it with and so it makes sense to apply the

19 average number of hours, you know the ones that are

20 used for going more put the price first by virtue of

21 the fact that they break first, but in terms of the

22 overall U.S. market, it will end up being the average
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1 once all the lamps break. Then you have got just

2 CFLs and LEDs. Who knows where they are going to

3 break and I think the average makes a lot of sense.

4 One other more advanced analysis you could

5 give is -- this wasn't really the case for

6 incandescents but with LEDs and CFLs they last so

7 long that I've actually seen rotating: essentially

8 where the new LEDs and the new CFLs are better than

9 the old ones and so when a new one is purchased, the

10 better one goes in the main usage situation and then

11 the older CFLs and LEDs they are rotated out to

12 other fixtures that are used less frequently. 

13 Something you could see in like TV

14 replacements and consumer electronics which didn't

15 really exist in lighting until more recently. And

16 then in regards to Issue 21 the Energy Commission did

17 submit some estimates of how the back-stop will not

18 be met by just regulating CFLs and LEDs. The energy

19 consumption of -- or the energy savings by improving

20 incandescents to 45 lumens per watt are greater than

21 the total energy consumption of LEDs and CFLs today

22 and even at 50% of the market being LEDs, the energy
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1 consumption in moving from incandescents to 45 lumens

2 per watt is great than that energy consumption as

3 well.

4 So we will continue to include that in the

5 comments but I was also curious if there is any

6 specific area or more specific aspects of that that

7 DOE is interested in?

8 MS. DEBUTTS: This is Lucy deButts. I

9 don't think we have any additional specificity to

10 highlight here.

11 MR. RIDER: Okay thank you.

12 MR. BROOKMAN: Thank you Ken. Yes Noah?

13 MR. HOROWITZ: Noah Horowitz with NRDC. 

14 There have been lots of studies, they are very

15 complicated and every home is different, how many

16 sockets they have, which socket they use, how many

17 hours per day, which bulb they put in it, and you are

18 right, some people will think as an economics driven

19 decision of this one's on the most hours per day I'll

20 put the more efficient on it to lower my bill.

21 Other people are I don't like the light

22 quality of CFLs, whether that's justified or not, and
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1 they put the incandescents in there and there are a

2 lot of hours per day for that. So just because it's

3 a CFL doesn't mean it's going to have a lot of hours

4 per day. LEDs may be a better solution than CFLs

5 although they are more expensive. Consumers may or

6 may not make that choice. The LED offers

7 dimmability. The bottom line this is really

8 complicated and as a gut check I think your 2.3 hours

9 per day is an appropriate starter.

10 MR. BROOKMAN: Okay thanks.

11 MS. KANTNER: And just to clarify the

12 earlier comment from the fellow from the Northwest

13 Energy Efficiency Alliance: this average operating

14 hours didn't just come from a study in the Northwest,

15 this came from about 10 different studies.

16 MR. BROOKMAN: Yes, Don Brundage?

17 MR. BRUNDAGE: I think there is something

18 to consider if the back-stop goes into effect and my

19 understanding if it goes, everything has to be 45

20 lumens per watt. I think there is probably a need to

21 do some carve outs based on available technology on

22 some of the size limitation issues of higher lumen
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1 bulbs. If somebody wants says a 1500 lumen bulb in

2 an enclosed fixture, you physically can't do that

3 with a lot of CFLs because they won't fit, so a lot

4 of lamps will not, you will not be able to put a high

5 lumen non-incandescent in there.

6 If you have a luminaire on the floor,

7 people don't want to have the luminaire sticking

8 above -- the light bulb sticking up above the top,

9 and these are all issues I have had in trying in my

10 own home -- in trying to look at trying to use higher

11 lumen bulbs, and in some cases I have been forced to

12 use incandescents because there is no product on the

13 market that fits these size limitations.

14 So if the -- I think the Department should

15 consider some carve out special classes of space

16 constraining products for higher lumen output

17 products because there are consumer utilities that

18 unless LEDs get better quickly, there are products

19 that will simply not be available on the market,

20 thank you.

21 MR. BROOKMAN: Thank you Noah?

22 MR. HOROWITZ: I want to offer a
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1 clarification. In terms of the market, we do have

2 100 watt-equivalent bulbs today that offer around

3 1600 lumens as LEDs and the form factor is roughly

4 the same as the lower wattage, lower light output

5 LEDs, so they should fit. I agree with you that

6 CFLs, once you get at a hundred watt or above

7 equivalent the diameter gets larger and it may not

8 fit. But I think we do have a bulb that's efficient,

9 that would meet the standards, that would meet

10 consumers' needs, in the form of an LED.

11 MR. BROOKMAN: Okay, okay.

12 MS. KANTNER: For the commercial sector,

13 DOE estimated hours of use for 14 commercial building

14 types, based on data from the 2010 U.S. Lighting

15 Market Characterization. Operating hours associated

16 with lamp types that do not meet the GSL definition

17 were not included in the hours of use estimates -

18 so, for example, hours of use associated with GSFLs

19 were not included in the hours of use estimate.

20 DOE did not explicitly analyze GSLs

21 installed in the industrial sector because far fewer

22 GSLs are installed in that sector compared to the
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1 commercial sector, and the hours of use for GSLs in

2 the two sectors were assumed to be approximately

3 equal.

4 DOE analyzed these sectors together, using

5 data specific to the commercial sector, and refers

6 to the combined sector as the commercial sector. DOE

7 found that the national, weighted-average daily

8 operating hours for the commercial sector are 10.7

9 hours per day. We don't have an item for comment but

10 does anyone have any questions or comments on that?

11 DOE accounted for the impact of lighting

12 controls by reducing total energy use by 30% for all

13 GSLs that operate on controls, regardless of sector

14 or control type. It's worth noting that "controls"

15 here refers not just to traditional controls such as

16 dimmers or timers, but also wireless controls

17 integrated into lamps referred to as "smart lamps".

18 The 30% value comes from a meta-analysis

19 of studies on the impact of lighting controls in the

20 commercial sector, and DOE has assumed that it is

21 applicable to the residential sector as well. In the

22 residential sector, 14% of sockets are controllable,
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1 primarily with dimmers. Based on manufacturer

2 interviews DOE estimates that only 5% of CFLs are

3 dimmable. This means that the fraction of CFLs

4 installed with controls is technologically limited. 

5 By contrast, LEDs were assumed to

6 generally be dimmable and the fraction of LEDs that

7 used controls was determined by the fraction of

8 sockets which are controllable and the prevalence of

9 smart lamps. This means that LEDs are

10 preferentially installed with controls compared to

11 CFLs.

12 In the commercial sector, DOE modeled an

13 increasing fraction of GSLs installed with controls

14 due to building codes, and this is detailed in

15 Appendix 10C of the TSD for those who are interested.

16 We have a couple of items for comment. 

17 Issue 22: DOE requests comment on its approach

18 regarding the dimmability of CFLs and LEDs. And

19 Issue 23: DOE requests data and information to help

20 compare the energy use implications of using dimmers

21 as opposed to other lighting controls.

22 MR. BROOKMAN: Yes Noah?
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1 MR. HOROWITZ: Noah with NRDC. Could you

2 clarify that 30% savings number for controls -- did I

3 hear you right that that's based on studies from the

4 commercial sector and you applied it to residential?

5 MS. KANTNER: That's correct.

6 MR. HOROWITZ: I think if that's the case,

7 I don't think we can apply it to residential. Those

8 are very different controls, many of the ones in

9 commercial applications are sensor based where a lot

10 of the dimmers in a home are simply a rotary dial

11 that most of the time is in the full light output

12 position so I think that number is too high for

13 residential.

14 MS. KANTNER: Is there an alternative to

15 suggest?

16 MR. HOROWITZ: It would be to come up with

17 a lower number for residential, I don't know what

18 that is, and then create a weighted average.

19 MR. BROOKMAN: Tom Eckman?

20 MR. ECKMAN: Yeah maybe the only way to

21 get at it is to take a look at what the total use

22 estimate per household is to see whether the kilowatt
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1 hours reflect -- given 2.3 hours of use per day minus

2 30% -- does that get you in the range of what we have

3 metered for total lighting use in buildings? And we

4 are around 1,900 kilowatt hours in Northwest so if

5 you are down around 1,000 or 1,500 it might be a bit

6 shy before the actual application of the dimmers are.

7 MR. BROOKMAN: Andrew deLaski?

8 MR. DELASKI: I like Tom's idea I'm just

9 brainstorming a bit -- I wonder, do the commercial

10 studies differentiate sort of center-base controls

11 versus those that are manual controls? That might

12 be a way to if you could just segregate that data

13 from the commercial studies, what's center-based and

14 what's manual.

15 MS. KANTNER: We could certainly look into

16 that.

17 MR. DELASKI: And use the manual numbers

18 for the residential.

19 MR. BROOKMAN: That's differentiated

20 between residential and commercial, Charlie?

21 MR. STEPHENS: You know a quick -- Charlie

22 Stephens. We did do some pretty narrow surveys that
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1 looked at not only which -- how much of the lighting

2 had control, you have 14% of sockets are

3 controllable, primarily the dimmers, that may very

4 well be true. Did you look at the data to find out

5 which fixtures in which rooms were controllable

6 because I think you will find there's a pattern to

7 that. There aren't very many bathroom -- you know,

8 bathroom lights generally aren't dimmable and if you

9 have a third of your lighting is done with portable

10 fixtures, I presume you are not counting those.

11 Dining room chandeliers: very commonly

12 dimmable, some kitchen lighting: very commonly

13 dimmable, but those are usually R lamps, recessed can

14 R lamps, not subject to the rulemaking so I think if

15 you -- I don't know if you did this or not but if you

16 look at the data a little more closely and line-up

17 which are dimmable and compare that to which have all

18 the operating hours, I think 30% -- it depends what

19 number you multiply that by -- it may only be on 10%

20 of operating hours of lamps in the house.

21 So the impact on energy use may be quite

22 small which is why I say when you start adding up any
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1 power consumption by the dimming system itself, if

2 there is any, there may not be such huge energy

3 savings associated with it.

4 MR. BROOKMAN: Joe?

5 MR. HOWLEY: So just to offer some counter

6 thoughts -- Joe Howley from GE -- on dimming, these

7 are based on commercial applications but often in

8 those applications you don't dim to really low

9 levels, you are dimming for different reasons in

10 offices and conference rooms. You may dim lower but

11 in residential applications, often when you are

12 dimming it's for mood, it's for atmosphere, and you

13 often do dim to very low applications. Your comment

14 here is that for GSLs that operate on controls,

15 Charlie was commenting that well only so many are

16 operated on controls, but presumably that's already a

17 filter in there, you have already filtered out

18 anything not on control so these are for the lamps

19 that are covered by this rulemaking that are on

20 controls, how well are they dimmed in the residential

21 sector or how often.

22 But for TV viewing or for dining room or
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1 for things like that they may be dimmed well beyond

2 30% and for long periods of time so I don't know that

3 you could instantly jump to the conclusion that it

4 should be less than 30 or more than 30, I think what

5 you will find in residential applications is just a

6 much wider variability in how much they are dimmed,

7 depending on where they are used in the room but it

8 is an interesting question. 30% may not be a bad

9 place to start but you could just as well find lower

10 versus higher depending on the individual household

11 and how they are using, thanks.

12 MS. KANTNER: To answer your question, we

13 did not look at specifically which rooms those

14 dimmers were located in, we just assumed they were

15 randomly distributed according to the distribution of

16 GSLs in the home, but that is something that we can

17 take into account at the NOPR stage.

18 MR. STEPHENS: I would strongly recommend

19 that.

20 MR. ECKMAN: Yeah the data from the

21 Northwest has 82,000 sockets so I'm sure we can parse

22 those out into which types were covered products here
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1 and which of those are under controls so.

2 MR. BROOKMAN: Noah?

3 MR. HOROWITZ: Something nobody has

4 touched on and I think is equally or more important

5 in driving the calculation and would be good to test

6 around the room is you say 14% of sockets are

7 controllable or dimmable and --

8 MS. KANTNER: In the residential sector.

9 MR. HOROWITZ: In the residential sector,

10 so that's a relatively small number on the percentage

11 basis so if you are multiplying a whole number times

12 14% whether it's by .5 or .31 the accuracy, the 14%

13 number drives this and I'm wondering if people feel

14 that's about right. I know there are studies in

15 California that show it's 14% or less of the sockets

16 are dimmable.

17 MR. BROOKMAN: Don Brundage?

18 MR. BRUNDAGE: I would point -- Don

19 Brundage, Southern Company -- I would point out that

20 you are going to have studies of lighting and

21 controls et cetera in areas with strong energy

22 efficiency programs so the data is in some ways
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1 biased towards having more controls and more CFLs. 

2 If you have locations that do not have strong energy

3 efficiency programs they generally will not tend to

4 do studies on energy efficiency programs either,

5 yeah. 

6 So I think you do need to be a bit

7 cautious on assuming that the data for the Pacific

8 Northwest and California is representative of the

9 rest of the country. I don't have a good -- I don't

10 have a good solution for this, just understand you

11 are probably biased on the side of more CFLs and more

12 controls than the country as a whole, thank you.

13 MS. KANTNER: Just to clarify, that 14%

14 number came from the Lighting Market

15 Characterization. It did not come from the Northwest

16 study.

17 MR. BROOKMAN: Charlie Stephens.

18 MR. STEPHENS: But I would add what we are

19 talking about here are sockets that they have already

20 demonstrated only 5% of CFLs are estimated to be

21 dimmable, there's a few more LEDs out there right

22 now that we may have found, but what we are talking
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1 about out here is dimming incandescents.

2 So I don't think there's going to be a

3 huge as big a difference around the country in how

4 people use their dining room chandeliers at night and

5 how they dim for television and that sort of thing

6 because they are dimming for the most part

7 incandescents and that's the same everywhere so I

8 don't -- in this one case I think our data may

9 actually be more representative than it is in some

10 other cases.

11 But it is parsible and as Tom said there

12 were 82,000 sockets surveyed and 2,200 monitored so

13 -- fixtures monitored, sometimes with multiple

14 sockets so it's -- there's a lot of data there that

15 can provide a lot of insight as to whether or not

16 this is appropriate.

17 MR. BROOKMAN: Okay are we ready to move

18 on?

19 MS. KANTNER: I think so. And here we see

20 the energy use results for each product class broken

21 down by sector. Displayed for each CSL is the

22 calculated average annual energy use as well as the
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1 energy savings with respect to the baseline. Energy

2 use and savings are much larger in the commercial

3 sector due to the longer hours of use. 

4 Note that the operating hours are assumed

5 to be the same across product classes for a given

6 sector but these results do incorporate the impact of

7 controls which can vary by sector and by technology

8 type.

9 Chapter 7 of the TSD also presents energy

10 use results without controls in order to illustrate

11 the impact of controls on energy use. That

12 concludes the Energy Use Analysis and now I'm going

13 to talk about the Life-Cycle Cost Analysis.

14 MR. BROOKMAN: Before we move on, comments

15 on this rather detailed table should there be any? 

16 Okay.

17 MS. KANTNER: The purpose of the

18 Life-Cycle Cost, or LCC, Analysis is to provide an

19 economic evaluation from the end-users' perspective. 

20 Life-cycle cost is the total cost to the consumer

21 over the lifetime of the product. Payback period is

22 the time required to recover the increased purchase
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1 price of more efficient products through reduced

2 operating costs.

3 The methodology used is to first develop a

4 Monte Carlo sample of 10,000 purchasers. For this

5 rulemaking a lamp sample was also developed for the

6 integrated low-lumen product class. Life-cycle costs

7 are then calculated for each CSL by adding installed

8 cost, lifetime operating cost and disposal cost and

9 subtracting the residual value. And we will go

10 through each of these inputs on the subsequent

11 slides.

12 The payback period is calculated by

13 dividing the average increase in installed cost by

14 the average decrease in first year operating costs. 

15 In other words, the operating costs are not

16 discounted in the payback period calculation. 

17 And then finally LCC savings were

18 calculated, at least for this rulemaking, based on

19 market efficiency distributions in the base case and

20 candidate standards cases, where a candidate standard

21 case is an analytical case where the standard is

22 assumed to be set at one of the CSLs. 
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1 One thing that distinguishes the LCC

2 Analysis from the previous analyses discussed is that

3 the LCC considers at distribution of purchasers in

4 order to take into account the variability in

5 parameters such as hours of use and energy price. 

6 For the LCC DOE developed a sample of 10,000 GSL

7 purchasers and used this same sample to determine the

8 average LCC at each CSL.

9 For the residential sector, purchasers

10 were randomly drawn from the set of households in the

11 2009 Residential Energy Consumption Survey or RECS. 

12 For the commercial sector, purchases were assumed to

13 be installed in buildings drawn from the set of

14 buildings in the 2003 Commercial Buildings Energy

15 Consumption Survey, or CBECS, where a selection

16 weight was applied to each building based on square

17 footage, lamp concentration, and the fraction of

18 lamps that are GSLs in each building type. 

19 One of the inputs to the LCC is the total

20 installed cost, where for GSLs, the total installed

21 cost was just the sum of the lamp price in 2020 and

22 applicable state and local sales tax. To determine
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1 2020 lamp prices, price learning was applied to the

2 2014 lamp prices developed in the Product Price

3 Determination, which can be seen here for the

4 integrated low-lumen product class.

5 Price learning accounts for decreases in

6 manufacturing costs due to production experience by

7 the start of the LCC analysis period, and the

8 specific application of it in this rulemaking will be

9 discussed in more detail in the Shipments Analysis, 

10 but it's worth noting that for CFLs, price learning

11 was not applied to the portion of lamp price

12 attributable to rare earth oxides. 

13 This was not relevant for LEDs because

14 LEDs were assumed to include a negligible amount of

15 rare earth material. For the preliminary analysis,

16 DOE has assumed no product class switching and

17 believes that installation costs are negligible under

18 this assumption.

19 Additionally, the value to a consumer of a

20 longer lived lamp is accounted for in the residual

21 value calculation which is incorporated into the LCC. 

22 Therefore, installation costs were not included in
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1 the installed cost. 

2 Electricity prices and trends are also an

3 input to the LCC and were estimated using data from

4 the Energy Information Administration. Note that

5 price estimates are sector- and location-specific. 

6 Discount rates are another input to the LCC and are

7 used to discount operating costs to the year of

8 purchase. They represent the opportunity cost of

9 funds used to purchase GSLs and are sector-specific.

10 There's a significant amount of detail on

11 discount rates in the TSD for those interested. And

12 we have an item for comment: DOE welcomes comment on

13 its approach regarding installation costs.

14 MR. BROOKMAN: Dave?

15 MR. GATTO: Dave Gatto, Westinghouse

16 Lighting. A question for CFLs: you are saying price

17 learning was not applied only to the portion of the

18 lamp price attributed to rare earth oxides. I

19 actually suggested there shouldn't really be any

20 price learning in CFLs at all because it's a mature

21 product with high volume and it's being marginalized

22 by LED so typically you see price learning where it's
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1 a developing technology and volume is going up. I

2 appreciate that you left REOs out since that's kind

3 of a volatile issue all by itself, but how did you

4 account for, or did you account for, any type of

5 price learning other than for REOs on CFLs?

6 MS. KANTNER: I would suggest that we hold

7 this discussion until it is discussed in more detail

8 in the Shipment Analysis.

9 MR. GATTO: Okay.

10 MS. KANTNER: Sorry.

11 MR. GATTO: No that's okay, it just seemed

12 exactly on point with the Issue 29 question, sorry

13 about that, I'll wait.

14 MS. KANTNER: Thanks.

15 MR. BROOKMAN: Additional thoughts on

16 approach regarding installation costs? Yes Mike?

17 MR. MCGARAGHAN: Mike McGaraghan,

18 California IOU's. When you analyze each CSL and LCC,

19 do you just pick a representative product that barely

20 meets the CSL and conduct the analysis based on that

21 product or do you conduct the analysis based on all

22 of the products that are available that meet that CSL
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1 including the ones that exceed the CSL

2 substantially?

3 MS. KANTNER: In general, we used the

4 representative products developed in the Engineering

5 Analysis, but for the low-lumen product class we also

6 developed -- as I will discuss on the next slide --

7 lamps for the 4 different lumen bins from EISA. But,

8 in general, we used the products developed in the

9 Engineering Analysis.

10 MR. MCGARAGHAN: I think that that

11 approach makes more sense for most DOE rulemakings,

12 where products get more expensive when they get more

13 efficient. Here where we see prices coming down I

14 think if DOE wants to assess the impact of CSL1 the

15 fact is consumers will have a lot of options and some

16 of them -- some of the most appealing and cheapest

17 options might be far beyond the level of CSL1 so we

18 would encourage you to use the shipment weights that

19 you forecasted and apply those, not just in the

20 National Impact Analysis but the LCC as well.

21 MS. KANTNER: We do weight the CSLs for

22 the LCC's savings calculation. I'll discuss that in
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1 a little bit.

2 MR. MCGARAGHAN: Okay, maybe I

3 misunderstood.

4 MR. BROOKMAN: Tom Eckman?

5 MR. ECKMAN: Tom Eckman, Northwest Foreign

6 Conservation Council. For the fraction of the

7 products that are being installed in the commercial

8 marketplace, I think installation costs should be

9 included because there is labor costs associated with

10 that and the lifetime of these products vary

11 significantly so the operation and maintenance cost

12 of the re-install is going to be a material element. 

13 You have got a janitor or electrician, somebody out

14 there that's re-vamping the building on schedule and

15 the schedule just got longer as a consequence of the

16 lifetime of those products.

17 So for the higher CSLs in particular,

18 where you move to 25,000 hours, you just reduced the

19 labor cost by half.

20 MR. BROOKMAN: Noah?

21 MR. HOROWITZ: Noah with NRDC. First you

22 develop a table, most of the 60 watt-equivalent LEDs
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1 are $10.00 or less right now yet none of the assumed

2 costs in the right-hand column get that low for LED. 

3 Help me understand where the price assumptions were

4 in particular for the whole floor which is --

5 MR. BROOKMAN: Noah, apparently your mic's

6 not on.

7 MR. HOROWITZ: So what I said goes, no. 

8 Sorry about that. Noah with NRDC, the typical LED

9 today for a 60 watt-equivalent is around a $10.00

10 price point, in some cases you know, $8.00 or even

11 less for off-brand names yet none of the prices in

12 the right-hand column reflect the $10.00-ish price

13 value and one could posit that the CSL4 reflects the

14 typical LED, approaching level 5 very soon from an

15 efficacy point of view, and I'm wondering why we are

16 seeing higher numbers there than what one would see

17 in the big box stores at a minimum.

18 MS. KANTNER: I'll let the folks who did

19 the Product Price Determination answer that.

20 MS. HUSAIN: Sure, this is Aisha from

21 Navigant. So these numbers again are based on what

22 we were talking about in the Product Price
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1 Determination or determined based on those weightings

2 that were given to big boxes as well as electrical

3 distributors as well as online retailers and this is

4 the shipment weighted average price. So it's not

5 just the big box prices here.

6 MR. BROOKMAN: Yes Charlie?

7 MR. STEPHENS: Charlie Stephens. There's

8 something yeah, there's something here that's not. I

9 commented on this earlier when we talked about how

10 you are weighting the pricing from one store. I

11 think most people here and I've heard it from the

12 manufacturers already at least a couple of times

13 today where price actually matters of the product.

14 Sometimes big time but we are sort of

15 suggesting that it has no impact on shipments. In

16 other words, when people are faced with a product

17 that cost $2.00 versus the same product in a

18 different package, because there is 2 of them instead

19 of 4 they won't say that wow I can buy 4 of them for

20 two-thirds or half the price per unit of the 2 and

21 I'll buy the cheaper price.

22 If you -- I don't think you are taking
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1 into account here the higher shipments for the less

2 expensive products. If you did I think you would see

3 lower prices here so I don't think the pricing has

4 gone very well. I think the pricing -- product

5 pricing needs to be re-examined here seriously.

6 MR. BROOKMAN: Tom Eckman?

7 MR. ECKMAN: Just to re-iterate that. I

8 don't want to characterize these as sales weighted

9 averages, they are product availability averages. If

10 you are just simply taking one count for one product

11 it's what's on the store shelve that you did the

12 product survey it was on the store shelf and each one

13 gets equal weight. It's not a sales weighting and

14 that's a different -- it's a sales offering but it's

15 not a sales weighting and that's a different matter. 

16 I think Charlie is correct that the sales

17 weighting will turn out to be a lower number as

18 people do recognize the bargain.

19 MR. BROOKMAN: Don Brundage?

20 MR. BRUNDAGE: One observation -- Don

21 Brundage, Southern Company -- one observation I have

22 had on CFLs, excuse me on LEDs, is they are not all
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1 equal. You have directional LED products that I've

2 noticed tend to be less expensive in price while all

3 directional LEDs tend to be a bit more expensive. I

4 wonder if that's part of the confusion here because

5 there's some LED products out there that are not

6 really useable at all in all applications because of

7 the directional nature of LEDs thank you.

8 MR. BROOKMAN: Alex?

9 MR. BOESENBERG: Alex Boesenberg, NEMA. 

10 I'll first start by saying industry is perplexed as

11 everyone else about how the CSLs and prices play out

12 in the TSD and we are still digging into our thoughts

13 as to why it might be that way. So our written

14 comments will have more on this, so without reaching

15 any conclusions today I would point out that some of

16 the areas where we are going to dig into are -- well

17 first and foremost LEDs are still very much an

18 evolving and emerging technology despite the

19 increased product offering, there's still a lot of

20 fluctuation in design and in how we achieve what we

21 are trying to do and what that costs.

22 Also, perhaps not obvious or accounted for
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1 in the data in the way it's analyzed is that as a

2 manufacturer comes up with a good answer for a

3 certain type of lamp, rather than continue to evolve

4 that they put that into the market and let it go

5 awhile and dig into another type. You can come up

6 with a good A-line so now hey let's make a good globe

7 type of something like that so the products are

8 evolving in surges versus a continuous evolution

9 which is more typical in the way to see technologies

10 we are used to dealing with in these rules that are

11 more established.

12 And then also because LED is so new, while

13 there may be a lot of data, it's -- by the time a

14 lamp is a year old it's obsolete. Stuff is being

15 obsoleted month to month so looking at data and

16 trying to find trends in terms of price and quality

17 and everything else is difficult because these

18 products -- you can't say that the one they offer

19 today is going to be similar to the one they are

20 offering in June of 2015 because they may have

21 evolved in a direction that's not iterative so

22 there's a lot of I think assumptions or processes
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1 that have been applied in the past that cannot or

2 will not accurately reflect the way LEDs are and a

3 lot of it has to do with how soon this is all being

4 done.

5 Not to say that we are going to argue it's

6 being done but it begs a step back in our

7 consideration.

8 MR. BROOKMAN: Charlie?

9 MR. STEPHENS: This is Charlie Stephens. 

10 I guess I should add we actually do have monthly

11 sales prices, sales based prices for these products

12 but the question is I don't know if we can put it on

13 the public record and in what form but I can

14 guarantee that my comments will be based on the data

15 that we have in a generic sort of way so I can at

16 least make comments on what's here but we actually do

17 have this data monthly and we are going to continue

18 to collect it monthly going forward and it probably

19 would account for something on the order of 2/3rds of

20 the residential product sales that we see in our

21 area.

22 MR. BROOKMAN: Okay. Yes, Dave?
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1 MR. GATTO: Dave Gatto, Westinghouse

2 Lighting. And Colleen I think you said this earlier

3 and this might actually second everyone's comments

4 that pricing doesn't make a lot of sense to us and I

5 know that DOE is challenged a bit with not having

6 sales data to weight and LEDs are moving kind of

7 quick.

8 But you excluded or backed out -- how did

9 you deal with the rebate because I'm wondering I know

10 you mentioned everything there is for $10.00. 

11 Everything in my area is above 15 but if I drive

12 across the bridge it's $8.00. There are rebates in

13 some areas and not in others so I don't know if

14 that's part of it. I think it's CSL2 and 3 there's

15 just something wrong with how you came up with the

16 numbers but I'm wondering how you -- did you identify

17 the price when it included rebate? How did you

18 address that? 

19 Especially when you are looking at big

20 box, did you look at it nationally? Did you only

21 look at the local store? Maybe you can share that

22 with all of us I think that we are all a little bit
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1 confused about how you came to some of these prices.

2 MS. KANTNER: I'll let the folks who did

3 the Product Price Determination answer that.

4 MS. HUSAIN: This is Aisha of Navigant. 

5 So we as Maureen had mentioned earlier we did not --

6 we made sure that we weren't taking into account

7 prices that were rebated so it was the original

8 price, that's where we took it as a price point and

9 we didn't look locally specifically at a Home Depot,

10 it's more like the online national level and we had

11 confirmed that those online prices were actually the

12 in store prices, there's also like a button the

13 website that can indicate that. Does that answer?

14 MR. GATTO: Thanks Aisha, I'm not sure. I

15 think that when everyone agrees that the pricing

16 doesn't look right.

17 MS. HUSAIN: Sure and I think we'll take

18 into account all of your comments and as Maureen had

19 said we did do a straight average within like each

20 retailer so I think that's the main comment here and

21 we will definitely take that into account. Any

22 information that you can provide us to how you would
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1 want to change the methodology, the weightings would

2 definitely be welcome.

3 MS. DEBUTTS: Lucy deButts. Also to the

4 comment of whether or not you can provide

5 information, some information, some comments that are

6 provided has the confidentiality applied to them so

7 maybe you can do that. 

8 MR. GATTO: I guess that will happen

9 provided the people who give us the data are okay

10 with that, we have to ask them.

11 MR. BROOKMAN: Thank you. Charlie, Noah?

12 MR. HOROWITZ: Some of us looked at this

13 data and we are trying to understand for example

14 level 2 which was the highest priced and for a less

15 efficient product and we have a hypothesis or a guess

16 and I'm wondering if you could respond to this. That

17 if you looked at the LED that was less efficient than

18 today's and came out you know, 18 months -- 2 l/2

19 years ago it was at that lower efficiency point and

20 those bulbs did cost $25-$30.00 apiece.

21 The more efficient bulb delivering the

22 same light output today might be $10-ish dollars so
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1 was it that we are looking at bulbs that have been

2 replaced and are no longer -- we are looking at the

3 older models and that's why level 2 is where it is at

4 or can you expound on that?

5 MS. KANTNER: I'll let Aisha answer, but

6 before that I'll also mention that you will see in

7 the Shipments Analysis how we treated those higher

8 priced lamps as obsolete.

9 MR. BROOKMAN: Aisha?

10 MS. HUSAIN: This is Aisha from Navigant. 

11 So that is correct, so all of these -- the price

12 points are based on products that are available but

13 we were seeing that for the older LEDs so the less

14 efficient ones that they were higher priced than the

15 new ones that were coming online were lower prices so

16 that was a trend that we had noticed.

17 MR. BROOKMAN: Mike?

18 MR. MCGARAGHAN: Mike McGaraghan. I think

19 this goes to the question I was asking earlier and I

20 think you confirmed that when you did the LCC you

21 didn't assume for CSL2 that everybody is buying a

22 $30.00 lamp you assumed that everybody is buying --
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1 you applied a range and some market weights to

2 different products there so it almost doesn't really

3 matter because your own analysis shows that no one is

4 really going to buy the $30.00 lamp, everyone is

5 going to buy the $14.00 lamp even at CSL2. 

6 So if that's how you set up your LCC then

7 a lot of this is --

8 MR. BROOKMAN: So I think we can conclude

9 that the Department will benefit greatly from all of

10 your written comments here. Noah?

11 MR. HOROWITZ: Just to clarify, I'm sorry. 

12 So I guess building off Mike's point it would be good

13 to know when you did the LCC, did you assume the

14 $30.00 cost or there was a range and once you took a

15 weighted average it was more like $14.00? I'm still

16 struggling with that.

17 MS. KANTNER: We assumed, for lamps that

18 were purchased at a particular CSL, that the cost was

19 the cost from the Product Price Determination,

20 although this is the 2014 price and we used the 2020

21 prices, but for lamps purchased at that CSL, the

22 price listed for that CSL is what was used.
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1 However, for the LCC savings there was a

2 distribution of purchases made at different CSLs,

3 which were then weighted based on the shipments

4 expected at each CSL.

5 MR. BROOKMAN: Mike?

6 MR. MCGARAGHAN: Mike McGaraghan, so we

7 would just suggest that you apply the same weighting

8 to costs as you do to savings in the LCC.

9 MS. KANTNER: So there's actually a slide

10 on this later. 

11 MR. BROOKMAN: Let's move on, I think we

12 have covered this sufficiently, keep going.

13 MS. KANTNER: In addition to creating a

14 sample of purchasers, due to the high variability

15 seen in LED lamp prices across lumen ranges, DOE

16 developed a sample of lamps for the integrated low17 lumen product class, which is the only product class

18 that includes LEDs. Lamps were sampled from the four

19 lumen ranges listed here, which correspond to the

20 EISA 2007 lumen bins, with the exception of the

21 highest lumen range, which is truncated just below

22 2,000 lumens since GSLs 2,000 lumens and above are in
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1 a separate product class.

2 These lumen ranges correspond to 40 watt-,

3 60 watt-, 75 watt-, and 100-watt equivalent lamps. 

4 Lamp data for the 60 watt-equivalent lumen range

5 comes from the Engineering Analysis.

6 To determine lamp data for the other lumen

7 ranges, DOE scaled prices from the Product Price

8 Determination using online retail price data and used

9 the efficacy-to-lumen relationship developed in the

10 Engineering Analysis.

11 In order to sample lamps, one needs to

12 know the distribution of lamps by lumen range and the

13 figure in the lower left-hand corner illustrates

14 DOE's estimate of the sector-specific market shares

15 by lumen range, which DOE assumed to be constant over

16 time.

17 For the residential sector, in red, the

18 market share estimates were based on data from the

19 Cadeo Group and from DOE's Residential Lighting End

20 Use Consumption Survey, or RLEUCS. For the

21 commercial sector, in blue, market share estimates

22 are based on model counts for in-based CFLs from the
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1 CPUC's Retail Lighting Shelf Survey, under the

2 assumption that, at least in the commercial sector,

3 the lumen distribution would be similar for in-base

4 CFLs and for screw based CFLs and LEDs.

5 Note that the 60 watt-equivalent lumen

6 range dominates in both sectors, but the commercial

7 sector has a larger share of 75 and 100 watt8 equivalent lamps. And there's an item for comment. 

9 DOE seeks comment on the market distribution

10 estimates for the four lumen ranges analyzed as part

11 of the integrated low-lumen product class.

12 MR. BROOKMAN: It's kind of a small figure

13 in print here. Comments on the lumen ranges

14 estimates, market distribution estimates, nothing

15 here, okay. 

16 MS. KANTNER: To capture variability in

17 operating hours, DOE sampled from sector-specific

18 hours of use distributions. In the residential

19 sector, hours of use were sampled from location- and

20 room-type-specific areas of use distributions. Once

21 a lumen range was selected based on the distribution

22 discussed on the previous slide, a room type would be
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1 sampled from a lumen-range-specific distribution of

2 room types developed from RLEUCS.

3 Note that for the high lumen and

4 non-integrated product classes, the room distribution

5 was assumed to be the same as for the highest lumen

6 range in the low-lumen product class. Independent

7 from the room selection a geographic location would

8 be sampled from the set of households in RECS.

9 Then a room type and geographic location

10 would be used together to select the hours of use for

11 a particular purchaser from a room- and location12 specific hours of use distribution. The room

13 specific hours of use distributions were based on

14 metered data from the Northwest in the Northwest

15 Energy Efficiency Alliance's Residential Building

16 Stock Assessment Metering Study, which were then

17 adjusted for each RECS portable domain based on the

18 average hours of use in that region.

19 The purpose of this procedure was to

20 capture more realistic variability in hours of use

21 for consumers and to allow for correlations between

22 lumen output and hours of use. 
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1 In the commercial sector, due to a lack of

2 available data, a much simpler approach was taken. A

3 triangular distribution was applied to the average

4 hours of use for each building type, such that the

5 minimum hours of use would be 80%, and the maximum

6 hours of use 120%, of the corresponding average hours

7 of use.

8 DOE invites comments and data on its

9 approach to account for variability and hours of use. 

10 This comment is specific to the commercial sector but

11 we welcome comments on the residential sector as

12 well.

13 MR. BROOKMAN: Any comments here? No? 

14 Okay.

15 MS. KANTNER: In the LCC and subsequent

16 analyses the relevant lifetime of a GSL is the age at

17 which a lamp is retired from service, which is not

18 necessarily the same as the technical lifetime of the

19 lamp. To capture variability in lamp lifetime, DOE

20 first developed sector-specific probabilities of

21 survival as a function of lamp age, using Weibull

22 distributions which are commonly used to model
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1 appliance lifetimes.

2 These distributions took into account a

3 lamp's rated -- L70 -- lifetime, sector-specific

4 hours of use distributions, and the effect of on time

5 cycle length for CFLs in the residential sector. DOE

6 found no data to suggest a negative impact on LEDs

7 from on-time cycle length and did not take into

8 account on-time cycle length in the commercial sector

9 because the longer hours of use in that sector

10 suggestion that the impact will be minimal.

11 DOE also assumed no net effect from

12 dimming on either CFL or LED lifetime because there

13 were no data to suggest otherwise. DOE then

14 considered 3 scenarios for lifetime: the first,

15 called the "rated-lifetime" scenario, just takes into

16 account the three factors listed above. In this

17 scenario LEDs can live up to 50 years. The second

18 scenario, referred to as the 

19 "renovation-driven-lifetime" scenario, truncates the

20 rated-lifetime scenario for both LEDs and CFLs using

21 a Weibull distribution with a median of 20 years, in

22 order to account for lamp turnover during renovations
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1 or retrofits. 

2 The third scenario, referred to as the

3 "early-replacement" scenario, considers the impact on

4 lifetime if consumers treat LEDs in a manner similar

5 to consumer electronics and truncates the 

6 rated-lifetime scenario for LEDs using a Weibull

7 distribution with a median of 5 years.

8 Note that in this scenario the 

9 renovation-driven-lifetime approach is still used for

10 CFL's. DOE believes the renovation-driven-lifetime

11 approach is most likely to reflect actual service

12 lifetime of GSLs and therefore has used it for the

13 reference scenario. DOE invites comment on the three

14 lifetime scenarios considered.

15 MR. BROOKMAN: Don Brundage?

16 MR. BRUNDAGE: Don Brundage, Southern

17 Company. I hardly know where to start on the

18 optimistic assumptions embedded in the effective

19 on-time cycling just does not affect the lives of a

20 residential CFL. If you cut off -- on and off a CFL

21 frequently it shortens the lifetime. Anyone who has

22 ever had one knows that because the starters are what
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1 wear out first. 

2 MS. KANTNER: Just to clarify, we did take

3 it into account for the residential sector.

4 MR. BRUNDAGE: Okay, so you did include

5 it. All right. Assume no effect from dimming on

6 their CFL or LED lifetime, do you assume -- what

7 percentage of CFL bulbs do you assume die an instant

8 death because a non-dimmable CFL is placed by mistake

9 in a dimmable fixture?

10 MS. KANTNER: We didn't assume any did.

11 MR. BRUNDAGE: Well mistakes happen and

12 anybody who has ever had a non-dimmable CFL fitted in

13 a dimmable fixture knows its instant death for the

14 CFL once you dim it for the first time, so it may be

15 a 1% number but it is not a zero % number. 

16 Renovation driven lifetime -- I would suggest that

17 renovations where you might want to change a CFL even

18 to a different color temperature could be something

19 as simple as changing the color in a room and for a

20 -- if the walls were beige you might like 2,700K. If

21 it's blue you might like 3,500K. There's an

22 abundance of opportunities in residential settings
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1 that you are going to be changing light bulbs,

2 especially in portable fixtures.

3 The lifetime of a floor lamp or a lamp

4 that sits on a desk is not going to be 50 years and

5 you are probably not going to take the bulb out and

6 switch it to a different lamp when it's -- I'm just

7 saying these -- you are assuming some very high

8 lifetimes that I think are not realistic in true

9 residential service. Thank you.

10 MR. BROOKMAN: Ken Rider has a comment,

11 Ken unmute your phone. We can't hear you yet.

12 MR. RIDER: Sorry there we go. Just a

13 comment on the early-replacement lifetime scenario

14 and I eluded to this earlier -- in earlier comments,

15 but I would think that people who buy the next with

16 being LEDs will not just throw away the LEDs that are

17 in their fixtures and probably rotate them out. You

18 see it in TV's, someone gets a cooler TV they put it

19 in their living room and their old TV moves on to the

20 bedroom or whatever.

21 If you are trying to model the consumer

22 electronics kind of lifetime it's not thrown away
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1 it's just moved to another less used spot in the

2 house so I wouldn't assume that they get thrown away

3 but rather they rotate to maybe a lower usage

4 fixtures or something.

5 MR. BROOKMAN: Charlie Stephens?

6 MR. STEPHENS: Charlie Stephens yeah I

7 would concur with Ken's comment there for the

8 residential screw in fixtures. I think you might

9 apply a renovation-driven lifetime with the pin-based

10 fixtures to some extent because there you know you

11 are going to replace the fixture when you renovate

12 maybe.

13 But screw in products just get moved from

14 fixture to fixture there's no -- if you paid 50 cents

15 for the light bulb maybe not, but if you paid $4.00

16 or $5.00 for the light bulb you are just going to

17 move it to another fixture if you don't like it where

18 it is.

19 But the other -- I think -- so the impact

20 on that would not be that it dies, it just changes

21 its hours of use. It will get moved to another

22 fixture that may have fewer hours of use. 
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1 MR. BROOKMAN: Comment, do we have

2 additional -- yes Noah?

3 MR. HOROWITZ: Noah with NRDC. I'm fine

4 with the first two scenarios you have there, I don't

5 know what the right weighting would be but I have

6 concern of applying the typical turn-over rate of

7 consumer electronics of 5 years and say if you have a

8 25 year rated LED it's only going to be 5 years

9 because people are going to buy the newer and better

10 one and get rid of the other LED. I agree with the

11 other commenters that it is probably going to be

12 moving around the house but I don't think there's

13 going to be as drastic a motivation to replace an

14 existing LED.

15 If it is still giving off the right amount

16 of light it might have been 85 lumens per watt, the

17 fact that the other one is 100 -- or 10 -- lumens per

18 watt, you might be saving 1 l/2 watts. I don't think

19 that 25 year light bulb is going to be taken after

20 that 5 years, so I disagree with the 5 years.

21 In consumer electronics the feature

22 changes are much more dramatic, so the TV that was
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1 that big became that big. The processing doubled, it

2 had wireless, smart TV'S -- you could go on and on. 

3 While we are going to see "smart LEDs" and some

4 improvements in LED I think the incremental

5 improvement is going to be a lot smaller.

6 MS. DEBUTTS: Lucy deButts, DOE. Do we

7 have a number in mind for the early replacement

8 lifetime?

9 MR. HOROWITZ: I don't know but it's

10 bigger than 5.

11 MS. DEBUTTS: Okay.

12 MR. BROOKMAN: Final comments on these

13 scenarios? Okay.

14 MS. KANTNER: Displayed here are the

15 life-time modeling results for the reference scenario

16 in the residential sector. Probability of survival

17 is plotted against GSL age, in years, for a 25,000

18 hour LED and three CFLs with different rated

19 lifetimes. In this scenario, which accounts for

20 renovations and retrofits, there is not a significant

21 probability of survival for any of these lamps past

22 30 years. Note that the effect of on-time cycle
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1 length is significant for CFLs. The probability of

2 failure for CFLs compared to the LED is significantly

3 higher in the early years than just a comparison of

4 the rated lifetimes would indicate due to the

5 reduced lifetime for CFLs in installation locations

6 with short on-time cycles.

7 DOE invites comments and data on the

8 assumptions and methodology used to calculate GSL

9 survival probabilities as a function of GSL age.

10 MR. BROOKMAN: Comments here on survival

11 probabilities? Okay.

12 MS. KANTNER: To account for the different

13 lifetimes of GSLs within a given product class, DOE

14 incorporated a residual value into the lifecycle

15 cost. The residual value represents the remaining

16 dollar value of surviving GSLs at the end of the LCC

17 analysis period, where the LCC analysis period was

18 the lifetime of the shortest lived lamp in a product

19 class. The residual value is applied as a credit to

20 the LCC -- in other words, it is subtracted from the

21 rest of the LCC. The residual value represents an

22 estimation of what the price of the same lamp would
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1 be at the end of the LCC analysis period, taking into

2 consideration the impact of price learning which

3 occurs by that time.

4 The residual value is pro-rated to the

5 remaining lifetime of the lamp and is also discounted

6 to the analysis start year. Another component of the

7 LCC is the disposal cost. The disposal cost is the

8 cost of disposing or recycling lamps at the end of

9 the lamp lifetime. For CFLs, DOE assumed that

10 consumers in the residential sector do not pay

11 disposal costs.

12 10% of consumers in the commercial sector

13 were estimated to pay an average recycling cost of

14 $1.00 per lamp. Because LEDs do not contain mercury

15 DOE has assumed no disposal costs for them. DOE

16 requests comment and data on the disposal cost

17 assumptions.

18 MR. BROOKMAN: Joe?

19 MR. HOWLEY: Yes, on those assumptions

20 your residential assumption is probably correct in

21 terms of them paying for recycling. Your commercial

22 sector assumption is low, I know the commercial
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1 sector uses a lot fewer compact fluorescent lamps but

2 there are over 10 state laws requiring the recycling

3 of all mercury containing lamps meaning that the last

4 time we looked at this number it was probably closer

5 to 35% of all mercury contained lamps are recycled,

6 35 to 40% something closer to that range.

7 And we are just talking about compact

8 flourescents now because they are the only products

9 here that contain mercury and I would say the average

10 recycling cost is closer to 50 cents a lamp for these

11 not a dollar so I think your 2 numbers there are --

12 need to be adjusted for the purposes.

13 MR. BROOKMAN: Thank you Dave?

14 MR. GATTO: Dave Gatto, Westinghouse

15 Lighting. Actually I'm just going to second Joe. I

16 think that the commercial sector is very low --

17 there's a requirement to recycle in quite a number of

18 places. I have to agree with Joe, I think that

19 dollar per lamp was probably based on the GSFL so

20 that's probably about correct for linear but for CFL,

21 I might call it 70 cents, but it's below a dollar.

22 The only other thing I have and it might
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1 be that now finally with LED I have a reason to

2 understand the residual value, but I do want to ask

3 this as a question that has come up in other

4 rulemakings where it would seem meaningless. So if

5 you are using 10,000 hours as a lifetime of the

6 minimum -- the lowest lifetime of a covered product,

7 you are applying what you are calculating is the

8 value of the LED at the end of life value forward. I

9 don't know if I said that right so if the LED is

10 rated 20,000 and the CFL is rated 10 at the end of

11 10,000 hours you are applying a forward value of half

12 of the cost of the LED in the end of life price

13 dollars?

14 MS. KANTNER: Yes, you are calculating

15 what the remaining value is for that lamp past the

16 lifetime of the lowest lived lamp in that product

17 class.

18 MR. GATTO: So only for the purposes of

19 lifetime payback calculation? Where is that being

20 applied because I think if you -- it's in your one

21 scenario you are going to consider the LED lamp is

22 replaced at a certain point, whatever that number is
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1 is fine and then you can't carry a residual value

2 for it forward or is that not what you are saying

3 that you did?

4 MS. KANTNER: It's not taken into account

5 in the payback period. It just looks at the

6 installed cost and the first year operating costs,

7 but it is taken into account in the life-cycle cost.

8 MR. BROOKMAN: Keith?

9 MR. COOK: Keith Cook with Philips. 

10 That's the same line of questioning I had. You said

11 your value only has meaning if somebody is willing to

12 pay for it so what you are saying is actually 10,000

13 hours, somebody takes this thing out to the garage

14 sale and somebody buys it then at whatever the value

15 is that you have estimated. That means that's a

16 whole new cultural change because people don't do

17 that today, they throw away the bulbs at the end and

18 I don't know why somebody would then buy a lamp at a

19 garage sale when they can go to a big box and get a

20 newer one with probably better efficacy at the same

21 price. This doesn't make any sense to me.

22 MS. KANTNER: Well the lamp is still
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1 operating and hasn't been retired from service.

2 MR. COOK: I understand that. But you can

3 get a brand new one at the same price, it doesn't

4 make sense.

5 MR. BROOKMAN: Charlie?

6 MR. STEPHENS: Let me try to explain. 

7 Let's just assume the 30 year analysis period and the

8 lamp you are talking about got purchased in year 28,

9 but it's a 10 year lamp. So what you are calculating

10 for the 30 year life-cycle analysis is the value --

11 the remaining 8 years of the 10 year lamp that was

12 purchased in year 28, am I -- have I got that right? 

13 I mean just as an example?

14 MS. KANTNER: The idea is we want to be

15 able to compare lamps at different CSLs --

16 MR. STEPHENS: Different lifetimes?

17 MS. KANTNER: -- that have different

18 lifetimes.

19 MR. STEPHENS: Right so they are just

20 equalizing lifetimes and comparing it's an analysis

21 function it's not a marketplace function, it's an

22 analysis function.
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1 MS. KANTNER: We are not actually

2 suggesting that people will go out and try to get

3 some money for this lamp on the second-hand market. 

4 We are just trying to assign a value to the fact that

5 some of these lamps live longer and there's a value

6 to the consumer for that longer lifetime.

7 MR. STEPHENS: If you stop your analysis

8 at 10 years and some of the lamps live twice that

9 long then there's a you know, there's a weight there,

10 there's a value there for the half of the product, or

11 the fraction of the product that lives longer than

12 the analysis.

13 MR. BROOKMAN: Tom Eckman?

14 MR. ECKMAN: Tom Eckman, Northwest Power

15 and Conservation. An alternative would have been to

16 include the replacement cost of the shorter lighted

17 bulb so they all match out right. You could do that

18 as well. That's more complicated.

19 MS. KANTNER: That might be more

20 complicated but that would be an alternative

21 approach.

22 MR. ECKMAN: So you do one way or the
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1 other, but you have to normalize so that you are

2 looking at the same lifetime for all product types.

3 MS. KANTNER: Right, I mean the problem is

4 you don't want to penalize a lamp for having more

5 life-cycle cost because it lived longer.

6 MR. BROOKMAN: Okay, we are going to move

7 on now, yes?

8 MR. DELASKI: Just one -- on your number,

9 the recycling costs are probably lower than a dollar

10 and you had 35 to 40% what you estimate of the lamps

11 that are recycled in the commercial sector. Is that

12 your number for linear lamps?

13 MR. HOWLEY: It's the number for all

14 fluorescent technology but generally the way this

15 works in a company if the company has an edict to

16 recycle, the mercury containing lamps, they capture

17 all lamps. Companies are not recycling, some should

18 but they just don't have that edict but if the edict

19 is there they recycle both their CFLs, their

20 pin-based, their linear, everything. It depends on

21 the company culture but what you are saying is 40% of

22 the company cultures are recycling all of their
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1 mercury containing lamps right now.

2 MR. DELASKI: Okay thanks for that

3 clarification.

4 MS. KANTNER: So now to clarify two of the

5 primary results of the LCC analysis, that we started

6 to discuss earlier: The life-cycle cost calculation

7 determines the average cost if all consumers in the

8 sample developed earlier were to purchase a GSL at a

9 particular efficiency level -- at a particular CSL. 

10 The LCC savings calculation, on the other hand, is

11 intended to represent the likely actual impact on

12 consumers. The calculation determines the average

13 cost savings if the standard is set at a particular

14 CSL, considering the market efficiency distribution

15 in the absence of a standard, because some consumers

16 would purchase efficient lamps regardless of what a

17 standard is set. The LCC savings calculation also

18 yields the fraction of consumers expected to

19 experience a net cost if a standard is set at a

20 particular efficiency level.

21 For this rulemaking, a market

22 transformation approach was taken to the LCC savings
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1 calculation which means that the market efficiency

2 distribution was taken into consideration for both

3 the base case, which refers to the case where no

4 standard is set, and each candidate standard case

5 which refers to the case where a standard is set at a

6 particular CSL.

7 The efficiency distributions in the

8 compliance year were projected as part of the

9 Shipments Analysis, using a consumer choice model and

10 historic market share data by GSL technology type. 

11 The consumer choice model will be discussed later.

12 Unlike a roll-up approach to calculating

13 LCC savings, wherein savings are calculated by

14 assuming that consumers who would have purchased less

15 efficacious lamps in the absence of a standard, will

16 purchase the least efficacious options available to

17 them under a standard, the market transformation

18 approach accounts for consumers who would select a

19 more efficacious -- and sometimes less expensive --

20 GSL than the least efficacious option required under

21 a standard.

22 In order to estimate the fraction of
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1 consumers experiencing a net cost, DOE assumed that

2 consumers who purchased the most efficacious GSLs in

3 the efficiency distribution in the base case would

4 also purchase the most efficacious GSLs under a

5 standard.

6 In other words, DOE assumed that the rank

7 order of consumers, in terms of efficiency in a

8 standards case would be the same as in the base

9 case.

10 MR. GATTO: Dave Gatto, Westinghouse

11 Lighting. I'm not sure if this is a question or a

12 comment but I think this is going to play out in the

13 next slide or 2 so somebody, Mike maybe, asked this

14 earlier. You're assuming that the consumer would pay

15 the higher price, that's really what I'm landing on

16 here is if the consumer had a choice between 2

17 products with higher efficiency but one was at the

18 minimum efficiency of the CSL you were analyzing you

19 approached it as if they would pay the higher price

20 that you identified in the pricing determination that

21 we kind of know is a little bit off? I just want to

22 and please Colleen don't take this in any way
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1 insulting, I think that you guys kind of did the best

2 you could with what you had but it's clear when the

3 least efficient product in this same product type is

4 the most expensive option: A, that's probably a sign

5 your product that should have been excluded, and B,

6 consumers wouldn't purchase that anyway. So I just

7 want to make sure I'm really clear, or we're really

8 clear, what you analyzed because if that is the

9 approach then when you get to the payback and you

10 have a hundred year payback I don't think that's a

11 realistic calculation. A calculation that shows that

12 CSL2 the consumer would take a hundred years to get

13 their money back -- in real life that would never

14 happen.

15 MS. KANTNER: I think what you said was

16 not quite correct, so let me try to clarify. So in

17 the Shipments Analysis, which we will discuss later,

18 we estimated the fraction of consumers who had

19 purchased at each CSL. Then we assumed that each

20 consumer who did purchase at a particular CSL paid

21 the price which was originally developed in the

22 product price determination and then price learning
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1 was applied to it. So all the consumers who

2 purchased at a particular CSL paid the same price,

3 but we didn't assume for a given candidate standard

4 case that everyone purchased at the same CSL. That

5 efficiency distribution was developed in the

6 Shipments Analysis.

7 MR. GATTO: Okay, that makes sense. So I

8 guess my comment to that is that it all comes back

9 to, you know, Lucy, we need to redo the price

10 determination piece. I mean that's what it really

11 comes down to because you can apply price learning to

12 a $30.00 price point, now it's a $25.00 price point,

13 the consumer is still not paying that so I don't know

14 what the solution is. I'm saying that a lot of times

15 you are asking -- what's the solution I don't know, I

16 just think that we would all feel better if we had in

17 the analysis that on its face looked like it made

18 more sense than what we saw.

19 And I did skip ahead so I was looking at

20 the next page. It just -- we have got to go back and

21 redo those prices somehow.

22 MR. BROOKMAN: Okay, got it. Let's move
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1 on to the next page.

2 MS. KANTNER: Here we see the base case

3 and standard case efficiency distributions for the

4 integrated low-lumen product class in the residential

5 sector. For each candidate standard case, or CSC,

6 the market share at each efficiency level, or CSL, is

7 indicated.

8 Note that CSLs 1, 4 and 5 are the most

9 popular, and due to the inverted price structure for

10 LEDs, CSLs 4 and 5 are preferentially selected over

11 CSLs 2 and 3. And we have a couple of items for

12 comment. Issue 25, DOE seeks comment on the

13 assumption that in the standards case consumers

14 purchase lamps that are at least as efficient as the

15 ones they would purchase in the absence of standards,

16 and Issue 30, LCC savings and the percent of

17 consumers affected by a standard were determined

18 using the base-case and standards-case efficiency

19 distributions. DOE seeks comment on this approach.

20 MR. BROOKMAN: Keith?

21 MR. COOK: Keith Cook with Philips. I

22 think the reason the industry is so quiet is we are
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1 just befuddled by this whole thing. It doesn't make

2 any sense to us why the more efficacious products are

3 lower cost and why people would be buying less

4 efficacious products over the more efficacious, a

5 little bit more expensive.

6 This whole thing doesn't make any sense to

7 us and we think what's happening in all honesty is

8 this market is so dynamic, it is changing so rapidly

9 that the data is not good and a lot of the data you

10 have got in here I think is the older stuff and it's

11 leading us astray on this whole analysis.

12 MR. BROOKMAN: Okay thank you.

13 MS. DEBUTTS: Lucy deButts, DOE. And as I

14 said in the intro we welcome any help we can get. 

15 Any data you can provide would be useful.

16 MR. BROOKMAN: And you all are familiar

17 with the capacity to execute an NDA through Navigant

18 correct? Don Brundage?

19 MR. BRUNDAGE: Not trying to tell the

20 manufacturers how to do their jobs but I think one

21 thing that might be useful if you could provide more

22 data on the CSL categories. Are there potentially
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1 some specialty products that are sneaking in here

2 such as LEDs that are not omnidirectional in light

3 output or color temperature, I think any -- maybe it

4 is just a mishmash of vintages of products in a

5 rapidly emerging field or maybe there is some clues

6 in here based on some of these are not really

7 general application products that are showing up in

8 weird spots on the payback screen.

9 MR. BROOKMAN: Yes Andrew?

10 MR. GIALLONARDO: Andrew Giallonardo from

11 Natural Resources, Canada. I'm speaking as another

12 regulator in having looked at some of these numbers. 

13 I think we are approaching this a little bit from the

14 point of view that all these consumers are rational

15 so why would they buy these products but we all know

16 that consumers make tons of irrational choices all

17 the time.

18 And we've said that these lamps that would

19 be typically at candidate standards levels 2 and 3

20 are in all senses bad lamps for the consumers to buy

21 and the predicted sales numbers reflect that l/2 a

22 percent, 1.5%, a small fraction of the consumers are
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1 predicted to be buying these lamps. It's an

2 irrational decision but it is probably likely that if

3 these lamps are on the market there is some small

4 fraction of consumers that will buy the lamps simply

5 because not all consumers behave rationally.

6 MR. BROOKMAN: Andrew deLaski?

7 MR. DELASKI: Yeah I just want to concur

8 with the other Andrew to my left that these numbers

9 don't seem crazy to me and this is a very

10 illuminating slide. I think that the notion that

11 there are some less efficacious products out there

12 and they are bought and you are showing l/2 of a

13 percent of consumers are buying CSL2 lamps and when

14 you freshen this analysis for the next stage of the

15 rulemaking I wouldn't be surprised if those lamps do

16 go away because they may be I suspect they are

17 disappearing form the market -- and it would be --

18 but it doesn't really matter. 

19 The point is that you are only giving them

20 1/2 a percent of the market anyway so if they go away

21 or not it's not like it's going to change the

22 results. It's almost a non -- that CSL just isn't
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1 very important is what this is showing me and that's

2 what CSL3 also isn't very important, 1.7% market

3 share so this is a very illuminating slide, thank

4 you, it really shows me and I think your assumptions

5 in Issue Box 25 and 26 seem reasonable. I'm sorry

6 the numbering is off 25 and 30.

7 MS. KANTNER: It matches the TSD.

8 MR. DELASKI: The assumptions here are

9 that you would assume the same ranking in the base

10 case as the standards case for people who would buy a

11 more efficacious lamp, it makes good sense to me. I

12 don't see why their behavior would be changed. 

13 MR. BROOKMAN: Okay Charlie?

14 MR. STEPHENS: Yeah I would like to just

15 second both of the Andrew's comments here while at

16 the same time siding with Dave over here who suggests

17 that maybe after we redo the price work we may see

18 some different numbers and at that point maybe we'll

19 see that the methodology is sound if it delivers a

20 different result when we get better pricing.

21 MR. BROOKMAN: Ken Rider, you are next.

22 MR. RIDER: Just to speak on the topic at
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1 hand. I think this makes a lot of sense just around

2 the fact that the industry typically ends up

3 congregating around certain wattages and outputs so

4 you end up with a large market share for certain

5 efficiencies and also in conjunction with the prices

6 you were talking about makes a lot of sense to have

7 market shares as you have described.

8 Going to an earlier part, I had a question

9 earlier on the LCC with the lifetimes. You said that

10 the remaining life is credited back. My follow-up

11 question to that was what about the remaining value

12 of the energy savings inherent in the lamp, is that

13 also credited or how is that handled?

14 MS. KANTNER: No, it's not credited.

15 MR. RIDER: So then there's potentially

16 missed value of the energy savings left in the lamps?

17 MS. KANTNER: It gets complicated, because

18 you don't know what the efficacy would be of the

19 replacement lamp for the shorter lifetime lamp.

20 MR. RIDER: Well, yeah, so I mean like the

21 LED is the most efficacious in this case are the

22 CSL5, they also have the longest life and the least
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1 efficacious and CSL0 has the shortest life. So the

2 concern is if you did analysis on the basis of the

3 CSL0 life and you go 10,000 hours and then you just

4 credit back the remaining life on the LED you are

5 missing a significant amount of energy savings

6 associated with the LED and the LCC analysis.

7 MS. KANTNER: Thanks for your comment.

8 MR. BROOKMAN: Okay thank you. Noah?

9 MR. HOROWITZ: Noah with NRDC. I want to

10 go back to a point I made earlier and encourage the

11 agency to consider setting a CSL between the current

12 1 and 2 that has the same efficacy as CSL2 but a

13 shorter lifetime to allow for a more efficient CFL

14 than CSL1 to be under consideration, recognizing a

15 CFL of 25,000 hours is unlikely.

16 MR. BROOKMAN: Okay thank you. Yes Mike?

17 MR. MCGARAGHAN: Mike McGaraghan,

18 California IOU's. I think this is finally the best

19 slide for me to get the answer to this question, but

20 I agree with the distribution here and agree with the

21 Andrews, both of their comments. But what I am

22 still not clear on is when you did the analysis for
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1 CSL2 did you assume that that lamp cost $34.00 or did

2 you assume that it cost $34.00 for -- yeah, did you

3 assume that that lamp cost $34.00 for all consumers

4 or did you assume it cost $34.00 only for 49% of the

5 consumers?

6 MS. KANTNER: Maybe we should look at the

7 next slide where it starts to -- the LCC results

8 might be easier to talk about it.

9 MR. BROOKMAN: Yeah move on if that

10 illuminates, yeah.

11 MS. KANTNER: Yeah, but to answer your

12 question: when we calculated the life-cycle costs,

13 which are in the table on the left, that was just an

14 analytical result intended to represent the average

15 cost if all consumers were to purchase at that CSL. 

16 Now on the right-hand side, in the LCC savings table,

17 that's taking into account the base case and

18 candidate standard case efficiency distributions we

19 talked about on the previous slide. So in that table

20 only those in the half of a percent of consumers that

21 purchased at that CSL were paying that installed

22 cost.
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1 So here are the LCC and LCC savings

2 results for the integrated low-lumen product class. 

3 The life-cycle cost results included installed cost,

4 first year operating cost, lifetime operating cost,

5 life-cycle cost and simple payback period which can

6 be compared to the average lifetime.

7 The LCC savings results include the

8 fraction of consumers who experienced the net cost

9 and the average savings experienced by consumers. We

10 see here that for both sectors the max-tech

11 efficiency levels shows the lowest life-cycle costs

12 and the greatest LCC savings. The results displayed

13 here are for the compliance year but due to the

14 rapidly evolving lighting market the TSD includes LCC

15 and payback period results for 2025 as well. Any

16 comments on this slide?

17 MR. BROOKMAN: Noah?

18 MR. HOROWITZ: Maybe Mike can ask this

19 question more articulately. I'm struggling between

20 what costs did you assume for the bulb, let's put

21 aside installed costs and recycling and things like

22 that. Did you use different numbers when you did the
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1 LCC Cost Analysis verses the LCC Savings Analysis?

2 MS. KANTNER: In the LCC cost we were just

3 assuming that all consumers in the sample purchased

4 at that particular CSL.

5 MR. HOROWITZ: At that $30.00 price.

6 MS. KANTNER: Ignoring the four lumen bins

7 for now, then yes, at that $34.00 price. For the LCC

8 savings, we considered the market efficiency

9 distribution, so the fraction of the market that

10 purchases at each CSL, and then those consumers each

11 pay the corresponding price associated with that

12 CSL. 

13 MR. BROOKMAN: In the preceding table.

14 MR. HOROWITZ: I defer to his head nodding

15 does that make sense or not.

16 MR. MCGARAGHAN: I'm trying to match up

17 the rows there. So the right table is really the one

18 that's the output of the whole thing.

19 MS. KANTNER: The right table is intended

20 to give DOE's prediction about what is likely to

21 happen. The left table is intended to illustrate

22 what happens if everyone purchased at that CSL.
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1 MR. MCGARAGHAN: So if you look at CSL2 on

2 the right table it says 27% of consumers experiencing

3 that cost and the average savings is negative. So

4 how can that be if no one is really buying products

5 right at that level, there's only a half of a percent

6 of people buying products right at that level.

7 MS. KANTNER: So it is a very small

8 percentage of consumers buying at CSLs 2 and 3, that

9 small percentage, though, is just enough to push it

10 slightly negative because no one purchases at those

11 CSLs in the higher candidate standard cases.

12 MR. MCGARAGHAN: Okay, thank you we will

13 keep looking at it and I'll come back and make

14 comments.

15 MR. BROOKMAN: Going to move on now.

16 MS. KANTNER: Okay and now here are the

17 LCC and LCC savings results for the integrated high18 lumen product class above and the non-integrated

19 product class below. For the non-integrated product

20 class, the LCC results are displayed separately for

21 the two lamp options at CSL1 from the Engineering

22 Analysis, whereas the LCC savings results are
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1 combined considering the estimated fraction of

2 consumers who select each option.

3 As with the integrated low-lumen product

4 class, both of these product classes show the lowest

5 life-cycle cost and greatest LCC savings at the max6 tech efficiency level.

7 MR. BROOKMAN: Just going to give you a

8 moment to take a peek at this table, there's a lot of

9 data here. Don Brundage?

10 MR. BRUNDAGE: Don Brundage, Southern

11 Company. At least the numbers go the right

12 direction, unlike the previous table. The high lumen

13 classes 2,000 to 2,600 lumens, is that correct?

14 MS. KANTNER: Yes.

15 MR. BRUNDAGE: Okay, just based on that

16 just to comment back on that previous page. It's

17 rather obvious based on your products' lifetimes that

18 CSL2 through 5 were CFLs -- were LEDs -- based on the

19 17 year life span and I do have some -- I did have

20 some concerns in the upper end of the low-lumen

21 product class range, we are at 1,500 to 2,000 about

22 product availability for 1,500 to 2,000 on LEDs, but
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1 you don't tend to find them that large and if you are

2 dealing with compact fluorescents you end up having

3 size limitations so I think there needs to be some

4 analysis in that upper end of the range.

5 I agree with some of the other comments

6 that you can get a form factor like a light bulb for

7 a 100-watt equivalent or 1,300 lumens but then the

8 1,300 to 2,000 you start having size and availability

9 issues first in the CFLs and with the LEDs, so I

10 think some analysis is needed before you set a number

11 up in the high range about whether there needs to be

12 some space constraint classes set up because products

13 don't appear to be on the market right now to satisfy

14 all consumer needs in the 1,500 to 2,000 lumen range,

15 thank you.

16 MR. BROOKMAN: Thank you. Additional

17 comments on this other detailed set of tables, okay.

18 MS. KANTNER: To account for uncertainty

19 in key analysis inputs, DOE considered a number of

20 alternative scenarios. The alternative scenarios for

21 lifetime have already been discussed. DOE also

22 considered an alternative scenario for rare earth
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1 oxide price.

2 In the reference scenario, DOE assumed

3 that the rare earth oxide price was constant at the

4 June 2014 price and in an alternative scenario that

5 rare earth oxide price would be constant at an

6 increased level 4 and half times the June 2014 price. 

7 In estimating electricity prices, DOE used the price

8 projections associated with the Annual Energy

9 Outlook's reference economic growth scenario but also

10 considered alternative scenarios using the

11 electricity prices associated with low or high

12 economic growth. 

13 In addition to calculating LCC savings

14 using the market transformation approach discussed

15 earlier, DOE calculated LCC savings using a roll-up

16 approach where consumers who would have purchased a

17 GSL below a standard level, select the least

18 efficacious lamp available to them.

19 As mentioned previously, DOE also

20 calculated LCC results for 2025, as well as 2020, 5

21 years after the assumed compliance year. Appendix 8B

22 includes results for all of these alternative
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1 scenarios and for alternative scenarios associated

2 with commercial controls, smart lamp incursion and

3 smart lamp stand, which will be discussed later

4 during the National Impact Analysis. And we have an

5 item for comment. DOE invites comment on the two

6 rare earth materials price scenarios analyzed.

7 MR. BROOKMAN: Or any other comments on

8 these scenarios that we have heard so far? Okay.

9 MS. KANTNER: And now my colleague Brian

10 Gerke will present the Shipments and National Impact

11 Analyses. 

12 MR. BROOKMAN: Do we want to break for

13 lunch we have got 10 slides left. We have about I

14 don't know 10 slides should we press on or do you

15 want a break? Want to break for lunch? Okay I guess

16 we are going to break for lunch. I guess so I cast

17 my eyes around the room and I guess most of you want

18 to break for lunch, okay we are breaking for lunch. 

19 It's 5 minutes after 1:00. We'll start back here at

20 2:00.

21 (BREAK FOR LUNCH 1:05 p.m.)

22
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1 MR. BROOKMAN: Welcome back we are going

2 to pick up where we left off so we are going to hear

3 from Brian Gerke. 

4 MR. GERKE: Welcome back everyone. I'm

5 Brian Gerke from Lawrence Berkeley National Lab and I

6 will be discussing the shipments model and the

7 National Impacts Analysis. I apologize in advance, I

8 think I woke up with a bit of a frog in my throat

9 this morning so if I have to clear my throat a lot,

10 that's why.

11 In the Shipments Analysis DOE projects

12 shipments over a 30 year analysis period starting on

13 the expected compliance date of the rule being

14 considered. In this case the analysis period runs

15 from 2020 to 2049. In this preliminary analysis

16 separate shipments projections were computed for a

17 base case and 5 candidate standards cases.

18 The shipment's projection methodology

19 accounts for turn-over and growth in the installed

20 socket for analyzed GSLs in the U.S. Crucially the

21 Shipments Analysis assumed that the EISA 2007 back

22 stop provision will take effect in 2020 so that no
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1 GSLs will be available below the baseline during the

2 analysis period.

3 In the base case and each of the CSCs the

4 shipments are disaggregated among the lamp options

5 considered in the LCC analysis. The disaggregation

6 was performed via a consumer choice model which

7 accounts for consumer sensitivities to various

8 properties of the representative lamps as listed here

9 on the slide.

10 MR. COOK: Keith from Philips. Quick

11 question what do you mean by the candidate standard

12 case?

13 MR. GERKE: A candidate standards case is

14 an analytical case in which the standard is assumed

15 to be set at one of the candidate standard levels. 

16 So there's a subtle distinction between the two.

17 The consumer choice module -- this slide

18 shows a schematic diagram of the consumer choice

19 model that derives the shipments projection. In each

20 year of the model demand is estimated from 3 sources

21 as shown the slide, new construction, direct

22 replacement of retired lamps and the substitution of
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1 lamps considered in this analysis for lamps that are

2 outside of the scope of this analysis such as GSILs. 

3 The estimated demand is then fed into the

4 demand module which apportioned some demand to

5 substitute products outside the scope of this

6 analysis, such as integrated LED luminairres. The

7 remainder of the demand is fed into the consumer

8 choice module.

9 Product price and feature information are

10 also input into the consumer choice module which

11 outputs a projection of the shipments per efficiency

12 level for each of the years being considered. These

13 shipments are then fed back into the price learning

14 module in the following year, which adjusts prices

15 according to a learning curve approach which I will

16 discuss next, to produce price inputs for the

17 following year of the model. Further details of this

18 model can be found in Chapter 9 of the TSD.

19 Learning curves model prices as a power

20 law function of the cumulative historical shipments

21 of a product. In simple terms this means that the

22 price of the product drops by a fixed percentage each
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1 time the cumulative shipments double. As the

2 cumulative shipments grow, the doubling time

3 lengthens and so the annual rate of price decline

4 slows.

5 In this Preliminary Analysis DOE applied

6 learning curves to the two technologies -- CFL and

7 LED lamps -- separately because LEDs were introduced

8 much more recently than CFLs. Early in the analysis

9 period the price of LEDs falls much faster per year

10 than that price of CFLs because LED shipments

11 currently have a much shorter doubling time.

12 DOE found evidence that the learning curve

13 for LEDs has recently been steeper as a function of

14 cumulative shipments than the historical CFL learning

15 curve. That is, the price of LEDs is falling faster

16 for each doubling of cumulative shipments than the

17 price of CFLs did historically.

18 However, in the Reference Analysis DOE

19 assumed that the learning rates for the two

20 technologies were identical at the historical CFL

21 rate. That is, DOE assumed that the LED learning

22 rate for recent years will slow somewhat from its
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1 recent trend. 

2 An Alternative Analysis considered the

3 possibility that the LED learning curve will remain

4 steeper than the CFL learning curve throughout the

5 analysis period. For CFLs, as mentioned earlier,

6 price learning was not applied to the portion of the

7 CFL price that is attributable to the cost of rare

8 earth oxides.

9 This table shows again the product prices

10 from the product price determination. As highlighted

11 in the table the product price determination found

12 that for both CFLs and LEDs, the price of the less

13 efficacious lamp option or options was significantly

14 higher than the more efficacious counterparts.

15 DOE assumed for the purpose of the price

16 learning that this structure occurs because the less

17 efficient lamp options entered the market earlier

18 when the price of the technologies was higher and

19 that these products are now effectively obsolete and

20 will soon be supplanted by cheaper, more efficacious

21 options. 

22 Such lamps would not be expected to
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1 undergo the R&D efforts that would drive price

2 learning. For this reason DOE did not apply learning

3 curves to the least efficacious CFL or to the two

4 least efficacious LED lamp options. The lack of a

5 price trend means that these lamps exit the market

6 quickly in the base case shipments projection.

7 MR. BROOKMAN: Yes.

8 MR. GATTO: Dave Gatto, Westinghouse. A

9 couple of things in here, I think this is the place

10 Colleen was saying that the price learning for CFLs

11 would be priced low, let me start with that. What --

12 we kind of see CFLs as a mature product where there

13 really isn't any more price learning, but what it

14 sounds like you are saying just now is that you are

15 considering the base model as not having any price

16 learning because it is obsolete and that CSL1 which

17 you are still calling CFL on the slide would have

18 price learning.

19 So I think the first thing that I would

20 say there is that CSL0 is not obsolete. It's a

21 covered lamp that we want to make sure we preserve in

22 any rulemaking. It's not obsolete because it's lower
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1 efficiency it's lower efficiency because it meets a

2 certain utility. 

3 For CSL1 I don't know that any of those

4 prices are right so I won't get into that again, I

5 think we all kind of know we need to do some more

6 work, but for CSL1 if you are assuming that this is

7 either an existing CFL that meets the slightly higher

8 efficacy being a bare spiral of your base case or you

9 are assuming that it's to be developed CFL that is

10 slightly more efficient than the current, I would

11 like to know what price learning you applied.

12 I would say for and we can put all of this

13 in the NEMA comments but I guess for the record I

14 would like to say that I don't think there is any

15 more price learning in CFL. There's no R&D, there's

16 no more blood from that stone and the item that you

17 selected is an existing product, it is not a new

18 technology that would have price learning associated

19 with it.

20 MR. BROOKMAN: Thanks.

21 MR. GATTO: So do you know the answer if

22 you apply price learning to the CFLs what price
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1 learning, what percentage and how far out did you

2 take it?

3 MR. GERKE: Well the red curve shows the

4 price learning, or the price trend over time for the

5 CSL1 lamp. As you can see it's fairly flat, it's a

6 very, very minor reduction. Because it is a mature

7 product so the price doubling time is very long, and

8 shipments of this product are declining over the

9 analysis period as you will see, so not much happens.

10 MR. GATTO: Okay thank you.

11 MR. HOWLEY: Joe Howley, GE. If the

12 volume goes down too low it actually might go up to

13 the reverse happening where you see the prices go

14 down as volume goes up.

15 MR. HOWLEY: But you also see the prices

16 go up if volume went down too far.

17 MR. BROOKMAN: Okay yes Mike?

18 MR. MCGARAGHAN: Mike McGaraghan,

19 California IOU's. Brian I'm sorry I know you said it

20 but could you just explain again why you decided to

21 hold CSL2 and 3 with no learning but CSL4 and 5 with

22 learning?
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1 MR. GERKE: The assumption is that those 2

2 lamps are essentially already obsolete products so

3 they are going to remain at the price level that they

4 currently have on the market, not falling any further

5 whereas the more efficacious lamps will continue to

6 be developed, dropping in price.

7 MR. MCGARAGHAN: So just an observation

8 the more -- when you say the more efficacious lamps

9 will continue to be developed, I think what you mean

10 is they will continue to get more efficacious and

11 cheaper. So even -- I mean you could make a case

12 that the current higher efficiency LED lamps right

13 now are going to be a thing of the past in a year or

14 two. 

15 So I guess I don't know how -- what I

16 would propose that you do differently but I'm not

17 sure why one is getting you know, why one has an

18 assumed learning rate and the other doesn't because

19 they are all in the same boat.

20 MR. GERKE: If you can come up with

21 something I'd be happy to hear a comment on it. I

22 understand your concern. In this analysis, I'll say
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1 this later, an efficacy trend was not applied to this

2 either. We are considering ways of handling the

3 issue that you are discussing and input on how to do

4 that is very welcome.

5 MR. BROOKMAN: Charlie Stephens? No,

6 okay. So I just wanted to make sure that we lingered

7 here long enough to get all the comments since this

8 provoked so much comment earlier okay.

9 MR. GERKE: In addition to the baseline

10 trend DOE also found evidence for differential trends

11 in the price of LED, GSLs in different lumen ranges. 

12 The price of higher lumen LEDs has been falling more

13 rapidly recently than the price of lower lumen LEDs. 

14 In this Preliminary Analysis DOE modeled this as an

15 exponential time trend on the price increment between

16 lamps in the lowest lumen range and the higher lumen

17 lamps. 

18 The rates of decline were based on recent

19 market observations. DOE assumed in this Preliminary

20 Analysis that there is no lower limit on these price

21 increments and recent trends suggest that the price

22 difference will rapidly vanish if that's the case as
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1 shown on the figure.

2 DOE seeks comments on these assumptions.

3 MR. BROOKMAN: Charlie Stephens?

4 MR. STEPHENS: Charlie Stephens. Can you

5 say from your analysis what the correlation is

6 between the lower lumens and the lower efficacy? As

7 Mike McGaraghan pointed out earlier if the trend is

8 higher lumen packages and higher efficacy and lower

9 prices which suggests there's some correlation in the

10 data, co-linearity if you will in the lumen levels

11 and efficacy and pricing. So I guess what I'm seeing

12 here doesn't surprise me. It's almost like the two,

13 2 of the lines are CSLs 2 and 3 and 2 of the lines

14 are CSLs 4 and 5. 

15 MR. GERKE: They look similar although

16 these are actually differential movements that we

17 considered.

18 MR. STEPHENS: I get that, I'm just

19 wondering how much correlation there is to where you

20 know why wouldn't this be the case?

21 MR. BRUNDAGE: Don Brundage, Southern

22 Company. This sort of defies just basic engineering
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1 sense. I mean you have to have more lumen material

2 to do twice as much lumen I mean assuming there's

3 improvements in both, whatever materials, electronic

4 stuff in there you are going to have more of it with

5 the one that has twice the light output. Even among

6 the most mature technology imaginable standard

7 incandescents you get a bigger test in filament and

8 it's a slightly more expensive bulb for a 100 watt

9 than a 60 watt so I don't understand. 

10 I feel like you are hearing trends, you

11 are extrapolating trends beyond reasonable limits. 

12 You can come up with exactly the same price across

13 all lamp sizes. 

14 MR. GERKE: So input on what the minimum

15 price difference might be would be extremely helpful

16 in developing a better model.

17 MR. BROOKMAN: Charlie, follow up?

18 MR. STEPHENS: Yeah this is not an unusual

19 thing with technologies in a lot of cases. Once you

20 figure out how to do more with less prices often go

21 down. Once you aren't using as much power you don't

22 need the same heat sink, the product gets smaller, it
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1 gets lighter. You can put more of them in a package

2 and at the same time improve what you are providing

3 and the level of service and it's true across a lot

4 of products and so it doesn't surprise me that we are

5 seeing this trend. It's more light out of smaller

6 packages at higher efficacies.

7 MR. BRUNDAGE: Don Brundage, Southern

8 Company. I would agree with that -- that the same

9 trends would also apply to the 300 through 500

10 lumens. They should still be slightly cheaper than a

11 1,500 lumen lamp, that's what I was saying.

12 MR. STEPHENS: Well I accept that we all

13 saw the earlier LEDs that came out there were no

14 1,600 lumen products because they had not figured out

15 how to make a 1,600 lumen product with a small enough

16 heat sink and a form factor that would actually work. 

17 It took them a while to get to the point where the

18 thing was efficient enough where you could get that

19 kind of lumen output.

20 So early on you see smaller lumen packages

21 and then over time you can get more and more out of

22 less and less and pretty soon you can provide 2,000
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1 lumens in what used to look like an 800 lumen

2 package.

3 MR. BRUNDAGE: But the 800 lumen package

4 would also get cheaper too.

5 MR. STEPHENS: Yes it would but if you are

6 looking at historical data it looks like this.

7 MR. BROOKMAN: Noah?

8 MR. HOROWITZ: Noah with NRDC. I think

9 you've got this partially right. I agree that the

10 cost will be coming down for all these light packages

11 and that the incremental costs will shrink. I don't

12 think it goes to zero, so in a more mature market

13 call it, it looks like eye-balling this 20, 22 or

14 somewhere around there you are saying regardless of

15 the light output all of these bulbs will be the same

16 cost and I think a 450 lumen or a higher volume bulb,

17 call it the 800 lumen bulb is cheaper to make than

18 the 1,600 lumen. It has fewer LEDs, less heat sink,

19 smaller driver so I guess a question to industry is

20 would you price them the same way or do you expect

21 there to be some incremental cost, albeit smaller

22 than what we are seeing today.
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1 So I don't have a proposal what's greater

2 than the zero but I don't think it's zero.

3 MR. BROOKMAN: Okay thank you. Additional

4 thoughts, you see there the issue request box Number

5 40, any additional yes Mike?

6 MR. MCGARAGHAN: Mike McGaraghan. So I

7 would agree with the last several comments and the

8 question I have is why aren't we already seeing or

9 how do we end up with the lines all on top of each

10 other if they are all based on different data

11 streams? I assume that the purple line and the

12 green line and red line are all based on real data

13 that you collected?

14 MR. GERKE: They are extrapolations of

15 real data that a trend is seen in recent years and we

16 have assumed that these are exponential trends and

17 that it can drop to zero which is an assumption

18 because we have no good information on what the

19 minimum price difference might be, therefore the

20 incremental price vanishes under that trend and we

21 are seeking comment on the incremental price would be

22 if any, of a mature product in a mature market.
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1 MR. BROOKMAN: Dave you have some industry

2 perspective?

3 MR. GATTO: I don't know whether I can

4 give that. I think my challenge is that I would

5 agree that the trend is going to continue. I'm not

6 sure if it's at that sequence, my eyes are bad and I

7 can't actually see what year that kicks in. And I

8 agree -- I think we're -- that you are going to have

9 cost differences because there's component

10 differences to deliver those different lumen bins.

11 So what I would suggest is that you have

12 chosen to assume that there's no reason why it

13 wouldn't go to zero and I would suggest is you

14 reverse that. You assume it can't go to zero and

15 re-analyze it. So what those percentages are, you

16 know when we do individual manufacturing interviews

17 we can all provide some confidential data but I'm not

18 sure that I would even know.

19 What I do know though is that the odds of

20 the highest volume item being priced as the same as a

21 lower volume item when the lower volume item has more

22 components is -- it doesn't make mathematical or
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1 market sense to me so I don't know where exactly we

2 will end up. You may be better served to assume that

3 there are similar trends towards higher efficiency

4 lower cost, but that there is no scenario under which

5 that would normalize to zero at the higher lumen

6 levels.

7 MR. BROOKMAN: Okay thank you, additional

8 thoughts on this? 

9 MR. GERKE: The Shipments Analysis made

10 two more key assumptions in the integrated low end

11 product class. First the efficacy of each lamp

12 option was assumed to be constant over the analysis

13 period as I mentioned earlier. Second, a market

14 shift away from GSILs and toward CFLs and LEDs away

15 from GSILs and toward's CFLs and LEDs was assumed to

16 occur in the earlier years in the analysis which

17 slightly boosts shipments in the analyzed lamps.

18 Prior to 2020 a fixed percentage of the

19 GSIL market was assumed to switch in each year. In

20 2020 and after all retiring GSILs were assumed to be

21 replaced by CFLs or LEDs leading to a large spike in

22 the shipments of CFLs and LEDs in 2020 owing to the
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1 impact of the EISA back stop.

2 This figure shows the predicted shipments

3 of integrated low lumen CFLs and LEDs for both the

4 base case and for standards case 5, which assumed a

5 standard set at the maximum efficacy level considered

6 here. The dashed lines indicate the base case; the

7 solid lines indicate the standards case. 

8 As shown in the base case, LED shipments

9 are projected to roughly equal -- the LED shipments

10 are projected to roughly equal CFL shipments by 2020

11 and rapidly supplant them thereafter, however at

12 residual level of CFL shipments remains throughout

13 the analysis period.

14 In the standards case CFLs are eliminated

15 from the market in 2020 leading to a significant

16 boost in LED shipments early in the analysis period. 

17 DOE requests comment on its assumptions regarding

18 market shifts away from GSILs prior to 2020.

19 MR. BROOKMAN: No comments?

20 MR. GERKE: When projecting the shipments

21 of the integrated high lumen and non-integrated

22 GSLs, DOE made some further assumptions. For the
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1 integrated high lumen GSLs DOE assumed that such

2 lamps make up 3% of the installed stock of integrated

3 GSLs in the United States and that this fraction

4 will remain constant over the analysis period. For

5 the non-integrated GSLs DOE assumed that such lamps

6 will remain a constant fraction of the installed GSL

7 stock in the commercial sector throughout the

8 analysis period.

9 DOE also assumed that the reduced wattage

10 non-integrated lamp option, the reduced wattage

11 non-integrated lamp option is a niche product owing

12 to its very limited availability currently. DOE

13 therefore assumed that this lamp option will remain a

14 constant and small fraction of all integrated GSL

15 shipments over the analysis period in the base case

16 and in all standards cases. DOE seeks comment on

17 these assumptions.

18 MR. BROOKMAN: Andrew?

19 MR. DELASKI: Just a question, what is the

20 source on the data for the 3% number on the first

21 bullet for the lamps over 2,000 lumens?

22 MR. GERKE: We had pulled that together
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1 from a number of different sources including the LMC

2 and several of the metering studies that are out

3 there. The details for that were developed in the

4 TSD and perhaps Colleen could tell more?

5 MR. BROOKMAN: Colleen?

6 MS. KANTNER: Colleen Kantner, Lawrence

7 Berkeley National Lab. I believe that was based on

8 model counts of lamps above 2,000 lumens and between

9 1,490 and 1999. 

10 MR. GERKE: So it was looking at the

11 counts of models on the market in the absence of

12 anything else to work from.

13 MR. BROOKMAN: Dave?

14 MR. GATTO: Dave Gatto, Westinghouse

15 Lighting. I just want to make sure that I understood

16 that. So when you say model counts you have looked

17 at those 4 channels of distribution and you saw that

18 there were some over 2,000 products in the market and

19 assumed that some were being bought by consumers for

20 residential purposes?

21 MS. KANTNER: We had market share data on

22 how many were in the highest EISA lumen bin, which
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1 goes from -- I think it's from 1,490 to 2,600 -- and

2 then we did model counts for those that were above

3 and below 2,000 lumens within that grouping and then

4 split the market share between those two classes.

5 MR. GATTO: With the incandescent products

6 in that lumen bin or --

7 MS. KANTNER: For all GSLs.

8 MR. GATTO: Okay, thanks.

9 MR. DELASKI: And how are reflectors

10 reflected in this number? Are they out of this

11 number all together? 

12 MR. GERKE: Reflectors are not analyzed

13 here so this is all for A lamps.

14 MR. DELASKI: Okay so at one point in the

15 TSD it says that reflectors that are not incandescent

16 reflectors might be a general service lamp. 

17 MR. GERKE: They fall under the proposed

18 definition of GSL in the TSD but DOE is not

19 currently considering setting standards for those

20 lamps.

21 MR. DELASKI: So therefore high output GSL

22 -- high output reflectors are not in this report,
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1 okay.

2 MR. BROOKMAN: Joe?

3 MR. HOWLEY: Joe Howley, GE. Your second

4 box there on your continuing prevalence of

5 non-integrated GSLs I assume you are talking about

6 installed fixtures with pin based compact

7 fluorescent?

8 MR. GERKE: That's right.

9 MR. HOWLEY: And you are holding them

10 constant from 2020 to 2050?

11 MR. GERKE: As a fraction of the

12 commercial market for GSLs.

13 MR. HOWLEY: So I would expect that

14 fraction to get smaller and smaller over that 30 year

15 period because low wattage integrated LED fixtures we

16 would expect to become more common over that period

17 and pin based CFLs would probably be less commonly

18 used over that period. So holding it constant over

19 that 30 years is probably it is way too optimistic of

20 an assumption for the continued sale of those

21 products over that time period. I would suggest some

22 kind of decline of that market over that period.
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1 MR. BROOKMAN: Joe would you guess at the

2 decline rate?

3 MR. HOWLEY: I have no crystal ball, all I

4 could say and it's 3% now so how low can it go but it

5 will certainly go lower than that over the 30 year

6 period.

7 MR. BROOKMAN: Yeah.

8 MR. GERKE: Any kind of concrete input on

9 either that or on the 3% of the high, integrated

10 high lumen would be very helpful in trying to develop

11 something more realistic.

12 MR. BROOKMAN: Charlie?

13 MR. STEPHENS: Charlie Stephens. I agree

14 with Joe and one place you might want to go for that

15 I mean just as a start is you might look at the

16 remodel rate for the commercial buildings that have

17 these things because I think starting already, almost

18 every building that's remodeled is going to be

19 putting in some sort of an LED product. If they

20 aren't doing it today by next year they will and

21 certainly by the time these standards go into effect

22 pretty much every building with this kind of fixture
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1 is going to revert to LEDs and they are going to

2 have fancier controls and they are going to be

3 connected and you know -- so I think.

4 MR. GERKE: It would be straightforward to

5 put that assumption in the model. I think that is

6 reasonable that is one thing that we can do but if

7 there is something more sophisticated --

8 MR. STEPHENS: Just look at your remodel

9 rate and maybe there's a plateau somewhere at 20% or

10 something, it doesn't just hangs in there for a long

11 time but the rest of it all gets remodeled into LED

12 over the period.

13 MR. BROOKMAN: Thank you. Two comment

14 boxes here, any additional thoughts before we move

15 on?

16 MR. HOWLEY: Just one last comment on the

17 reduced wattage pin base lamps, it's Joe Howley, is

18 that they are a niche product right now. They

19 certainly aren't available across the whole base

20 product line and there is very limited sales of those

21 today, nor is there availability of all of those in a

22 reduced wattage version so you found a very limited
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1 product to base your analysis on with regard to that

2 reduced wattage and baseline.

3 MR. GERKE: Your statements are

4 essentially the rationale that we used for making

5 that assumption so I'm glad that we agree. 

6 In addition to the Reference Shipments

7 Analysis DOE performed several alternative scenario

8 analyses varying certain key assumptions. As

9 mentioned earlier in its Reference Analysis DOE

10 assumed CFLs and LEDs have the same learning rate and

11 in the Alternative Analysis DOE instead assumed that

12 LEDs have a faster learning rate as a function of

13 cumulative shipments than CFLs, matching recent

14 observations.

15 DOE also performed an Alternative Analysis

16 in which prices were held fixed for all products

17 which allows one to gauge the impact of the price

18 learning on the analysis. In its Reference Analysis

19 DOE assumed an increasing fraction of GSL demand

20 would be fulfilled by integrated LED luminairers

21 growing to 15% of demand by 2049. In two alternative

22 analyses DOE assumed that this end year fraction was
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1 50% or zero at the end of the analysis period.

2 DOE also considered the same alternative

3 lifetime scenarios and the alternative price scenario

4 discussed in the LCC section. DOE requests comment

5 on these scenarios.

6 MR. BROOKMAN: Noah?

7 MR. HOROWITZ: Noah Horowitz, NRDC. Just

8 to reiterate a point made earlier we think the

9 assumption of 5 years that an LED is going to be

10 replaced is too small on the early replacement, we

11 think a larger number is needed for that scenario.

12 MR. BROOKMAN: Yes Keith?

13 MR. COOK: Keith Cook from Philips. Just

14 to comment on rare earth oxides -- I have seen some

15 reports they are out there on the web talking about

16 the rare earth oxides and right now they are saying

17 that they expect those prices to go up again. The

18 reason being of course that China still produces 96%

19 of the world's supply and now they have consolidated

20 their production and they are actually controlling

21 production quantities and so they are anticipating

22 price increases again.
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1 MR. GERKE: Thanks for that comment. If

2 you could put that in the written comments we would

3 be very interested in seeing them. 

4 Okay, two more comment boxes. DOE

5 requests any representative data on GSL shipments as

6 they become them available in order to improve the

7 accuracy of the Shipments Analysis. We have touched

8 on some specific cases where that is true but it is

9 also true in general. 

10 DOE also requests comment and data on

11 current market shares and market trends for GSLs in

12 the commercial sector. 

13 MR. BROOKMAN: Yes Noah?

14 MR. HOROWITZ: Sorry to have this go

15 backwards but this will help us go forward. NOAH

16 with NRDC, if you go to Slide 67, is it possible to

17 blow up the figure in the corner, at the left bottom? 

18 Market share by lumen range -- if not, you can just

19 leave it there so we can see that. 

20 If we can do this we can do anything. All

21 right, I think a general question or a request for

22 more granularity on the data is what does the market
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1 distribution look like earlier? We had a

2 conversation 3% of the models might be in that very

3 high lumen light output bucket. Here it looks like

4 more than roughly a third of the market is less than

5 the old 60 watt light bulb which is larger than some

6 of us might have thought so where did the red bars

7 come from? If you could provide a further breakdown,

8 that would be very helpful.

9 MR. GERKE: Colleen could you field that

10 one?

11 MS. KANTNER: Sure. Colleen Kantner,

12 Lawrence Berkeley National Lab. So the red data,

13 which is for the residential sector, came from the

14 Cadeo Group, where they had data from a major mass15 market retailer directed towards the residential

16 sector. 

17 MR. HOROWITZ: I guess a follow-up

18 question is what's the time period that that data was

19 collected? This gets to 60 watt and 40 watt part of

20 the market just went into effect so if they did it 12

21 months ago we probably didn't see the effect.

22 MS. KANTNER: I believe it's from within
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1 the past year.

2 MR. HOROWITZ: Okay thanks.

3 MR. BROOKMAN: Charlie?

4 MR. STEPHENS: Just a quick question here. 

5 I noticed that this is the first time thanks to your

6 blowing it up that I noticed you are starting or you

7 are ending again there at 750 lumens. It isn't

8 really consistent with the bins you used earlier for

9 selecting product to analyze. You went -- I think

10 you said you were looking for stuff between 700 and

11 900 that sort of yields potentially a little bit of a

12 data inconsistence in the analysis if you are

13 actually using this data for anything. Is that going

14 to introduce any kind of an error band, I guess I'm

15 kind of wondering how much of the product you are

16 referring to with your base case and your analysis is

17 in the 700 to 750 bin versus the 750 to 900 bin

18 because you have got a split here, you have got 750

19 to 1,050.

20 MR. HOROWITZ: Are these the EISA bins?

21 MR. GERKE: Yes these are the EISA bins

22 and it shows it for that reason.
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1 MR. STEPHENS: Is there any benefit to

2 doing your analysis based on the EISA bins if you are

3 going to use this data for that?

4 MR. GERKE: This is the data -- these are

5 the bins in which we were able to get this data is

6 another reason.

7 MR. STEPHENS: I understand that but I

8 guess, you know, sometimes if it is best data

9 sometimes it pays to conform your analysis to your

10 best data or at least I watched a mobile home

11 analysis like this go on where they drew the bins in

12 exactly the wrong places where the same home could

13 fall into two different bins, that's not really a

14 good way to have it.

15 MR. GERKE: I'm not sure how much there is

16 in the 700 or 750 range.

17 MR. STEPHENS: Well I'm equally as

18 concerned about the 900 to 1,050 range which is in

19 the you know, kind of the middle of your -- it

20 divides your next bin here in half.

21 MR. BROOKMAN: Thanks Charlie. Additional

22 comments related to this graphic proposal okay.
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1 MR. GERKE: Any other on this slide -- 

2 MR. BROOKMAN: Okay.

3 MR. GERKE: Now I will discuss the

4 National Impact Analysis or NIA which estimates the

5 national energy savings and net present value that

6 would be associated with each candidate standards

7 case for GSLs shipped between 2020 and 2049. NIA

8 uses the shipments model to estimate the total

9 installed stock of GSLs in each year. These stock

10 estimates are then used to develop an annual series

11 of aggregate national energy consumption and consumer

12 cost values. 

13 The analysis accounts for the time value

14 of money using discount rates of 3 and 7% which are

15 standard in DOE rulemaking analyses. These are the

16 NIA results in the Reference Analysis for each of

17 the standard candidate's standards cases. The

18 national energy savings ranges from .02 to .5 quads,

19 net present value is positive in each case and ranges

20 from 1 to a bit over 2 billion dollars at a 7%

21 discount rate.

22 Each of the alternative scenarios
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1 discussed in the LCC and the shipment sections was

2 also considered in the NIA. DOE also considered

3 several additional alternative scenarios in the NIA

4 only. In the reference scenario DOE assumed that the

5 prevalence of lighting controls increases in the

6 commercial sector over the analysis period as floor

7 space is brought into compliance with building codes

8 that require them.

9 DOE also analyzed an alternative scenario

10 in which commercial lighting controls were held fixed

11 at current levels of penetration to gauge the impact

12 of this assumption. In the reference scenario DOE

13 assumed that the prevalence of smart LED lamps with

14 built-in dimming functionality would grow over the

15 analysis period to reach 50% of shipments of LEDs by

16 the end of the period.

17 DOE performed an alternative analysis in

18 which smart lamps were excluded and another in which

19 the market share grew to 100% by the end of the

20 analysis period. In this Reference Analysis DOE

21 assumed that the stand-by power associated with smart

22 lamps is negligible. DOE also performed an
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1 alternative analysis in which all smart lamps were

2 assumed to have a 1 watt stand-by load when in the

3 off mode.

4 Based on the available evidence DOE

5 assumed zero rebound effect for lighting in

6 residential and commercial sectors. DOE also

7 considered alternative scenarios and higher rebound

8 rates. DOE welcomes comments on these alternative

9 scenarios and on any other scenarios that should be

10 considered.

11 MR. BROOKMAN: Tom Eckman?

12 MR. ECKMAN: What was this? Was there an

13 assumption of the operation of the smart lamps, did

14 they turn themselves off, did they brighten

15 themselves, dim themselves?

16 MR. GERKE: They were assumed to have

17 dimming and so there are assumed to be some energy

18 savings associated with that dimming, it was the

19 standard 30% that we were using for controls

20 throughout the rest of the analysis. 

21 MR. ECKMAN: So that applied in the base

22 case to 50% --
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1 MR. GERKE: By the end of the analysis.

2 MR. ECKMAN: By the end of the analysis. 

3 MR. HOWLEY: Joe Howley with GE. Just you

4 are assuming zero rebound effect but based on your

5 analysis you are showing that more people are running

6 LEDs and CFLs for a longer period of time versus

7 incandescent based on some of the earlier comments

8 which would suggest that there would be at least some

9 rebound effect where people would leave these on

10 longer simply because they don't use a lot of energy

11 and they last a long time as opposed to

12 incandescents.

13 It's just -- it would seem like some

14 rebound effect is more likely than no rebound effect

15 at all.

16 MR. GERKE: To be clear the assumption

17 about the hours of use assumes that CFLs and LEDs

18 are currently used in different applications and

19 incandescents but that during the analysis period

20 incandescents will be gone so the set of 

21 applications --

22 MR. BROOKMAN: Colleen has a comment.
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1 MR. KANTNER: Can you also clarify if you

2 think that rebound is applicable when moving from

3 CFLs to LEDs?

4 MR. HOWLEY: That's harder. I think

5 that's much harder because they are both viewed as

6 long-life products by the consumer, but I think

7 moving from incandescent to LED or halogen there is

8 definitely a perception there that these don't use a

9 lot of energy and last a long time. And it's not

10 just -- you mentioned one reason why there might be a

11 rebound effect, I'm suggesting there is probably more

12 than one reason why there might be a rebound effect

13 and you dismissed one of the reasons but I don't

14 think you have dismissed all of the reasons why there

15 might be a rebound effect.

16 MR. BROOKMAN: Tom?

17 MR. ECKMAN: Unfortunately the history of

18 the deployment of that technology particular CFLs,

19 now LEDs, through utility programs and others is

20 they were told -- people were told put these in high

21 use areas so that the data is biased by the

22 recommendations which we gave the consumer to put
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1 these in high use areas so when we collected the data

2 on whole house lighting versus CFL lighting, CFL

3 lighting clearly was biased high because we told them

4 to put them in places that ran 3 hours a day or

5 longer to start with so it's a factor in the history

6 of the data. We just recommended that they put them

7 in high use areas so it's not clear that there was a

8 rebound there but we told them to put them in

9 kitchens where they use it 4 hours a day instead of

10 closets where they use them a half hour a year.

11 So when we collect the data obviously they

12 did, they took the recommendations.

13 MR. BROOKMAN: You mean they listened, oh

14 my goodness. Dave?

15 MR. GATTO: Dave Gatto, Westinghouse

16 Lighting. And Tom I kind of see where you are at but

17 I would say that I'm kind of where Joe is on that and

18 probably on the smart lamp as well that making the

19 assumption that it's zero from an analytical

20 standpoint is probably not your best reference case. 

21

22 We've seen it with where electricity
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1 prices are high and people are very aware of what the

2 incandescent is costing them. They leave every light

3 in the house off, but I can speak just from my own

4 family. When my wife knew an LED was in she would

5 leave that one kitchen light on so she wasn't in the

6 dark. It sounds silly but I think that there is some

7 whatever that number is, there's probably some minor

8 rebound effect.

9 The other thing is on smart lamp stand-by

10 power it's odd to me that you selected no stand-by

11 power. This is a developing product there aren't a

12 lot out there but they really come -- the lamps that

13 are smart lamps so to speak that are plug and play,

14 traditionally no different than a fan remote control. 

15 There has to be power present, the switch has to be

16 left on for them to offer that functionality and even

17 if it's a very, very minor amount of power, there's

18 some power consumption so that that lamp can wait to

19 hear whatever control signal is coming in, whether

20 it's WIFI or blue tooth or Zigbee. 

21 I don't know what wattage to use, you may

22 want to look at what's out there today and it's so
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1 new that you might have to kind of make a guess but

2 zero doesn't make any sense to me. There would have

3 to be some stand-by power associated with a smart

4 lamp, otherwise the switch is off and it wouldn't

5 work.

6 MR. BROOKMAN: Charlie?

7 MR. STEPHENS: Charlie Stephens. Yeah and

8 I think along those same lines I think it's a mistake

9 to assume that controls and smart lamps enable only

10 the ability to turn the lamp off and therefore

11 there's some amount of energy savings. It also

12 allows you to leave the lamp on. A lamp that you

13 ordinarily would turn off because if you left it on

14 it would be on for days while you were gone, you

15 could leave it on for hours a day while you are gone

16 for 2 weeks on vacation and so now you could leave it

17 on whereas before you might have turned it off just

18 because you didn't want to leave it on for 3 weeks.

19 So I don't think your controls are always

20 going to subtract from energy consumption.

21 MR. BROOKMAN: Okay.

22 MR. GERKE: On rebound I should reiterate
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1 something and I think Colleen mentioned the rebound

2 assumptions that we are using are based on

3 meta-analysis that is published that considered a

4 large number of studies into lighting rebound and so

5 comments that reference that would be especially

6 helpful in developing rebound assumptions.

7 MR. DELASKI: One comment on the rebound

8 it seems like I wouldn't expect at any rebound going

9 from 1 CFL or LED to another so as your incrementally

10 more efficient within those technologies I would

11 expect no rebound.

12 MR. BROOKMAN: Charlie?

13 MR. STEPHENS: I would agree with that I

14 think it's rational to consider some rebound going

15 from incandescent to these other technologies but not

16 from CSL to CSL. 

17 MR. GERKE: These tables show the impact

18 on the results on the reference results for the

19 selected alternative scenarios. The assumptions

20 about lamp lifetime have the most significant effect

21 on the results, both for energy savings and for NPV

22 for both of the alternative lifetime scenarios. 
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1 Assumptions about smart lamps, stand-by

2 power also have a substantial effect on the energy

3 savings. The assumptions about LED learning rates

4 have a moderate impact on the energy savings while

5 the impacts of changing other assumptions are more

6 modest. At this time DOE invites any further

7 comments about the NIA.

8 MR. BROOKMAN: Don Brundage?

9 MR. BRUNDAGE: Don Brundage, Southern

10 Company. So you are showing 100% smart lamp

11 incursion at CSC3 shows a 17% increase in use in

12 quads. 

13 MR. GERKE: 17% increase in the savings. 

14 MR. BRUNDAGE: Oh increase in the savings.

15 MR. GERKE: Essentially because more lamps

16 are dimmable that people are switching to.

17 MR. BRUNDAGE: I really think the smart

18 lamps, I mean if you look at some of the home

19 security things where they have smart lamps and they

20 are having people use their phone to put on lights

21 while they are not there I think a more reasonable

22 assumption would be zero because you are going to
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1 have increased usage and you are going to have

2 decreased usage, but I don't have a clear feel for if

3 it's going to result in an increase in energy savings

4 by having smart lamps.

5 It's providing an easier utility to have

6 that on when you are not home, that can be much more

7 significant than just some dimming.

8 MR. BROOKMAN: Charlie?

9 MR. STEPHENS: And I'll add to what Don

10 said by reminding what Dave said about stand-by

11 power. You are talking now about stand-by power or

12 maybe a half a watt or maybe something like that on a

13 10 watt or an 11 watt lamp which is not trivial. 

14 It's trivial on a 60 watt lamp but it is not so

15 trivial on a 10 or 11 watt lamp. I mean it's 24/7 so

16 you know it's -- yeah and so by the time you take all

17 of that into account with smart lamps I would agree

18 with Don. I'm not sure I would assume there's energy

19 savings.

20 MR. GERKE: Stand-by power is considered

21 separately and is added in the Alternative Analysis

22 that has stand-by power so --
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1 MR. STEPHENS: I thought it was mandatory

2 to consider stand-by power.

3 MR. GERKE: It is and it is being

4 considered.

5 MR. STEPHENS: Okay.

6 MR. GERKE: The assumption in the

7 reference case for this Preliminary Analysis is that

8 that's essentially negligible.

9 MR. STEPHENS: Okay I agree with Dave it's

10 not zero. It'll never be zero but we can argue about

11 what it might be or measure it.

12 MR. BROOKMAN: There's no comment box

13 here. Does any additional -- Susan please?

14 MS. CALLAHAN: I just want to go back to

15 Slide 87. I'm looking at the non-integrated.

16 MR. GERKE: Slide 87?

17 MS. CALLAHAN: Slide 87 yes the

18 non-integrated CFLs and there's no energy savings at

19 all and so I'm wondering why DOE would pursue that

20 particular lamp type in this rulemaking?

21 MS. DEBUTTS: Well when we do the analysis

22 or consider the lamps, all kinds of lamps that could
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1 fit the product classes so we are not saying that we

2 -- this is going to proceed right away, this is the

3 Preliminary Analysis so if you have data that

4 suggests that it should not be done, we do further

5 analysis in the NOPR and if it shows similar results

6 we may not. I mean I can't really speak -- I can't

7 really say that this is going to be done right now. 

8 We are still going to analyze it further.

9 MS. CALLAHAN: And what -- I guess I'm

10 curious what do we think that we have missed in the

11 analysis of those lamps or in that particular

12 category of lamps that would change this?

13 MR. GERKE: I think we want to give

14 stakeholders an opportunity to comment on that.

15 MS. CALLAHAN: Okay.

16 MR. GERKE: Before moving forward.

17 MS. CALLAHAN: Thanks.

18 MR. BROOKMAN: Thank you Susan. Yes,

19 Dave?

20 MR. GATTO: So Lucy then can I ask you a

21 question because I forgot to ask you this before but

22 this might be -- zero might be the one where you will
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1 give it to me. Is there a tipping point where DOE

2 analyzes and says this is a number above which we are

3 going to proceed forward whether we come up with the

4 rule or not. Below this it's not worth the

5 additional effort to analyze, you don't have the

6 number?

7 MS. DEBUTTS: There is no certain number

8 no. I wish there was it would be much easier right.

9 MR. GATTO: Okay it's the same answer.

10 MS. DEBUTTS: There is -- it's fair.

11 MR. GATTO: It's fair.

12 MR. BROOKMAN: Okay so let's return to

13 Slide 89 final comments on these two charts. Okay

14 then we are moving on.

15 MR. GERKE: All right, I'll pass it off to

16 my colleague Hayden Cook from Navigant Consulting who

17 will talk about the Preliminary Manufacturer Impact

18 Analysis and the NOPR Analyses.

19 MR. BROOKMAN: Ken Rider has a question on

20 our comment, Ken unmute your phone.

21 MR. RIDER: Oh there we go, yeah on that

22 chart I saw something awfully confusing and on the 87
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1 there you have the savings in billions of dollars and

2 you know you have got this life-cycle cost that shows

3 pretty good life-cycle savings for let's say CSL4 for

4 the non-integrated lamps the saving of all the money

5 or more money than the .35 quad kind of changing the

6 market -- large market -- and the small economy

7 market changes without really any savings but you

8 have a large NES -- not NES, NMV value. Can you

9 speak to why there is so much money? I don't

10 understand why there's so much money savings without

11 any energy savings.

12 MR. GERKE: Sure that's a lifetime effect. 

13 The higher CSL1 lamps considered in the

14 non-integrated product class has significantly longer

15 lifetimes than the baseline lamps and so fewer of

16 them are purchased over the analysis period which

17 saves money.

18 MR. RIDER: Okay thanks.

19 MR. BROOKMAN: On to Hayden.

20 MR. COOK: Hi my name is Hayden Cook. I'm

21 with Navigant Consulting and I will be discussing the

22 Preliminary Manufacturer Impact Analysis or MIA as
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1 well as the other analyses that we conduct during

2 the NOPR phase of this rulemaking. The purpose of

3 the MIA is to identify the impacts of amended energy

4 conservation standards on lighting manufacturers. 

5 The MIA is conducted in 3 phases. In the first phase

6 an industry profile is developed that identifies key

7 issues for the industry. 

8 In the second phase DOE develops an

9 industry cash flow model called the government

10 regulatory impact model or GRIM to forecast industry

11 cash flows. In this phase DOE also develops an

12 interview guide to facilitate the discussions that

13 will take place during manufacturer interviews.

14 In the third phase, manufacturers are

15 interviewed. Information from these interviews in

16 the GRIM are used to conduct a quantitative

17 assessment of manufacturer impacts due to standards. 

18 Manufacturer interviews are also used to make

19 qualitative assessments of manufacturer impacts due

20 to standard including impacts on competition,

21 competition -- manufacturing capacity, direct

22 employment and cumulative regulatory burden.
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1 The results from the second and third

2 phase of the MIA will be presented in the NOPR phase

3 of this rulemaking. At this time DOE would like to

4 pause here to make a few requests for comment on the

5 MIA. In the first box, DOE requests comment on any

6 key issues that manufacturers want to discuss that

7 they would be facing regarding this rulemaking and

8 potentially request any other data or information

9 that would help assess potential manufacturer impacts

10 due to the standards. And I'm just going to read

11 through the rest of these.

12 Jumping to the third box in the NOPR stage

13 DOE also plans to assess impacts on manufacturer

14 subgroups. These are manufacturing groups that have

15 cost structures that differ significantly from the

16 industry average or face different regulatory

17 frameworks than normal found in industry. DOE

18 requests comments on manufacturer subgroups to

19 analyze as well as characteristics that should be

20 examined for this analysis.

21 And then lastly in the second box one of

22 the subgroups that DOE looks at are small business
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1 manufacturers. If DOE finds that small business

2 manufacturers are impacted by this rulemaking they

3 will conduct a regulatory flexibility analysis to

4 identify ways to reduce the negative impacts on small

5 business manufacturers and DOE welcomes feedback

6 regarding small business manufacturers that should be

7 contacted for this assessment of the rulemaking.

8 MR. BROOKMAN: Yes Noah?

9 MR. HOROWITZ: Noah with NRDC. In terms

10 of the manufacturer subgroup analysis, we would

11 encourage DOE to reach out to manufacturers who might

12 not be in the room today. For example Cree is one of

13 the largest sellers producers of LEDs it would be

14 good to get their input.

15 Similarly companies like TCP are the

16 largest makers of CFLs sold in the U.S. and they

17 also produce LEDs so it would be good to get a

18 diverse set of input rather than just simply from the

19 trade association if possible, thank you.

20 MR. COOK: I think that's an excellent

21 application of a manufacturer's sub-group and we'll

22 definitely look into people that specialize in one
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1 technology or another technology.

2 MR. BROOKMAN: Do we have comments on

3 manufacturer impact analysis key issues and any data

4 information that might come forward here, Charlie?

5 MR. STEPHENS: I just have one question. 

6 Once you get into the LED phase you know, the

7 electronics area, you kind of bring in a whole

8 different group of component suppliers and

9 manufacturing chains that weren't necessarily there

10 before. To what extent are they considered in the

11 analysis?

12 MR. COOK: The -- I think I understand

13 your question. The Manufacturer Impact Analysis does

14 only look at the covered product manufacturers

15 typically and so for this rulemaking the thought

16 process would be they would only be looking at the

17 light bulb manufacturers that are covered for this

18 rulemaking and not necessarily the component

19 suppliers.

20 MR. STEPHENS: I wasn't just necessarily

21 thinking about component suppliers but when we were

22 talking about smart light bulbs those things usually
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1 come with other ancillary enabling technologies that

2 may be provided by any number of other companies that

3 would go along. In other words there are data-bases,

4 there's WIFI there's connectivity going on the

5 Internet of Things -- you know there's all these

6 other things that connect it to your light bulb that

7 are impacted by smart light bulbs for instance.

8 And the advent and the roll-out of smart

9 light bulbs, do they figure into the analysis at all

10 or not?

11 MR. COOK: I mean I don't know want to say

12 anything in stone but I would imagine not. I mean

13 the overall kind of the point of Manufacturer Impact

14 Analysis is to really assess what a standard be it a

15 negative or a detrimental to a manufacturer that

16 produced these products.

17 From what I think I heard there was a

18 potential increase in sales of products that don't

19 exist if there was a smart bulb adoption. I think

20 that would kind of be viewed as a benefit for those

21 manufacturers and probably outside the scope of a

22 typical manufacturer impact analysis on the people
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1 that make the covered products.

2 MR. STEPHENS: I'm thinking about

3 employment for one thing. If you set a standard for

4 instance at CSL4 the employment impact will be

5 different than if you set it at CSL1 I think and not

6 all of the employment impacts would be confined to

7 the manufacturers of the light bulbs.

8 MS. DEBUTTS: Do you have anything to

9 support that assumption that you know we can use?

10 MR. STEPHENS: I wouldn't say there's data

11 but there's conversations going on all over the place

12 that we are engaged with and sometimes at national

13 labs, like Northwest National Labs talking to the

14 various people who are engaged in connecting the

15 Internet of Things and developing apps and setting up

16 databases and data collection and management

17 strategies for the things that are connected you

18 would enable those people substantially if you set a

19 standard that made those light bulbs kind of the

20 standard at some point sooner rather than later, I

21 think -- I'm not sure.

22 MR. COOK: I think for the Manufacturer
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1 Impact Analysis, earlier I talked about there's a

2 quantitative and qualitative group and part of the

3 qualitative would be looking at domestic employment

4 so we could take a look at the potential qualitative

5 ramifications of I would assume an increase in

6 domestic employment for this enabling technology. I

7 don't know if it would be quantitative in its

8 assessment due to the some of the difficulties of you

9 know trying to predict employment from this kind of

10 secondary effect but certainly we can look at the

11 qualitative potential benefits of something like

12 this.

13 MR. BROOKMAN: Any additional comments on

14 all three of these, Manufacturer Impact Analysis,

15 Regulatory Flexibility Act Analysis and Manufacturer

16 Subgroup Analysis, Joe?

17 MR. HOWLEY: Just a general comment that

18 we assume we will be able to provide more specific

19 manufacturing impact feedback during the

20 manufacturing interview process.

21 MR. BROOKMAN: Correct, yes.

22 MR. HOWLEY: Okay.
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1 MR. BROOKMAN: Okay then moving on.

2 MR. COOK: Now I'll briefly discuss the

3 analyses conducted during the NOPR stage of this

4 rulemaking. These additional analyses include the

5 LCC subgroup analysis which conducts an LCC

6 assessment for specific consumer subgroups,

7 different than the manufacturing subgroups. The

8 Manufacturer Impact Analysis phases 2 and 3 of the

9 MIA which were previously discussed will be conducted

10 in the NOPR stage.

11 The Employment Impact Analysis which looks

12 at the indirect effects of national employment which

13 are impacts on net jobs as a result of changes and

14 expenditures and incomes due to amended standards

15 and just a side note this Indirect Employment Impact

16 Analysis is different from the Direct Employment

17 Analysis which is conducted as part of the MIA which

18 I just discussed and which looks specifically at the

19 changes in domestic production employment levels of

20 GSL manufacturers as a result of the amended

21 standards.

22 The Utility Impact Analysis which looks at
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1 the impact on generation capacity of utilities, the

2 Emissions Analysis which focuses on the impacts on

3 airborne pollution emissions, the Monetization of

4 Emission Reductions Benefits Analysis which

5 estimates the monetary benefits from emission

6 reductions and lastly the Regulatory Impact Analysis

7 which identifies potential non-regulatory

8 alternatives to amended GSL standards.

9 And at this point I'll hand it back to

10 Lucy deButts to wrap up on remarks.

11 MS. DEBUTTS: Well needless to say we are

12 expecting lots of comments from people and hopefully

13 lots of data as well. This slide represents again

14 just as a reminder how to submit those comments. 

15 February 9th hopefully we can hear from all of you

16 guys who want to submit your opinions and data and

17 thank you very much for coming. It's been a very

18 productive meeting I think so with that said back to

19 Doug.

20 MR. BROOKMAN: Thank you any final

21 comments before we close? Closing comments here,

22 okay thanks to all of you, safe travels.
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1 (Whereupon at 3:03 p.m.., the meeting was

2 adjourned.)

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befuddled 189:1

beginning 60:13

begins 120:16

begs 157:6

behalf 6:19

behave 191:5

behavior 122:21

192:12

beige 170:20

belabor 124:11

believe 19:19 26:1

47:4 48:10 72:15

73:4,13 74:22

80:11 222:7

230:22

believes 19:20

147:17 169:10

beneath 102:9

benefit 38:5 162:9

232:1 252:20

benefits 97:10

254:11 256:4,5

Berkeley 5:19 7:8

7:10,11 119:6

203:5 222:7

230:12

Berkely 87:19

best 186:1 194:18

232:8,10 238:20

better 46:14 99:17

126:21 129:8,10

131:4 132:18

173:9 179:20

187:16 192:20

214:16 219:2

beyond 49:6 73:4

92:16 140:1

150:17 214:11

biased 142:1,11

237:21 238:3

big 79:12 107:8

111:1,3 115:9

116:3,8 117:2,5

125:11 143:3

152:17 153:2,5,14

158:19 174:1,1

179:19

bigger 126:17

174:10 214:7

biggest 109:18

biggie 74:11

bill 130:20

billion 233:20

billions 247:1

bin 54:22 222:22

223:6 231:17,17

232:20

bins 54:6 55:1,7,8,9

55:19,21 74:5,7

96:7 150:7 163:20

197:6 218:10

231:8,20,21 232:2

232:5,11,13

bit 18:16 19:5 24:19

68:6 75:7 87:3,12

97:9 109:5 110:14

110:20 122:11

137:5,9 142:6

151:1 155:3 158:5

158:22 185:21

189:5 190:13

203:8 231:11

233:20

BLE 76:20

blood 209:16

blow 229:17

blowing 231:6

blue 105:15 164:21

170:21 239:20

board 125:4

boat 211:19

Boesenberg 2:13

38:1,2,2 155:9,9

book 6:4 105:15

boost 220:16

boosts 219:17

bottom 24:7 84:2

131:7 229:17

bought 118:13

191:12 222:19

bound 53:20

box 19:18 63:21

107:8 111:1,3

115:9 116:4,9

117:2 152:17

153:5 158:20

179:19 192:5

217:4 224:4

244:12 249:5,12

249:21

boxes 11:1,1 47:19

63:18 101:21

153:2 226:14

229:4

brainstorming

137:9

brand 48:12 180:3

break 8:10 101:22

102:3,13 103:2

105:13 128:21

129:1,3 202:12,15

202:15,16,18,21

breakdown 230:7

breaking 202:18

breaks 128:16,17

Brenda 104:22

Brendan 103:22

Brian 3:4 7:11 37:4

202:9 203:3,5

210:19

bridge 158:12

brief 8:2,5

briefly 255:2

brighten 235:14

bring 13:8 17:11

84:12 99:14 251:7

broad 26:16 27:9

53:1 101:17,18

broadly 27:20

broken 143:20

Brookman 5:2,9,22

7:5,20 10:11 12:2

13:9 17:12,14,16

19:17 20:5 22:6

24:1,20 25:7 26:3

26:11 27:13,22

28:22 29:6,12

30:11 32:1,17

33:13 34:5 35:17

36:7 37:2,9 38:1,9

39:14,21 41:9,16

42:4,11 43:12

45:7 46:1,19 47:9

47:19 48:1,17

49:13 50:20 53:7

54:3,20 55:12

56:4 58:7 59:5,19

60:9 61:3,19

63:13,17,20 67:3

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brought 37:5 234:7

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bucket 230:3

buckets 55:2

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building 1:10 5:7

102:5 133:13

135:14 146:16,18

151:14 162:12

166:15 167:4

225:18,22 234:7

buildings 85:19

137:3 146:13,14

146:14 225:16

built-in 234:14

bulb 24:12 25:15

34:11,13 36:10,10

36:15,17,18,19

67:8 82:14,14

115:3 118:9,9

125:4 127:1

130:17 132:1,8

133:8 160:21

171:5 172:15,16

173:19 181:17

196:20 200:6

214:8 216:16,17

230:5 251:17

252:6,19

bulbs 24:8 31:3

33:3 55:22 84:8

117:12 118:14

132:1,11 133:2

160:20 161:1

170:7 171:1

179:17 216:15

251:22 252:7,9

253:7,19

bulk 26:20 113:16

bullet 23:2 24:4

90:9 93:12 221:21

bunch 112:3 113:10

113:12

burden 248:22

Burns 3:11

business 105:1

249:22 250:1,5,6

businesses 125:2

button 159:12

buy 35:1 40:17 84:6

113:14,15 116:6,6

116:7,16 118:8,18

123:2 153:19,21

162:4,5 171:15

173:9 179:18

190:15,20 191:4

192:10

buying 34:12 38:7

40:13 161:21,22

189:3 191:1,13

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C

C 5:1

Cadeo 164:19

230:14

calc's 87:9,9

calculate 94:9 175:8

calculated 76:21

90:11 93:16 113:6

116:20 143:22

145:7,12,18

184:13 195:12

201:15,20

calculating 87:21

178:7,14 180:9

184:12 201:13

calculation 72:20

141:5 145:16

147:21 150:22

178:19 183:6,10

183:12,17 184:1

186:11,11

California 6:19 28:3

32:4 58:9 61:21

87:1 96:4 110:14

123:21 125:19

141:15 142:8

149:18 194:18

210:19

Caliper 34:9

call 8:7 81:14 92:10

92:18 115:12

177:21 216:13,17

Callahan 2:18 6:6,6

94:3,3,11,11

244:14,17 245:9

245:15,17

called 5:18 168:15

248:9

calling 114:21

208:17

Canada 190:11

Canada's 6:22

candelabra 18:2

candidate 64:16

145:20,20 184:4

187:3 188:5

190:19 195:18

198:11 203:17

204:11,13,15

233:6

candidate's 233:17

candidates 87:5

cans 80:6

Cao 4:5

capacity 51:21

189:17 248:21

256:1

capped 99:19

capture 44:16 75:15

90:18 97:10

165:16 166:20

167:19 182:16

capturing 98:14

cards 105:1

care 32:10

careful 83:3 101:16

Carlo 145:4

Carol 4:10

carry 179:1

carve 131:21

132:15

case 68:13 80:20

81:10 84:1 108:17

121:3 125:19

128:13,14 129:5

136:6 143:8

145:19,21,21

184:3,3,4,5 185:3

185:8,9 187:4

188:2,3,5,13

192:10,10 193:21

195:17,18 203:14

203:17 204:3,12

204:13,14 208:6

209:8 211:11

212:22 213:20

220:4,4,6,7,8,14

221:15 231:16

233:7,19 235:22

238:20 244:7

cases 109:22 132:11

143:10 145:20

152:10 198:11

203:17 214:19

221:16 229:8

233:17

cash 248:9,11

Cassidy 103:22

cast 202:16

catalogue 89:8 90:1

90:13,13 94:7,13

94:16 97:6 111:7

categories 12:19

52:2 97:15 189:22

category 40:8

245:12

caught 23:10 74:19

cause 33:2

causing 29:2

caution 31:21

cautious 30:16

35:11 74:14 142:7

caveat 30:13

CBECS 146:15

CCT 42:19 65:21

114:1

Celia 7:3

cell 9:11

cent 25:16

center-base 137:10

center-based

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CFL 13:7 18:12

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CFL's 169:10

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30:10,17 31:1

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challenge 74:5

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challenged 158:5

chance 103:17

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chances 83:9

chandeliers 138:11

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86:2 89:18,18

124:1 160:1

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changed 58:11

192:12

changes 44:6 45:6

172:20 173:22

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changing 83:5

170:19 171:1

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channel 106:1,12,13

107:2 114:15

117:11

channels 106:3,6

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characteristics

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characterization

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142:15

characterize 154:8

Charlie 2:15 6:14

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79:22 80:1,11

84:10 85:14,17

115:21,22 118:1,5

124:8 127:7

137:20,21 139:15

142:17 153:6,7

154:16 157:8,9

160:11 172:5,6

180:5 192:13

212:5 213:3,4

214:17 225:12,13

231:3 232:21

240:6,7 241:12

243:8 251:4

chart 96:18 99:15

246:22

charts 96:12 246:13

cheaper 109:3

153:21 207:20

211:11 215:10

216:4,17

cheapest 127:3

150:16

check 115:16 131:8

checked 8:2 105:2

China 228:18

choice 131:6 184:9

184:11 185:16

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205:10

choices 116:4

125:10 190:16

choose 125:3

chose 96:12

chosen 218:12

Chuck 104:12

circuit 56:12

circuitry 52:14

claim 71:22

Claire 4:8 103:22

clarification 25:6

133:1 183:3

clarify 78:16 124:2

131:11 136:2

142:13 162:11

170:2 183:4

186:16 237:1

class 30:22 53:10,10

53:16,17,19 64:12

65:11 66:3,5,9,14

66:18,20 69:17,20

69:22 70:2,7 71:3

71:7 72:3,15,17

74:7 77:3 88:9

89:13,16,20 91:13

91:14,16 92:22

93:5,7,21,22 94:9

94:19 95:6 101:15

108:16 109:2,7

143:20 145:6

147:4,16 150:5

163:17,17 164:1

165:11 166:6

175:13,19 178:17

188:4 196:2

198:18,19,20

199:4,21 219:11

247:14

classes 13:3 51:8,19

51:20 52:4 58:5

64:9,10,20,22

65:3,9,18,20

66:16 67:2 69:8

69:16 70:4 72:7,8

73:21 90:21 91:1

91:4,6,8,9 95:10

100:8,17 101:1

110:10 132:15

144:5 166:4 199:4

199:13 200:12

223:4 245:1

classification 72:4

classifications 40:22

clear 19:13 23:4

45:20 62:7 186:2

186:7,8 194:22

203:9 236:16

238:7 243:2

clearance 115:7

cleared 5:12

clearly 54:10 73:13

127:1 238:3

close 11:21 105:3

111:2 256:21

closely 24:19 25:5

61:6 138:16

closer 49:2 118:2

177:4,6,10

closet 128:16

closets 127:22

238:10

Closing 8:21 256:21

clues 190:5

co-linearity 213:10

coatings 56:10

code 14:13

codes 135:14 234:7

coffee 102:8,10

cold 126:21

colleague 55:19

92:5,13 202:9

246:16

colleagues 5:18

87:11 118:1

collect 113:21

157:18 238:11

collected 105:18

110:15,16,21

111:7 113:19

114:4 116:11

124:18 217:13

230:19 238:1

collecting 126:1

collection 253:16

Colleen 2:17 7:7

87:16,18 88:5

119:3,6 158:2

185:22 208:10

222:4,5,6 230:9

230:11 236:22

241:1

Collins 3:10

color 170:18,19

190:3

colored 42:17,21

43:3,7,8

column 44:8,9

152:2,12

combined 134:6

199:1

come 34:3 35:2,3

82:14 86:4 88:8

101:9 112:2

116:16 118:2

131:14 136:16

142:15 156:5

178:3 198:13

211:20 214:12

230:7 239:12

246:3 251:4 252:1

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116:15 134:18

156:2 164:5 187:8

187:11

coming 33:20 38:11

97:4 150:13

161:15 216:10

239:19 256:17

commend 106:20

comment 11:21

17:1 19:15 27:8

32:19 36:8 37:3

39:1,2,8,11 42:15

47:19 48:19 55:18

59:6,8,18,20

61:21 63:18,21

66:22 70:18,21

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commenter 126:8

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98:21 100:6,6

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128:10 130:5

134:10 144:14

155:14 157:14,16

158:3 159:18

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167:13 171:14

174:12 175:7,10

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196:16 198:14

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209:13 212:7

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Commission 96:5

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65:19 66:17 73:10

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123:10 224:16

commonly 20:12

24:18 106:17,19

138:11,12 167:22

224:17

compact 16:11 18:5

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52:11 177:1,7

200:2 224:6

companies 182:17

250:15 252:2

company 6:9 16:20

27:15 92:13 101:6

122:19 141:19

154:21 169:17

182:15,15,21,22

199:11 213:22

215:8 242:10

comparable 113:22

compare 31:4

135:20 138:17

180:15

compared 15:8 69:4

133:22 135:10

175:2 196:6

comparing 180:20

comparison 175:3

compatibility 84:18

95:16

compatible 78:18

83:14 84:19

competition 15:10

248:20,21

compiled 94:5

complete 9:7 105:3

105:3

completely 22:14

compliance 14:6

15:1,2 89:14

120:17 184:8

196:13 201:21

203:13 234:7

complicated 39:19

42:6 130:15 131:8

181:18,20 193:17

component 34:8,20

176:6 218:9 251:8

251:18,21

components 35:6

52:6,8,13 56:12

57:21 91:11

105:14 218:22

comprising 18:6

computed 114:3,5

114:12 203:16

concentration

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concept 126:16

concern 30:12 32:4

32:10 47:14,18

54:15 79:4,12

80:13 84:17 85:9

85:13 173:6 194:2

211:22

concerned 47:12,16

54:7,8 86:18

101:7 232:18

concerns 31:1 73:22

109:19 199:20

concise 9:9

conclude 162:8

concludes 144:12

conclusion 140:3

conclusions 155:15

concrete 225:8

concur 172:7 191:7

condition 33:9

conditions 126:21

conduct 13:19

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248:16 250:3

conducted 51:2

75:21 120:1 248:5

255:3,9,17

conducts 255:5

conference 139:10

confidence 58:16

confidential 218:17

confidentiality

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configuration 84:11

108:19

confined 253:6

confirm 32:7

confirmed 89:17

90:5 93:13 159:11

161:20

conform 232:9

confused 159:1

confusing 59:1

108:18 246:22

confusion 155:4

congregating 193:3

Congress 16:22

17:10

conjunction 193:5

connect 252:6

connected 226:3

253:17

connecting 253:14

connection 37:18

connectivity 252:4

consequence 151:15

consequences 27:21

conservation 1:2

5:5 7:2 65:14

151:6 181:15

248:4

conservations 15:11

consider 24:5 31:4

44:2 54:16 60:8

62:3 109:1,6

115:14 117:10

131:18 132:15

178:21 194:11

241:14 244:2,22

considerate 97:17

consideration 61:22

78:21 89:17 92:18

95:9 108:15 110:9

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184:2 194:14

considerations

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considered 14:5,6

16:16 37:7 44:10

56:11 63:2,6 96:1

117:4,7,8 121:10

128:15 168:14

169:14 197:8

200:19,22 201:10

203:14 204:5

205:1,12 207:2

213:17 220:5

228:2 234:2,2

235:7,10 241:3

243:20 244:4

247:13 251:10

considering 12:8

15:6 18:3,14 19:1

19:4,9,10 22:3

38:14 39:17 41:20

42:13,18 44:6,12

44:15,18,20 52:3

52:17 53:10,15

56:8 65:2,8 74:2

75:18 89:6,21

92:22 183:14

199:1 208:15

212:2 223:19

considers 15:12

75:19 146:3 169:3

consist 56:17

consistent 93:20

124:13,15 231:8

consolidated 17:20

228:19

constant 164:15

201:3,5 219:12

221:4,6,14 224:10

224:18

constitutes 13:21

constraining 132:16

constraint 200:12

construction 204:21

Consulting 5:19

7:17,19 246:16

247:21

consumer 27:16

31:19 33:10 34:20

34:21 35:2 44:5

52:1 79:15,19

80:14 95:18 106:6

106:8 108:22

112:20,22 116:14

117:7 126:18

129:14 132:17

144:20 147:19

169:5 171:21

173:7,21 181:6

184:9,11 185:14

185:16 186:12,20

187:13 200:14

204:6,7,17,18

205:7,10 233:11
Energy Conservation Standards Preliminary Analysis for General Service Lamps

January 20, 2015

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237:6,22 255:6

consumers 15:7

34:11 35:13 40:13

51:14 52:10 55:2

74:8,13 75:1

80:12 84:5,8

89:19 98:8 110:7

110:9 117:17

119:11 122:22,22

131:5 150:15

166:21 169:4

176:10,12 183:7

183:12,15,18

184:14,18 185:1,2

185:7 186:6,18

187:1 188:13,17

190:14,16,20,22

191:4,5,13 195:3

195:5,15,20 196:8

196:9 197:3,10

198:2,8 199:2

201:16 222:19

consumers' 133:10

consuming 104:8

consumption 38:22

69:3 129:19,21

130:1,2 139:1

146:11,15 164:20

233:11 239:18

240:20

contacted 250:7

contain 176:14

177:9

contained 177:5

containing 177:3

182:16 183:1

contains 52:5

content 9:10 13:14

29:7

context 120:6,15

continue 43:9 46:11

59:13 73:15 103:5

123:3 130:4 156:3

157:17 211:5,9,10

218:5

continued 224:20

continues 30:15

continuing 8:12

224:4

continuous 12:13

56:2 68:8 90:20

91:7 156:8

contracts 106:11

111:4

contrast 135:5

contributions 56:5

control 30:20

125:19 134:14

138:2 139:18

239:14,19

controllable 134:22

135:8 138:3,5

141:7

controlling 228:20

controls 119:17,20

123:19 124:3,5,20

125:16,22 126:4

134:12,13,14,15

134:16,19 135:4,7

135:10,13,21

136:2,8 137:10,11

139:14,16,20

141:1,21 142:1,12

144:7,10,11 202:2

226:2 234:5,10

235:19 240:9,19

convenience 117:10

convenient 117:14

conventional 25:14

41:12 67:8,11

conversation 10:7

97:8 230:2

conversations 9:12

253:11

conversion 57:19

convert 57:3

converters 57:3,12

57:13 58:19,21

converts 25:21

Cook 2:14 3:5 6:4

7:18,18 33:14,14

41:9,10,11 47:11

47:11 61:4,4 78:6

78:6 96:10,10,22

109:16,16 123:13

123:14,14 179:9,9

180:2 188:21,21

204:10 228:13,13

246:16 247:20,20

250:20 251:12

252:11 253:22

255:2

cooler 171:18

copy 105:1

corner 164:13

229:17

correct 17:13 32:11

108:1 136:5

154:16 161:11

176:20 177:20

186:16 189:18

199:13 254:21

correlation 213:5,9

213:19

correlations 166:21

correspond 11:2

163:19 164:2

corresponding

105:20 167:6

197:11

cost 8:16 15:8,8

33:21 34:20 36:21

37:12,16 38:3

44:5 61:11,15,18

61:22 62:2,19

99:3,10 107:7,12

107:15,22 108:9

116:20,21 117:13

118:20 119:8

144:13,18,20,20

145:8,8,8,13

146:20,21 148:1,8

151:11,19 153:17

160:20 162:14,18

162:19 175:15

176:7,7,8,13,16

177:10 178:12

179:6,7 181:16

182:5 183:6,7,13

183:19 185:1

189:3 195:1,2,3,4

195:15,22 196:3,3

196:4,4,5,8 197:1

197:2 198:3 199:5

207:7 216:10,16

216:21 218:9

219:4 233:12

247:2 249:15

costing 239:2

costs 37:13,20 87:20

145:2,6,14,15

147:6,17,22 148:7

148:13 149:16

151:8,9 152:2

155:21 163:8

176:11,15 179:6

182:9 195:12

196:11,20,21

216:11

Council 6:17 7:2

151:6

Counsel's 7:4

count 154:10

counter 139:5

counterparts

207:14

counting 138:10

country 142:9,12

143:3

counts 164:22 222:8

222:11,16 223:2

couple 46:7 71:11

71:12 119:20

121:14 135:16

153:12 188:11

208:9

courier 11:20

course 9:3 14:6

71:17 228:18

cover 49:14 71:17

103:7 105:9

coverage 8:9 15:14

15:17 23:3 24:21

25:1 42:9

covered 9:1,10 24:9

39:3,18 40:2

51:20 63:17 68:12

71:14,21 98:12,16

102:1 103:3

107:16,18 108:14

108:16,17,17,18

109:7,18 139:19

140:22 163:12

178:6 208:21

251:14,17 253:1

covering 53:4

109:12

CPUC's 165:1

crazy 191:9

create 25:15 74:6

136:18

creating 68:2

100:17 163:13

credit 105:7 175:19

194:4

credited 193:10,13

193:14

Cree 250:12

CRI 42:18 44:3,21

97:16 114:1

criteria 14:8 20:10

23:7 24:17 29:19

39:4 51:10 70:19

72:16 101:16

121:19 124:22

126:18

Crucially 203:20

crystal 225:3

CSC 188:5

CSC3 242:11

CSCs 204:3

CSL 84:2 88:13,14

89:17 90:17 92:8

93:21 94:18 95:12

98:5,6,11 105:18

105:21 106:14

107:7 143:21

145:7 146:8

149:18,20,22

150:1 162:18,21

162:22 163:4

183:9,14 184:6

185:18 186:19,20

187:2,4 188:6

189:22 191:22

194:11 195:15,21

197:4,10,12,22

241:16,16

CSL0 109:3 194:1,3

208:20

CSL1 87:4,6 88:15

88:22 89:1 91:7,8

92:7,19 93:19

94:19 95:3,20

107:15,21,22

109:3 113:21

150:14,17 194:14

198:21 208:16

209:3,6 210:5

247:13 253:5

CSL2 88:15 89:2

91:7,12,14 92:8

158:14 161:21

162:5 186:12

191:13 194:12

195:1 198:1

199:18 210:21

CSL3 91:17 99:15

192:2

CSL4 91:20 152:13

210:21 247:3

253:4

CSL5 91:22 193:22

CSLs 64:16 89:6,8

89:10,11,15,21

90:20 91:3 93:1,7

95:9 145:22

150:21 151:17

155:11 163:2

180:15 188:8,10

188:11 198:8,11

213:13,14

cultural 179:16

culture 182:21

cultures 182:22

cumulative 205:20

206:1,2,14,16

227:13 248:22

curious 67:6 104:7

130:5 245:10
Energy Conservation Standards Preliminary Analysis for General Service Lamps

January 20, 2015

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current 44:15 47:4

47:6 54:21 55:20

120:19,21 122:5

194:11 209:10

211:12 229:11

234:11

currently 12:16

18:8,19 25:17,20

38:16 39:6 46:13

53:12 57:22 75:18

92:1 121:4 206:11

211:4 221:12

223:19 236:18

curve 12:14 56:2

68:2,3,6,15,15,18

90:4,5,12 93:11

93:13 205:15

206:12,15 207:3,4

210:3

curved 96:5

curves 205:19 206:6

208:3

customers 82:13

cut 169:20

cycle 13:21 43:22

44:19 168:5,7,8

174:22

cycles 13:19 175:6

cycling 169:19

Cymbalsky 17:7,7

17:13,15 31:6

32:12,19 49:4

Cymbalsky's 123:6

Cymbalsky- 2:8

D

D 5:1

D.C 5:8

daily 121:13 134:7

dark 30:7,10 239:6

darker 69:19

dash 91:5

dashed 220:6

data 10:18 39:9,12

90:1 93:8 94:4,5,7

94:13,16 95:22

97:6,13 105:15

110:15 111:9,21

112:4,7 120:1,4

121:18 124:10,17

125:12 126:2

127:9 133:14

134:5 135:19

137:12 138:4,16

140:20 141:22

142:7 143:8,14

148:3 156:1,13,15

157:14,17 158:6

160:9,13 164:4,6

164:8,18 166:14

167:2,8 168:6,13

175:7 176:16

184:10 189:9,9,15

189:22 199:9

213:10 216:6

217:10,12,15

218:17 221:20

222:21 229:5,10

229:22 230:12,14

230:18 231:12,13

232:3,4,5,8,10

237:21 238:1,6,11

245:3 249:8 251:3

253:10,16 256:13

256:16

data-base 94:14

96:11

data-bases 95:22

252:3

database 26:6

databases 89:15

253:16

date 15:2 120:17

203:13

dates 14:6 15:1

Dave 2:10 6:10 22:7

22:9 23:14 25:7

34:5,6 39:14,15

45:7,9 54:3,4

73:19 79:2,3 80:9

80:10 82:10 97:2

97:3 114:15,19

148:14,15 157:22

158:1 177:13,14

185:10 192:16

208:8 218:1

222:13,14 238:14

238:15 243:10

244:9 245:19

Dave's 100:6

David 3:12 4:4 25:9

day 8:19 35:9 36:13

101:9 102:12

121:14 122:1,13

130:17,19 131:2,4

131:9 134:9 137:1

238:4,9 240:15

days 240:14

DC 1:12

deadlines 10:17

deal 15:6 113:13

115:10 158:9

dealing 17:2 83:4

156:10 200:2

death 170:8,13

deButts 5:14,15

10:10,11,12 13:15

13:16 26:3,4,4

130:8,8 160:3,3

174:6,6,11 189:13

189:13 244:21

246:7,10 253:8

256:10,11

deButts- 2:4

decaying 90:8

December 14:16,17

14:21 15:1,3

decided 210:20

decision 130:19

191:2

decline 206:3

212:18 224:22

225:2

declining 210:8

decrease 145:14

decreased 243:2

decreases 70:4

147:5

dedicated 40:11,12

40:17

Defense 6:17

defer 197:14

defies 213:22

define 18:21 43:6

45:10

defined 18:9,10,19

28:4 45:11

defines 54:1

defining 19:1 20:14

42:18

definitely 54:7

82:11 118:19

159:21 160:2

237:8 250:22

definition 15:18,19

15:20 16:5,9

18:11,22 19:9

20:18 21:3 28:8,9

28:11 41:15 42:17

43:3,4 45:19

47:15 53:1 85:21

133:16 223:18

definitions 42:13,16

43:1,13 52:18

53:8

deLaski 3:3 104:15

104:15 112:1,2

113:8 114:7 137:7

137:8,17 182:8

183:2 191:6,7

192:8 221:19

223:9,14,21 241:7

delay 5:11

deliver 99:18

218:10

delivering 160:21

delivers 192:19

demand 204:20

205:3,4,4,7

227:19,21

demonstrated

142:20

Department 1:1 5:4

5:7 6:22 7:3,22

9:4,14 10:2 12:7

17:1 96:5 105:4

112:6 132:14

162:9

Department's 13:11

depending 106:3

140:7,10

depends 138:18

182:20

deployment 237:18

Depot 113:9 115:2

117:6 159:9

Depots 113:1

depreciation 44:17

Dept 2:1 3:1

derive 35:16

derives 204:19

described 35:7

193:7

design 51:17 56:13

57:12 58:5 62:18

62:19 63:6 64:15

86:7 90:16,18

155:20

designated 87:15

designed 40:6 52:8

73:6 77:8,18 85:1

85:4,22 86:1,4

designer 85:1

designing 85:6

desk 171:4

despite 155:18

Desroches 7:9,9

detail 15:17 38:10

62:5 114:16 147:9

148:10 149:7

detailed 10:3 43:15

52:21 135:14

144:15 200:17

details 120:3 205:17

222:3

determination 8:14

12:15,20 21:16

103:6,8 105:10

147:3 152:19

153:1 159:3

162:19 164:8

185:20 186:22

187:10 207:10,11

determinations

12:12

determine 23:11

29:17 51:8 75:22

89:8 126:2 146:7

146:22 164:6

determined 18:6

20:11,20 21:2,12

21:21 22:18 53:20

65:19 76:4 119:12

135:7 153:1

188:17

determines 183:7

183:12

detrimental 252:15

develop 20:2 64:8

93:7 95:12 105:17

106:13 119:9

145:3 151:22

225:10 233:10

developed 40:3

60:16 61:2 64:16

106:1 119:15,22

145:5 146:6 147:2

150:4,6,8 163:16

164:9 166:2

167:20 183:8

186:21 187:5

209:9 211:6,9

222:3 248:6

developing 19:22

37:7 76:7 105:12

149:1 214:16

239:11 241:6

253:15

develops 248:8,11

device 19:7

diagram 51:3

204:18

dial 136:10

diameter 133:7

die 170:7

dies 172:20

differ 249:15

difference 35:15

100:9 107:18

108:14 110:5
Energy Conservation Standards Preliminary Analysis for General Service Lamps

January 20, 2015

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115:4 125:6,7,7

143:3 212:22

214:15 217:19

differences 97:20

98:13 101:11,15

108:13 125:8,9,10

218:9,10

different 28:19 30:4

30:22 71:16,16

72:1,1,10,11

83:11 84:1,14

87:3 88:13 96:17

106:15 108:16,22

110:22 111:2

113:10,13,14

114:11,11 116:7

126:10,11 130:15

131:15 136:8

139:9 150:7

153:18 154:14,15

162:2 163:2

170:18 171:6

174:18 175:12

180:15,16,17

192:18,20 196:22

212:11 217:10

218:10 222:1

232:13 236:18

239:14 249:16

251:8 253:5 255:7

255:16

differential 212:10

213:16

differentiate 137:10

differentiated

137:19

differently 116:14

211:16

difficult 79:1 105:13

118:16 156:17

difficulties 254:8

difficulty 5:12

dig 155:16 156:5

digging 155:12

dim 139:8,10,13

143:5 170:14

235:15

dimmability 131:7

135:18

dimmable 22:21

135:3,6 138:8,12

138:13,17 141:7

141:16 142:21

170:9,13 242:16

dimmed 75:6

139:20 140:1,6

dimmer 55:22

83:11

dimmers 134:16

135:1,20 136:10

137:6 138:3

140:14

dimming 139:1,6,9

139:12 143:1,6

168:12 170:5

234:14 235:17,18

243:7

dining 138:11

139:22 143:4

diode 18:19

diodes 16:12,13

direct 204:21

248:21 255:16

directed 14:12

230:15

direction 61:12

156:21 199:12

directional 155:1,3

155:7

directly 8:8 64:10

64:20,21 65:8

102:8 105:11

disaggregated

204:4

disaggregation

204:5

disagree 173:20

disappearing

191:17

discontinued 63:10

discount 148:6,7,11

233:14,21

discounted 145:16

176:5

discover 81:17

discovered 125:17

126:1

discreet 105:13

discuss 5:17 10:13

10:16 11:6 15:17

16:8,14,15 18:16

19:5 21:1 37:8

39:5 46:17 56:6

150:6,22 183:6

186:17 205:16

233:3 249:6 255:2

discussed 11:10

75:17 108:7

119:20 124:3

146:2 147:9 149:7

165:22 184:11

200:21 201:14

202:3 228:4 234:1

255:9,18

discussing 203:6

212:3 247:21

discussion 10:22

37:6 44:14 46:4

55:15 149:7

discussions 248:12

dismissed 237:13,14

displayed 143:21

174:14 196:12

198:20

disposal 145:8

176:7,7,11,15,16

disposing 176:8

disproportionate

121:1

distinction 62:17

204:16

distinguishes 146:1

distributed 140:15

distribution 69:11

87:13 106:1,3,5

106:13 107:1

110:22 111:14

114:14 140:15

146:3 163:2

164:12 165:3,9,14

165:21 166:1,4,12

167:3 168:21

169:7 183:14

184:2 185:3 187:5

194:20 197:9

222:17 230:1

distributions 113:5

145:19 165:18,20

166:13 167:22

168:2,4 184:7

188:3,19 195:18

distributor 117:7

distributors 106:7,9

106:10 112:20

113:3 153:3

diverse 250:18

divided 51:20 93:3

divides 232:20

dividing 145:13

division 53:11 91:5

docket 11:13,13,18

14:18

document 11:12

14:16 26:5 28:19

58:12

documents 11:4

12:10 14:18 26:8

DOE 12:12 13:18

14:16 16:1,14

17:8 18:2,6,10,14

19:1,8,10 20:8,9

20:10,13,20 21:1

21:8,12,14,16,21

22:3 26:4,13 28:9

29:16,18 30:5

31:6 32:7,11,13

34:17 38:13,16

41:19 42:8,16,17

43:14 44:1,6,11

44:18,20,22 48:4

49:4,5,18,19

51:19 52:3,17

53:10,11,15,19

54:16 56:8,11,16

58:1,10,16 60:3

60:17,22 62:2,6,9

63:7 64:7,9,10,13

64:16,19,21 65:2

65:8,10,19 66:1

66:16,22 68:21

69:2,8 70:18,21

71:4,7 75:13,17

75:21 76:3,8,13

76:18,21 77:1

87:2 88:20 89:6,6

89:10,16,20,22

90:5,11,15 92:22

93:2,6,8,13,16,19

95:8,11,13,15,17

95:21 97:16 98:22

105:6,11,16 106:2

106:5,15,20,22

120:9,13,15 121:6

121:12,15,18

130:7 133:13,20

134:4,6,11,20

135:2,12,17,19

146:6 147:16

148:12 150:11,14

158:5 163:15

164:7,15 165:9,17

167:8,19 168:5,11

168:13 169:10,13

174:6 175:7,13

176:9,15,15 185:1

185:6 188:12,19

189:13 200:19,21

201:2,7,15,19

202:5 203:11

206:5,12,18,21

207:15 208:2

212:10,14,19

213:2 220:17,22

221:1,5,9,12,16

223:18 227:7,9,11

227:15,19,22

228:2,4 229:4,10

233:15 234:2,4,9

234:12,17,20,22

235:4,6,8 242:6

244:19 246:1

248:8,11 249:3,5

249:13,17,22

250:1,5,11

DOE's 20:3 32:5

50:7 164:14,19

197:20

doing 15:5 49:11

84:7 85:18 123:10

225:20 232:2

dollar 175:16

177:11,19,21

182:9

dollars 61:8 160:22

178:13 233:20

247:1

domain 166:17

Dombrowski 4:7

104:2

domestic 254:3,6

255:19

dominate 107:9

dominates 165:6

Dominic 104:1

Don 2:7 6:8 16:19

27:13,14 30:11

33:8 35:10 36:14

48:17 101:4,5

108:11 122:17,18

126:13 131:16

141:17,18 154:19

154:20 169:15,16

189:18 199:9,10

213:21 215:7

242:8,9 243:9,18

Don's 32:20

dot 58:10 60:4 62:8

dots 57:13 58:20

60:1,2 61:5,14

62:22 63:8

double 70:10 206:1

doubled 174:1

doubling 206:2,11

206:16 210:7

Doug 2:3 5:8,16,20

10:14 47:21

256:19

downstream 61:13

dramatic 173:22

drastic 173:13
Energy Conservation Standards Preliminary Analysis for General Service Lamps

January 20, 2015

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draw 68:18

drawn 146:10,13

drew 232:11

drive 123:22 158:11

208:1

driven 75:2 130:18

170:16

driver 37:12,20

57:8 91:19 216:19

drives 141:13

driving 118:5 141:5

drop 73:3 85:11

109:21 217:17

dropping 73:11

211:6

drops 85:8 205:22

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57:14 58:2 120:7

135:14 144:3

147:6 163:14

167:1 175:4 188:9

196:13 248:17,19

249:10 254:8

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E 5:1,1 117:12

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107:17 123:6

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153:9 158:2 159:5

161:19 171:14,14

183:6,8 185:14

193:8,9 194:10

201:15 207:5,17

212:8 213:7

215:13 219:13,16

227:9 228:8 230:1

231:8 236:7 254:1

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174:7 175:3 206:8

215:20 220:16

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136:20 140:20

151:4,5,5 154:6,7

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235:11,12,21

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131:18 168:4,11

170:5 174:22

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239:8 241:20

242:2 247:12

254:10

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169:18

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215:6

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64:14 65:13 66:1

66:19 68:22 69:1

69:9,15,22 70:3,5

70:6,11,14,19,22

71:5,9 78:9 90:10

91:22 92:16 93:16

99:3 184:15,16,19

184:20 185:2,4

189:2,4,4 191:11

192:11 193:21

194:1 201:18

207:13,14,20

208:3,4 211:5,8

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43:20 44:12 51:8

52:13 53:13 56:8

56:13 57:1 63:2

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92:18 93:1,3,9

94:10 95:3 96:13

96:15 152:15

179:20 193:18

194:12 209:8

212:1 213:6,8,11

219:11 220:5

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164:9

efficiencies 72:12,12

193:5

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12:14 49:18,21

50:8,9 57:8,18,21

59:11 61:16 68:1

68:16 71:18 76:19

76:20 83:5 91:19

98:13 119:12

121:9 125:3,6,9

131:13 141:22

142:3,4 145:19

160:19 166:15

183:9,14,20 184:1

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185:18 187:5

188:3,6,18 195:18

196:11 197:8

199:6 205:11

209:1,1 211:12

219:3

efficient 36:20,20

36:21 38:5 56:10

56:15 57:2,11,13

58:18,20 71:14

72:22 91:10 94:21

94:21 99:6,10

107:11 109:11

130:20 133:8

145:1 150:13

160:15,17,21

161:14 183:16

186:3 188:14

194:13 207:17

209:10 215:18

241:10

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120:11 121:19

128:13 150:7

163:20 203:21

220:1 222:22

231:20,21 232:2

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49:6 69:2 74:21

77:8 80:16 97:17

142:4 168:12

209:7 212:2 225:9

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106:10 113:3

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104:21 153:2

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151:13

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electronic 76:4

214:3

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34:2 129:14 169:5

171:22 173:7,21

251:7

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eliminate 72:6,15

72:16 74:6 92:15

101:8

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eliminates 109:19

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169:18

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155:18 190:5

emission 256:4,5

emissions 105:7

256:2,3

emissive 56:10

emitted 57:4

emitter 57:18 62:9

emitters 57:16

emitting 16:12,13

18:19 19:7 56:18

employment 248:22

253:3,4,6 254:3,6

254:9 255:11,12

255:15,16,19

enable 240:9 253:18

enabling 252:1

254:6

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enclosed 132:2

encourage 10:3,18

11:16 31:2 60:3

60:21 62:13

150:18 194:10

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energy 1:1,2 2:1 3:1

5:4,8 6:15,19 7:4

7:22 8:16 9:5,14

12:7 15:9,11

26:18 27:11 29:20

31:3 35:13,15

38:21 44:5 45:2,4

45:16 46:7,9,9,13

46:16,22 47:5,13

47:14 48:5,11,19

48:20 49:1,3,6,8

49:11,18,20,22

50:3,5,8,12 51:21

53:22 61:16 65:14

69:3,3 71:22

72:21 73:14 74:21

75:15 78:3 83:4

85:12 105:4 119:3

119:7,8,10,11,17

119:19 120:11

124:6 125:18,22

126:4 129:16,18

129:19,21,22

130:2 131:13

134:12 135:20

138:21 139:2

141:21 142:2,4

143:20,22 144:1,1

144:9,11,12 146:5

146:11,14 148:4

166:15 193:12,16

194:5 201:8 233:5

233:11,18 235:17

236:10 237:9

240:11,20 241:21

242:2,4 243:3,18

244:18 247:11

248:3

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253:12,14

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44:14 51:18 64:3

64:6,8 75:14

119:13,15 150:4,9

164:5,10 198:21

213:22

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89:15

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entire 72:6,16 89:12
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environment 31:13

31:20 33:10,11

EPACT 26:1 27:18

equal 84:9 134:3

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equation 89:21 90:7

90:12 93:1,11,17

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75:18 89:21 93:1

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136:22 164:14

182:10 184:22

233:8

estimated 105:11

106:11 107:1

133:13 142:20

148:3 176:13

179:15 186:18

199:1 204:20

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135:2 148:5

164:18,21 165:10

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161:21,22

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100:11 155:18

156:8 196:14

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111:21 118:9

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115:11 118:5

123:6 133:18

160:13 180:13

250:12

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163:20

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115:18 158:8

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excuse 58:9 154:22

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22:3 38:16,21

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14:3 21:5,9,12,14

23:10 27:18

exist 27:6 28:9

101:19 129:15

252:19

existence 42:7

existing 14:3,10

25:17 44:2,8,9,12

65:14 66:2,20

123:4 173:14

209:7,17

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216:20 224:13,16

228:17 241:8,11

expected 88:1 163:4

183:18 203:13

207:22

expecting 74:12

77:12 79:5 256:12

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255:14

expensive 123:1

126:16 131:5

150:12 154:2

155:2,3 184:19

186:4 189:5 214:8

experience 36:2,4

82:12,18 147:6

183:19

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experiencing 185:1

198:2

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explain 81:7 180:6

210:20

explaining 114:17

126:9

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explicitly 16:5,9

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exponential 90:8

212:15 217:16

expound 161:4

express 12:6

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40:15 42:8 118:2

172:10 251:10

exterior 20:18

external 52:8,16

extrapolated 120:4

extrapolating

214:11

extrapolations

217:14

extremely 26:14

214:15

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eye-balling 216:13

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face 187:17 249:16

faced 61:9 153:16

facilitate 248:12

facilities 85:8

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fact 33:15 36:5

37:12 47:14 60:13

109:19 128:21

150:15 173:17

181:4 193:2

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76:15,16 108:5

114:2 115:19

133:3 200:6

215:16 238:5

factored 32:14 99:9

factors 15:6,11

168:16

fail 31:16 33:2 35:6

123:4

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fair 246:10,11

fairly 77:21 81:17

210:5

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falling 206:15 211:4

212:12

falls 206:9

familiar 9:3 45:17

102:4 189:16

family 239:4

fan 22:13 34:16

239:14

fancier 226:2

far 10:20 22:13 28:7

37:6 47:16 88:18

118:17 133:21

150:17 202:8

210:1,16

fashion 108:13

fast 60:18,19

faster 206:9,15

227:12

feasibility 56:20

feasible 29:22 51:11

64:18 75:10 91:15

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173:21 205:9

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256:15

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250:5 254:19

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187:16 214:10

243:2

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172:22 177:1

216:18 247:15

field 79:20 125:17

190:5 230:9

figure 112:6,8

164:13 165:12

213:1 214:20

220:2 229:17

252:9

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filament 19:7 214:7

fill 56:10

filled 121:5

filling 121:4

filter 115:16 139:17

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final 14:1,22 15:3

48:19 49:15 60:21

85:14 89:9 97:19

120:10 174:12

246:13 256:20

finalizes 34:17

finally 16:4,16

64:19 145:17

178:1 194:18

find 35:12 45:21

50:13 54:12,13

88:1 98:16 107:17

111:5 125:14

127:12 128:17

138:4,6 140:5,9

156:16 200:1

finding 62:21

finds 20:8 250:1

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first 13:21 16:8

52:22 64:9 65:19

66:6 69:20 70:11

71:13 74:22 83:10

90:8 93:8,11 94:7

98:6 112:19

121:15 128:20,21

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26:5 44:22 53:11

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67:13 76:13

120:22 121:12

122:2,4 125:19

134:7 142:22

168:6 205:18

206:12 207:11

212:10 226:22

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four 51:10 163:18

165:10 197:6

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146:17 151:6

181:11 183:18

184:22 186:18

190:22 191:4

196:8 197:9 199:1

221:3,6,14 224:11

224:14 227:19,22

framework 14:16

109:7 128:11

frameworks 249:17

frequency 44:3

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169:21

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function 12:15

167:21 175:9

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227:12

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234:14 239:16

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39:22 45:1 55:10

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22:9,9 23:14,14

23:22 25:9,9,19

39:15,15 45:9,10

54:4,4 73:19,19

79:3,3 80:10,10

81:2,5 82:10,10

97:3,3 114:19,19

148:15,15 149:9

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159:14 160:8

177:14,14 178:18

185:10,10 187:7

208:8,8 209:21

210:10 218:3

222:14,14 223:5,8

238:15,15 245:20

246:9,11

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234:11

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19:20 26:12 35:19

48:9 49:18 55:19

71:12 77:5 82:21

100:5 121:22

139:6 210:11

224:3 236:3

general 1:4 5:6,18

7:4 13:1,20 15:19

16:2,6,10,12

17:19 18:16 19:2

20:18,22 21:3,14

21:18 22:19 23:8

26:15,20 28:4

30:12 36:14 38:13

41:15 53:14 54:11

59:18 60:7 64:7

67:13 98:21

110:20 150:3,8

190:7 223:16

229:9,21 254:17

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66:10 67:18 84:18

135:6 138:8 142:3

182:14

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37:4,4 202:10

203:3,4,5 204:13

210:3 211:1,20

212:9 213:15

214:14 217:14

219:9 220:20

221:22 222:10

223:12,17 224:8

224:11 225:8

226:4 227:3 229:1

230:9 231:21

232:4,15 233:1,3

235:16 236:1,16

240:22 241:17

242:13,15 243:20

244:3,6,16 245:13

245:16 246:15

247:12

getting 22:13 25:13

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give 23:18 129:5

160:9 197:20

199:7 218:4

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144:5 153:2

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12:18 16:17 22:6

22:10 24:2 27:1,2

34:13 37:13,14

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114:15 116:2,3

117:18 127:3

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187:20 191:16,20

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228:17 229:14,15

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244:14 246:21

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goals 48:22

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216:12 223:1

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127:2,4 128:20

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GSIL 21:9 219:19

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120:7 205:2

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GSL 16:5 21:3,6

22:14 90:7 92:22

112:18 120:10

121:16 125:5

133:16 146:6

167:16 174:17

175:8,9 183:8

184:10,20 201:17

221:6,14 223:18

223:21 227:19

229:5 255:20

256:8

GSLs 1:4 15:21,21

15:22 16:7,8,11

16:15,16,17 17:18

18:1,5,17 19:6

20:7,9,11,13,16

20:17,19 21:2,15

21:19 29:16 30:5

30:9 38:13,14,15

38:21 41:21 52:5

64:8 65:4,5,6

105:11,16 106:22

112:17 120:18,19

121:4,5,7 122:6

123:1 133:20,22

134:1,13 135:13

139:14 140:16

146:18,20 148:9

163:22 169:12

175:13,16 185:2,4

203:20 204:1

212:11 220:22

221:1,3,5 223:7

224:5,12 229:11

233:7,9

GU24 40:6 42:1

GU24's 40:7

guarantee 83:13

157:14

guess 28:13 32:5

49:21 67:17 68:16

80:2 81:2 82:18

97:5 112:4 114:22

123:15 157:10

160:8,15 162:12

187:8 202:15,16

202:17 209:13

211:15 213:11

216:19 225:1

230:17 231:14

232:8 240:1 245:9

guidance 26:5,5

guide 248:12

guiding 84:8

gut 131:8

guy 80:13

guys 22:12 35:15

128:14 186:1

256:16

H

hair 35:1

half 151:19 153:20

178:11 181:10

195:20 198:5

201:6 232:20

238:10 243:12

hall 102:7,9

hallways 73:9 85:1

127:22

halogen 39:7 122:3

237:7

hamstringed

122:19

hamstrung 123:9

hand 9:18,20 64:2

183:10 193:1

256:9

handed 105:1

handle 17:3

handled 193:13

handling 212:2

hands 80:8

hangs 226:10

happen 160:8

170:11 186:14

197:21

happening 189:7

210:13

happens 23:18

32:13 38:6 197:22

210:9

happily 5:2

happy 211:21

hard 9:14 112:7

126:20

harder 83:20 237:4

237:5

hardware 106:9

Harowitz 24:3 42:5

42:5

hate 28:7

Hayden 3:5 7:18

246:16 247:19,20

head 197:14

health 51:15

hear 7:21 9:21

28:20 58:18 128:6

128:7 136:3

171:11 203:2

211:21 239:19

256:15

heard 74:16 153:11

202:8 252:17

hearing 82:8 214:10

heat 99:7,7 214:22

215:16 216:18

held 227:16 234:10

Hello 128:7

help 9:16 10:19

24:3 106:13

135:19 152:3

189:14 229:15

249:9

helpful 28:13 31:8

39:13 50:18

100:18 214:15

225:10 230:8

241:6

hey 84:5 156:6

Hi 5:15 15:15

247:20

high 30:17 31:2,7

32:16 33:1 38:20

38:21 48:20 53:11

53:14,15,19 54:9

54:18 65:17 66:9

69:16 70:2 90:6

91:1,6,9,14,15,19

92:10,18 93:15

97:21 98:2 101:12

114:4 132:4

136:12 148:21

163:14 166:3

171:7 199:12

200:11 201:11

220:21 221:1

223:21,22 225:9

225:10 230:3

237:20 238:1,3,7

239:1

high- 198:17

higher 46:10 48:7

49:10 70:13 72:7

72:19 74:7 84:3

107:12 112:13

117:13 120:21

121:2 122:9,10

123:12 131:22

132:10,16 140:10

151:17 152:16

154:1 161:7,14

175:3 185:15,17

185:19 198:11

207:14,18 209:7

211:12 212:12,16

213:8,8 215:6

216:16 219:3,5

235:7 247:13

highest 26:17,18

160:14 163:21

166:5 218:20

222:22

highlight 12:11

130:10

highlighted 207:10

highly 56:9

historic 184:10

historical 205:20

206:14,20 216:6

historically 206:17

history 13:17

237:17 238:5

hit 54:10 60:5 74:16

100:3

hits 17:17

Ho 3:15 104:3

hold 112:8 125:12

149:6 210:21

holding 224:9,18
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38:6 106:9 113:1

113:9 115:2 117:6

130:15 132:10

136:10 140:16

159:9 232:10,12

242:18 243:6

homeowners 40:16

honest 22:11

honesty 189:7

hopefully 7:22 23:9

48:3 88:19 128:6

256:12,15

hoping 14:20 98:22

99:11

Horowitz 2:5 6:16

6:16 12:5,6 24:2

24:15 25:13 26:7

36:9,9 46:20,20

47:21 48:2,2

55:13,13 59:22,22

67:5,6,11 83:19

83:19 92:3 98:20

100:20 103:10,10

104:7 107:5,20

108:2 117:22,22

130:13,13 132:22

136:1,6,16 141:3

141:9 151:21

152:7 160:12

162:11 173:3

174:9 194:9

196:18 197:5,14

216:8 228:7,7

229:14 230:17

231:2,20 250:9

Hosbach 3:20

Hosback 104:4

hostile 33:10

hour 174:18 238:10

hours 35:4,5,8,9

36:11,13 43:21

46:7,8,12 92:11

96:14 101:7

119:14,21 120:18

120:19,21 121:2,8

121:8,13,14,16

122:1,6,13 123:3

123:7,12,16

126:10,12 127:22

128:19 130:17,19

131:2,3,8,14

133:13,15,17,18

133:19 134:1,8,9

137:1,1,4 138:18

138:20 144:3,4

146:5 151:18

165:17,18,19

166:10,12,13,18

166:20,22 167:4,5

167:6,6,9 168:4,9

172:21,22 178:5

178:11 179:13

194:3,15 236:17

238:4,9 240:15

house 33:4,4 98:1

125:20 138:20

172:2 173:12

238:2 239:3

household 136:22

140:10

households 125:2

146:10 166:8

housekeeping 5:20

Howley 2:9 3:6,22

6:13,13 19:19,20

26:11,12,12 35:18

35:19 39:21,22

42:21 46:3 48:9,9

49:16,17,18 52:20

54:21 59:8 67:21

68:14 71:10,11,12

77:5,5 84:17

86:15 100:5,5

111:17 121:21,22

121:22 122:8,13

122:16 139:5,6

176:19 182:13

210:11,11,15

224:3,3,9,13

225:3 226:16,17

236:3,3 237:4

254:17,22

huge 27:5 110:1

139:2 143:3

huh 29:8

hundred 133:6

186:10,12

Husain 2:6 7:13,13

15:15,15 17:17

20:4,7 23:5,21

24:12,16,22 26:2

26:10 28:11,16

29:2,15 38:12

41:19 42:12 43:17

50:10,22 53:9

56:6 58:17 59:4

62:15 63:9,15,19

64:2 152:20 159:4

159:17 161:10

hypothesis 160:15

hypothetically 17:4

I

i.e 108:13

idea 24:16 100:7

137:8 180:14

identical 206:20

identification 102:6

identified 16:1,15

29:15 51:9 64:9

64:14,15 65:10

66:16 68:21 70:6

87:5 88:16 106:5

185:20

identifies 248:6

256:7

identify 20:10 51:7

158:16 248:3

250:4

identifying 69:1

76:13 90:10 93:15

IESNA 18:22

Ignoring 197:6

illuminated 45:13

illuminates 195:10

illuminating 191:10

192:3

illumination 12:17

20:17 21:17 23:8

23:12 26:15 28:6

28:8,10,12

illustrate 87:20

144:10 197:21

illustrates 164:13

imaginable 214:6

imagine 252:12

immediate 6:1

Immediately 8:3

impact 8:18 15:9

52:1,12 87:22

119:17 121:10

123:21 124:2,4

134:11,19 138:21

144:6,11 150:14

150:20 153:15

168:6,10 169:3

172:19 176:2

183:11 202:4,10

220:1 227:17

233:4 234:11

241:17 242:4

246:17 247:22

248:10 251:3,13

252:13,22 253:4

254:1,14,19 255:8

255:11,15,22

256:1,6

impacted 250:2

252:7

impacts 8:17 15:7

51:13,15 93:19

203:7 242:5 248:3

248:17,19,20

249:9,13 250:4

253:6 255:13

256:2

implement 17:22

implications 135:20

implied 99:15

important 37:22

61:22 120:6 141:4

192:1,2

imposing 84:4

impossible 78:12

79:6

improperly 77:11

improve 10:19 44:5

51:7 56:13 57:1

59:10 63:2 215:2

229:6

improved 19:14

57:5,16 91:10,11

91:17,18 94:20

improvement 174:5

improvements

29:21 59:14 174:4

214:3

improves 91:21

improving 56:8,12

57:7,8,18 129:19

in-base 165:3

in-based 164:22

inappropriate

125:15

incandescent 14:3,4

16:2,7,10 17:19

18:1,2 21:4 30:18

31:2 33:3 39:7

54:1 122:3 127:5

223:5,15 236:7

237:7 239:2

241:15

incandescents 16:20

17:2,6 30:14

53:22 67:12,16

122:7 123:4,5

126:11 129:6,20

130:1 131:1

132:12 143:1,7

214:7 236:12,19

236:20

incident 56:19

include 17:8,19 18:5

18:17 43:20 56:9

57:2 122:7 130:4

147:14 170:4

181:16 196:7

255:4

included 16:9 23:6

24:20 25:1,4

62:16,18 73:16

133:17,19 147:22

151:9 158:17

196:3

includes 163:18

196:14 201:22

including 39:2

40:21 62:10 95:10

95:22 106:7,9

113:11 124:19

150:1 222:1

248:20

inclusion 120:9

incomes 255:14

inconsistence

231:12

incorporate 144:6

incorporated

103:21 147:21

175:14

incorrect 118:12

increase 69:3 71:18

145:13 242:11,13

242:14 243:3

252:18 254:5

increased 15:8 38:4

123:18,19 144:22

155:19 201:6

243:1

increases 228:22

234:5

increasing 38:21

61:11 135:13

227:19

increment 212:15

incremental 174:4

216:11,21 217:20

217:21

incrementally 241:9

increments 212:21

incursion 202:2

242:11

INDEPENDENCE

1:9

Independent 166:6

indicate 63:5

159:13 175:4

220:6,7

indicated 188:7

indicates 110:4
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individual 99:5

118:4 140:10

218:16

individually 115:17

individuals 103:15

103:16 104:10

105:5

industrial 27:20

133:21

industry 19:20 43:1

46:5,17 50:1,16

52:20 59:6 61:7

84:7 98:8 155:10

188:22 193:2

216:19 218:1

248:6,7,9,10

249:16,17

infeasibility 57:14

57:17

information 8:1

20:1 50:15 60:20

61:1 63:5 79:6

81:6 110:19,21

111:7 117:16

135:19 148:4

159:22 160:5,5

205:9 217:18

248:15 249:8

251:4

infrequently 123:5

inherent 193:12

initial 12:12 67:9

86:3 89:11 93:3

94:8

initiated 13:21

input 12:8 50:15

75:21 76:21 89:22

93:2 119:14 148:3

148:6 205:10

212:3 214:14

225:8 250:14,18

inputs 145:10

146:19 200:19

205:16

ins 81:16

insight 143:15

install 51:12 58:3

installation 121:1

147:17,22 148:13

149:16 151:8

175:5

installed 76:10 79:8

83:22 133:21,22

135:4,10,13 145:7

145:13 146:13,20

146:20 148:1

151:7 179:6

195:21 196:3,21

203:19 221:2,6

224:6 233:9

instance 252:7

253:4

instant 45:17 170:7

170:13

instantly 140:3

Institute 104:13

instructed 14:8

insulting 186:1

insure 89:11

insured 78:17

integrate 57:19

integrated 18:7,7

18:18,21 30:4

34:13 39:10 40:7

40:10 41:21 52:4

52:5,10,14,18

53:2,9 58:1 65:3,5

65:17,17 66:4,9

66:15 67:7 69:8

69:15,16,19 70:2

71:3 74:4 88:10

89:20 90:21,22,22

91:4 93:7 95:9

106:16,17 112:17

112:18 134:17

145:6 147:4

163:16 165:11

188:4 196:2

198:17 199:3

205:6 219:10

220:3,21 221:1,2

221:14 224:15

225:9 227:20

intend 17:11

intended 183:11

195:14 197:19,21

intent 26:16 27:16

46:22

intention 92:14

interchangeable

78:1,2

interested 130:7

135:15 148:11

229:3

interesting 140:8

interior 20:18

interior/exterior

28:6

intermediate 18:1

internal 98:15

internet 106:7

111:2 112:21

117:8,9,16 252:5

253:15

interpretation

28:10

interpreting 28:21

29:1

interview 248:12

254:20

interviewed 248:15

interviews 135:2

218:16 248:13,15

248:18

intro 189:14

introduce 103:13,17

104:10,18 231:14

introduced 58:15

206:7

introductions 6:1

103:11

inverted 188:9

Investor 6:20

invite 10:14

invites 167:8 169:13

175:7 202:5 242:6

IOU's 28:3 32:4

58:9 61:21 87:1

96:4 110:14

149:18 194:18

210:19

irrational 190:16

191:2

issue 11:1,1,6 17:4

19:17 34:8 39:22

40:1 41:17 45:5

48:16 54:10 60:21

63:9 66:22 70:18

77:1 79:12 84:15

84:20 85:13 95:8

95:11,15,17,21

106:20 121:18

122:20 124:22

128:11 129:16

135:17,19 149:3

149:12 188:12,16

192:5 212:3 217:4

issues 8:6 9:1 19:15

29:3 37:5 44:17

77:20 95:7 110:11

131:22 132:9

200:9 248:7 249:6

251:3

It'll 244:10

item 115:11 134:9

148:12 165:8

202:5 209:16

218:20,21,21

items 5:21 121:15

135:16 188:11

iterative 156:21

J

Janetz-Sell 104:5

janitor 151:13

Jantz-Sell 4:6

January 1:6 5:6

13:22 14:1 120:14

120:16

Jennifer 3:7 104:19

jeopardy 86:9

Jim 3:18 104:1

job 84:7

jobs 189:20 255:13

Joe 2:9 3:6 6:13

19:18,20 26:11,12

35:17,18 39:21

41:10 46:1 48:9

49:16,17 54:20

59:7,19 71:10,12

73:20 74:16 77:4

77:5 81:19 84:16

86:14 98:12 100:4

100:5 111:16

121:21,22 139:4,6

176:18 177:15,18

210:11 224:2,3

225:1,14 226:17

236:3 238:17

254:16

Joe's 85:17 100:21

John 2:8 17:7 31:6

32:17 35:7 49:4

123:6

Johnny 104:2

join 10:7

joining 10:5 105:5

128:4

Jordan 3:10

Joseph 3:22

jump 92:12 140:3

Jumping 249:12

June 18:20 156:20

201:4,6

justified 130:22

justify 101:15

K

Kantner 2:17 7:7,7

87:18,18 119:5,6

122:5,10,15 124:2

126:7 131:11

133:12 136:5,14

137:15 140:12

141:8 142:13

143:19 144:17

149:6,10,14 150:3

150:21 152:18

159:2 161:5

162:17 163:9,13

165:16 167:15

170:2,10 174:14

175:12 178:14

179:4,22 180:14

180:17 181:1,19

182:3 183:4

186:15 188:2

192:7 193:14,17

194:7 195:6,11

197:2,6,19 198:7

198:16 199:14

200:18 202:9

222:6,6,21 223:7

230:11,11,22

237:1

Karen 104:2

keep 9:10 34:11

51:5 60:22 62:13

77:10 78:1 83:16

120:6 163:12

198:13

Keith 2:14 6:4

33:13,14 34:7,17

36:7 41:9,11

47:10,11 61:3,4

78:5,6 96:9,10

97:4 109:15,16

123:13,14 179:8,9

188:20,21 204:10

228:12,13

Keith's 48:3 61:21

79:18

Ken 2:21 128:4,5

130:12 171:10,11

192:21 246:19,20

Ken's 172:7

Kevin 4:3,7 104:2

key 77:21,22 84:19

200:19 219:10

227:8 248:6 249:6

251:3

keyed 77:14

kick 32:9

kicks 218:7

kids 33:1

Kienle 2:16 7:14,14

64:4,5 67:10,13

68:5,17,21 75:12

78:15 87:11 89:5
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115:14 116:10,19

117:4 118:21

119:2

kilowatt 136:22

137:4

kind 25:19 31:7

34:7,19 35:10

43:14 60:22 72:20

73:20 74:19 79:6

80:18 86:10 97:4

98:4 108:18

114:10 115:15,16

117:17 124:18

126:2 149:2 158:6

165:12 171:22

185:21 186:1

208:12 209:5

215:19 224:22

225:8,22 231:14

231:15 232:19

238:16,17 240:1

247:5 251:7

252:13,20 253:19

254:9

kinds 244:22

kitchen 128:16

138:12 239:5

kitchens 238:9

knew 22:12 239:4

knobs 81:20

knock 33:2

know 15:6 17:18

22:12 23:12 25:10

25:14 28:21 33:21

37:19 40:21 50:6

60:7,12 61:14

68:9,19 74:8 75:2

79:5,16 80:16,19

81:17,19 82:15

87:5 88:18 94:14

97:9,13,14,15,16

97:18,20 98:5,11

101:14 103:12

107:5 109:9,12,17

110:16 111:1

113:11,16 114:4

114:11 115:11

116:21 122:22

125:21,22 128:19

136:17 137:21

138:7,15 140:2

141:14 152:10

157:12 158:5,9,13

160:18 162:13

164:12 169:17

172:10 173:5

174:9 176:22

178:9 179:18

181:9 185:21

187:9,13,15

190:15 193:18

202:14 209:3,5,11

209:21 210:19

211:15,17 213:20

218:3,16,18,19

219:1 226:3 232:8

232:19 239:21

243:16 247:2

251:6 252:5,11

253:9 254:7,9

knowledgeable

81:13

knows 129:2 169:22

170:13

Krowka 2:19

103:20,20

L

l/2 160:18 173:18

190:21 191:12

L70 168:3

lab 5:20 7:8,10,12

33:9 87:19 119:7

203:5 222:7

230:12

labor 151:9,19

labs 253:13,13

lack 167:1 208:4

laid 74:1

lamp 15:19,20 16:4

16:15 18:10,11,21

19:2 20:12 21:1

21:17,21 22:2

23:8,9 24:17,20

24:22 26:15 27:12

29:15,18,19,22

30:1 31:12 33:2,6

34:18 35:4,5,19

35:21,22 38:19

40:8,10 42:17,18

42:21 43:5 51:7

52:5,7,11,18,19

52:22 53:2,5,5

54:12 55:4 56:13

56:15 61:7 63:8

64:13 65:12 66:4

66:6,8,13,16

68:10,16,22 69:5

69:5,21 70:5,8,9

70:16 71:1,2,13

71:15,18,20 72:22

72:22,22 73:3

75:4,14 76:4,7

77:2,7,9,9,13,13

77:16,18,19 78:8

78:9,10 79:10

82:7,12 83:21

84:2,13 85:3 86:2

87:9,10,14,20

88:14 90:14,16

91:12,18,20,22

93:18 95:2 96:14

98:12 105:19,22

106:4 108:14,17

110:8 114:12

116:5,9,21 119:14

128:15 133:16

145:5 146:17,21

147:1,2,11,20

148:18 156:3,14

161:22 162:4,5

163:15 164:4,6

167:17,19,19,21

168:22 171:3,3,6

175:18,22 176:5,9

176:14 177:10,19

178:15,16,21

179:18,22 180:8,9

180:11 181:3

182:4 192:11

193:12,19,19

195:1,3 198:21

201:18 202:2,3

204:4 207:13,17

208:4,21 210:5

214:13 215:11

219:11 221:10,11

221:13 223:16

238:18 239:9,18

240:4,10,12,12

241:20 242:10

243:13,14,15

244:20

lamp's 168:3

lamps 1:4 5:6,18

12:16,21 13:20

14:3,11 15:22

16:3,5,6,6,7,10,11

16:12,13,14 17:9

17:19 18:1,2,3,6,8

18:17 19:6,9,11

19:16 20:8,10

21:4,5,14 22:18

23:3,12 26:17,19

29:17 31:16 33:11

39:2,6,7,10,12

40:1,5,7 41:2,22

42:1 43:6 48:11

50:15 52:10 53:12

53:13,14,16 58:1

62:21 63:1,4

64:11 65:11,16,22

66:18 68:7 69:2,6

69:12,13,17,18

70:1,20 72:1,11

73:16,18 74:13

75:6,19 76:2,9

77:11 78:1 79:16

80:8,20 82:19

87:6 88:2 89:7,11

90:2,15,18 93:9

99:22 100:2

105:13,20 106:14

106:16,16,17,18

107:18,19 109:7

109:11 111:6

113:19,22 115:18

119:19 120:9

127:10,12,16

128:14 129:1

132:4 134:17,17

135:9 138:13,14

138:20 139:18

146:18 150:7

161:8 162:17,21

163:16,18 164:3

164:11,12 165:8

174:21 176:8

177:1,3,5 180:15

181:5,8 182:10,12

182:16,17 183:1

183:16 184:15

188:14 190:18,20

191:1,3,4,13,15

193:16 204:8,22

205:1,1 206:7

207:22 208:5

211:2,5,8,12

212:16,17 219:17

221:2,5,21 222:8

223:13,20 226:17

234:13,18,22

235:1,13 239:12

239:13 240:9

242:1,15,18,19

243:4,17 244:22

244:22 245:11,12

247:4,13,15

landing 185:15

language 47:4

large 26:14 27:10

27:11 40:15 59:13

78:10 106:2,8

112:22 117:7

193:4 200:1

219:21 241:4

247:6,8

larger 133:7 144:2

165:7 228:11

230:5

largest 26:21 34:22

250:13,16

lastly 13:6 249:21

256:6

law 205:20

Lawrence 5:19 7:7

7:9,11 87:18

119:6 203:5 222:6

230:12

laws 177:2

layers 19:8

layout 41:12

LBNL 37:5 87:12

LCC 87:21 119:4

144:18 145:17

146:1,3,6,8,19

147:7,21 148:3,6

149:18 150:20

161:20 162:6,13

163:1,8 167:15

175:16,17,20,21

176:1,7 183:5,10

183:17,22 184:13

188:16 193:9

194:6 195:7,16

196:1,1,7,12,14

197:1,1,2,7

198:17,17,20,22

199:5 201:13,15

201:20 204:5

228:4 234:1 255:5

255:5

LCC's 150:22

leading 189:11

219:21 220:15

learning 147:1,5,10

148:17,20,22

149:5 176:2

186:22 187:11

205:13,15,19

206:6,12,14,19,21

207:3,4,6,16

208:2,2,10,13,16
Energy Conservation Standards Preliminary Analysis for General Service Lamps

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208:18 209:11,15

209:18,22 210:1,4

210:21,22 211:18

227:10,12,18

242:3

leave 36:12 46:11

92:11 229:19

236:9 239:2,5

240:12,15,16,18

leaving 46:15

LED 16:12 18:17,19

18:21 19:2 34:21

34:21 39:5 43:10

54:9 57:10 59:20

60:2 63:7 69:9,22

74:2 75:19 88:15

88:16 91:12,17,20

91:22 99:5,19

109:11,22 121:3,7

122:2,4 128:12

131:6 133:10

148:22 152:2,8,14

155:1,5 156:12

160:17 163:15

168:12 170:6

173:8,10,14 174:4

174:18 175:2

178:1,8,9,12,21

193:21 194:4,6

205:6 206:7,10,21

207:3 208:4

211:12 212:11

220:8,9,16 224:15

225:19 226:11

227:20 228:9

234:13 237:7

239:4 241:9 242:3

251:6

LEDs 19:4,6 21:16

27:4 30:17 36:21

38:7 56:15 57:1,4

57:8,19,22 59:15

60:4 62:8 72:4,6

72:10 99:1,16,17

100:3,7,18 101:2

122:7 126:12,15

126:17 129:2,6,8

129:11,18,21,22

131:4 132:18

133:3,5 135:5,6,9

135:18 142:21

147:13,14 151:22

154:22 155:3,7,17

157:2 158:6

161:13 163:18

165:4 168:6,17,20

169:4,6 171:16,16

174:3 176:14

188:10 190:2

199:18,22 200:9

206:7,9,13,15

207:12 212:12,13

215:13 216:18

219:14,15,21,22

220:3 226:1

227:10,12 234:15

236:6,17 237:3,19

250:13,17

left 6:2 21:20 59:12

92:5 149:2 191:8

193:16 195:13

197:21 202:13

203:2 229:17

239:16 240:13

left-hand 29:8

164:13

legislation 27:16

47:8

legitimate 97:14

length 36:6 168:5,7

168:8 175:1

lengthens 206:3

lessening 15:10

let's 5:2 7:5 13:16

22:6 45:7 51:19

64:1 77:17 96:13

96:13 100:12

101:22 108:10

116:5 118:5 156:6

163:11 180:7

187:22 196:20

246:12 247:3

level 53:13 64:18

84:2,21 85:9,12

91:15 95:4 98:16

119:12 121:9

125:3 150:17

152:14 159:10

160:14 161:3

183:9,20 188:6

198:5,6 199:6

201:6,17 205:12

211:3 215:3 220:5

220:12

levels 49:20 64:16

73:7,8 95:11

139:9 190:19

196:11 204:15

213:10 219:6

234:11 255:19

Liana 3:21 104:2

life 33:16,19 34:10

34:20 37:16 43:22

46:6,7,14 178:8

178:12 186:13

193:10,22 194:1,3

194:4 199:19

life-cycle 8:16 119:8

144:13,18,20

145:6 179:7

180:10 182:5

183:6 195:12

196:3,5,11 199:5

247:2,3

life-time 174:15

lifecycle 87:20

175:14

lifetime 15:7 32:20

32:22 37:6,7,14

37:15,21 43:22

44:19 46:12 50:11

65:21 92:11,19

96:14,17 97:16

101:7 114:1

126:20 144:21

145:8 151:10,16

167:16,18,19

168:3,12,14 169:4

169:12,14,21

170:6,16 171:3,13

171:22 172:9

174:8 175:5,18

176:5,9 178:5,6

178:16,19 181:6

182:2 193:19

194:13 196:4,6

200:21 228:3

241:20,22 247:12

lifetimes 168:1

171:8 174:19

175:4,13 180:16

180:18,20 193:9

199:17 247:15

lift 17:10

light 12:15 16:12,13

18:18 19:7 20:13

20:14,14 27:19

35:8 43:7,8 57:4

67:8 69:4,11

71:19 73:7,8

75:16 84:21 85:8

85:12 86:11 98:14

117:12 121:17

123:7 125:4

130:21 132:8

133:4 136:11

160:22 171:1

172:15,16 173:16

173:19 190:2

200:6 214:5 215:5

216:10,15 230:3,5

239:2,5 251:17,22

252:6,7,9 253:7

253:19

lighted 181:16

lighter 69:17 70:9

215:1

lighting 6:5,11,12

6:13 16:1 20:19

20:22 21:18 22:10

22:19 26:12,20

27:17 28:4,5

31:14 39:16 53:14

54:5 60:7 61:6

63:8 73:20 79:4

85:10,18 96:7

97:4 119:17

123:20 125:16

127:18,20 129:15

133:14 134:11,19

135:21 137:3

138:1,9,12 141:20

142:14 148:16

158:2 164:19

165:1 177:15

185:11 196:14

222:15 234:5,10

235:5 238:2,2,3

238:16 241:4

248:4

lights 60:2 78:11

125:21 138:8

242:20

limit 9:12,17 24:10

212:20

limitation 131:22

limitations 132:13

200:3

limited 14:4 19:12

135:4 221:12

226:20,22

limits 214:11

Linda 104:3

line 23:19 91:5

103:12,21 131:7

179:10 217:11,12

217:12 226:20

line-up 138:16

linear 43:4 177:20

182:12,20

linearly 37:17

lines 213:13,13

217:9 220:6,7

240:8

lingered 212:6

Lingold 104:4

link 11:14

Lis 4:4

list 2:1 3:1 21:22

listed 16:10 21:7

42:15 59:10,21

62:15 65:18 66:5

66:12,14 162:22

163:19 168:16

204:8

listened 238:13

listing 71:15

lists 87:4

lit 85:20,22 86:5,12

86:17,19

little 18:16 19:5

24:19 47:12 54:6

54:8,9,18 59:12

75:7 78:3 81:11

87:3,12 97:6

101:6 109:5

110:14,20 122:11

138:16 151:1

158:22 185:21

189:5 190:13

231:11

live 35:14 168:17

181:5,8

lived 147:20 175:18

178:16 182:5

lives 31:13 169:19

181:11

living 171:19

LMC 222:1

load 235:2

local 80:7 146:22

158:21

locally 159:9

located 11:13

140:14

location 166:7,9

location- 165:19

166:11

location-specific

148:5

locations 120:2

142:2 175:5

logical 43:9 55:8

127:2

logically 55:1

long 31:18 33:12,22

33:22 34:4 36:10

60:20 129:7 140:2

181:9 210:7 212:7

226:10 236:11
Energy Conservation Standards Preliminary Analysis for General Service Lamps

January 20, 2015

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237:9

long-life 237:6

long-term 48:22

longer 63:10 121:2

123:2 126:20

144:3 147:20

151:15 161:2

168:9 181:5,6,11

182:5 236:6,10

238:5 247:14

longest 193:22

look 13:7 24:18 25:5

26:16 27:7 28:13

45:15 47:3 48:4

50:11 55:8,10

59:2 60:3 61:13

81:1 83:20 92:6

99:15 109:12

113:18 132:10

136:21 137:15

138:4,16 140:13

158:20,21 159:9

159:16 195:6

198:1 213:15

216:1 225:15

226:8 230:1

239:22 242:18

250:22 251:14

254:4,10

looked 29:18 96:21

111:17 115:8,15

138:1 160:12,17

177:4 187:17

190:12 222:16

looking 72:14 80:2

80:4,5,20,21 81:3

88:22 99:1,13

111:20 156:15

158:19 161:1,2

182:2 187:19

198:13 216:6

222:10 231:10

244:15 251:16

254:3

looks 179:5 216:6

216:13 230:3

249:22 255:11,18

255:22

losses 57:21

lost 95:19 112:9

lot 9:9 12:9 28:19

28:19 29:7 31:11

31:17 41:7 45:5

50:13 55:21 73:5

83:14 102:1 103:3

110:18 125:8

129:3 131:2,3

132:3,3 136:9

143:14,15 150:15

155:19 156:13,22

157:3 158:4 162:7

174:5 177:1

187:14 189:9

193:1,6 199:8

203:9 214:19

215:3 236:10

237:9 239:12

lots 31:15,15 130:14

256:12,13

Louis 7:9

low 65:17 66:4 67:7

69:15,19 88:11

90:6,22 91:5,8,13

93:14 101:12

112:17 114:5

115:19 128:1

139:8,13 152:2

176:22 177:16

201:11 208:11

210:12 219:10

220:3 224:15

225:4

low- 163:16

low-lumen 145:6

147:4 150:5

165:11 166:6

188:4 196:2 199:3

199:20

Lowe's 113:9 115:2

lower 20:21 36:21

48:15 53:13,17,20

55:17 67:17,22

68:1 70:14,15

73:3,4 74:5 75:9

84:3 99:3,10

107:12,15 130:20

133:4,4 136:17

139:10 140:9

154:3,17 160:19

161:15 164:13

172:3 182:9 189:3

208:22 209:1

212:13,20 213:6,6

213:8 218:21,21

219:4 225:5

lower-lumen-outp...

88:2

lowest 178:6,16

196:11 199:4

212:16

LPW 97:16

Lucy 2:4 5:14 10:11

13:15 26:3,4

130:8 160:3 174:6

187:9 189:13

245:20 256:10

lumen 33:16,17

34:1,20 38:21

41:22 42:1,3,9

43:20,21 44:15,17

45:18 53:11,12,13

53:14,15,17,19

54:2,6,22 55:1,2

65:4,5,6,17,17,20

66:5,7,9,10 67:7

67:22 68:4,12,14

68:16,19 69:15,16

69:20 70:2,13,15

70:15 71:1 74:5,7

80:5,6,22 81:3

82:3 86:6 88:11

89:12 90:3,7,13

90:19,22 91:1,6,6

91:8,9,13,14,15

93:3,10,15,20

94:7,8 95:5

112:17 131:22

132:1,5,11,16

150:7 163:15,17

163:19,20,21

164:2,4,6,12,15

165:3,5,10,13,21

166:3,5,22 197:6

198:18 199:12

200:14 212:11,12

212:13,16,16

213:8,10 214:1,2

215:11,14,15,19

215:20 216:1,3,16

216:17,18 218:10

219:5 220:3,21

221:1 222:22

223:6 225:10

229:18 230:3

lumen-range-spec...

166:1

lumens 14:7 20:20

20:21 26:20 32:9

38:14,20 41:3

42:1 45:15 53:17

53:18,21 54:2,15

55:3,3,4,5,6 65:4

65:6,7 66:8,11

67:9,12,14 72:19

73:4 82:6 86:2

88:19 89:22 93:2

99:18,19 100:1

101:8 129:20

130:1 131:20

133:3 163:22,22

173:16,17 199:13

200:7 213:6

215:10 216:1

221:21 222:8

223:3 231:7

lumens-based 95:14

luminaire 132:6,7

luminairers 227:20

luminairres 205:6

luminants 38:15

luminous 76:20

lunch 8:14,15,21

202:13,15,16,18

202:18,21

M

main 30:15 106:5

129:10 159:20

mainstream 59:7

maintain 69:10

maintained 21:9

71:9

maintaining 29:21

37:16 44:15

maintenance 33:16

33:17 34:1,20

43:21,21 44:16

77:15 80:13

151:11

major 11:6 47:18

78:13 230:14

majority 44:22

50:17 76:14

110:21

makers 250:16

making 20:15 36:17

39:19 79:14 97:17

97:19 227:4

238:18

management 57:7

253:16

mandated 13:22

mandatory 244:1

manner 169:4

manual 137:11,14

137:17

manufacture 51:12

manufactured

98:17

manufacturer 8:18

58:3 75:21 96:16

96:17 97:9 105:12

135:1 156:2

246:17 247:22

248:13,17,18,19

249:9,13,18

250:10 251:3,13

252:13,15,22

253:22 254:14,15

255:8

manufacturer's

250:21

manufacturers

32:21 74:12 97:21

104:21 153:12

189:20 248:4,14

249:6 250:1,2,5,6

250:11 251:14,17

252:21 253:7

255:20

manufacturing 74:9

97:21 98:3 147:6

218:16 248:21

249:14 251:9

254:19,20 255:7

marginalized

148:21

market 8:11 36:3

39:9,11 45:1,3

48:4,5,21 49:1

50:11,17 51:4,4,6

53:12 55:17 58:15

60:6 61:17,18

63:16 65:9,13

66:19 75:22 76:6

88:1 92:1 97:11

99:22 101:14

110:1 113:16

115:7 128:22

129:22 132:13,19

133:1,15 142:14

145:19 156:4

162:1 164:14,18

164:21 165:9,14

181:3 183:14,21

184:1,10,17 188:6

189:8 191:3,17,20

192:2 193:4,7

196:14 197:8,9

200:13 201:14

207:17 208:5

211:4 212:19

216:12 217:22

219:1,13,19

220:15,18 222:11

222:18,21 223:4

224:12,22 229:11

229:11,18,22

230:4,15,20

234:19 247:6,6,7
Energy Conservation Standards Preliminary Analysis for General Service Lamps

January 20, 2015

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marketing 50:14

marketplace 47:16

112:15 151:8

180:21

mass 106:10

mass- 230:14

match 55:17 181:17

197:16

matched 90:5 93:13

matches 68:15,15

192:7

matching 227:13

material 147:15

151:12 214:1

materials 62:9

202:6 214:3

mathematical

218:22

matter 8:6 38:10

125:4 154:15

162:3 191:18

matters 153:13

mature 100:10

148:20 208:12

210:6 214:6

216:12 217:22,22

Maureen 2:16 7:14

64:3,5 87:16

103:6 105:8 119:5

159:5,18

max- 199:5

max-tech 95:10

196:10

maximize 61:10,16

maximum 64:18

72:9 91:14 95:4

96:13,15,16 167:5

220:5

McDonald 7:16,16

McGaraghan 2:11

6:18,18 28:2,2,15

28:18 29:5 32:3,3

58:8,8 59:3 61:20

61:20 63:7,12

86:22,22 88:6

96:3,3 110:13,13

111:8 149:17,17

150:10 151:2

161:18,18 163:6,6

194:17,17 197:16

198:1,12 210:18

210:18 211:7

213:7 217:6,6

McMahan 104:1

McMahon 3:18

mean 22:20 28:20

30:20 31:7 38:6

45:13,20 53:1

101:9 114:22

122:10 125:6

131:3 180:13

182:3 187:10

193:20 204:11

211:9,11 214:1,2

225:15 238:13

242:18 243:15

245:6 252:11,12

meaning 177:3

179:11

meaningless 178:4

means 53:2 108:17

135:3,9 179:15

184:1 205:21

208:5

meant 27:5 67:7

measure 34:3

244:11

measured 76:19

measurements

94:15

measuring 33:19

median 168:21

169:7

medium 14:11 18:8

24:6 25:11,21

26:19 27:2,3,4,6

41:21 43:18,19

44:7,13,22 54:13

66:2 73:17

meet 41:15 45:1,4

45:22 72:7 85:6

86:1 88:14 89:1

92:11 133:9,9,16

149:22

meeting 1:2 5:4 9:8

10:9,13 34:18

85:10 105:5

107:22 109:6

256:18 257:1

meetings 9:4,15

meets 65:13 149:20

209:1,7

members 59:5

mention 11:17

161:6

mentioned 10:14

14:2,15 43:18

67:14 94:6 110:22

111:3 115:8 118:2

158:10 159:5

201:19 207:5

219:13 227:9

237:10 241:1

merchants 106:10

mercury 109:20

176:14 177:3,5,9

182:16 183:1

met 66:2 88:15,16

121:20 125:1

129:18

meta-analysis

134:18 241:3

metered 137:3

166:14

metering 120:1,21

166:16 222:2

method 76:1

methodology 51:1

64:8 66:15 93:6

95:12 106:21

145:3 160:1 175:8

192:19 203:18

methods 47:4,7

metrics 8:10 43:18

44:2,4,7 45:2,6

49:21 50:2,4,8,9

50:14,18

Meyer 104:3

MIA 247:22 248:3

248:5 249:2,5

255:9,17

mic's 152:5

Michael 92:5 104:3

116:1

microphone 103:16

microphones 6:2

mid-morning 8:10

middle 232:19

Mike 2:11 6:18 28:1

28:2 32:2,3 58:7,8

61:19,20 86:21,22

96:2,3 110:12,13

149:16,17 161:17

161:18 163:5,6

185:13 194:16,17

196:18 210:17,18

213:7 217:5,6

Mike's 162:12

mind 120:6 174:7

minimal 168:10

minimizing 57:8,21

minimum 14:7 46:6

46:8,14,15 84:21

89:9 95:3 152:17

167:5 178:6

185:18 214:14

217:19

minor 210:6 239:7

239:17

minus 137:1

minute 102:3 126:1

minutes 202:19

mishmash 190:4

misreading 58:12

missed 193:16

245:10

missing 194:5

mistake 55:20 170:8

240:8

mistaken 128:3

mistakes 170:11

mistaking 29:3

misunderstood

151:3

mix 32:6

Mizolek 4:8 104:1

mobile 232:10

mode 9:12 14:12

76:2 235:3

model 37:7 65:13

76:8,11,13,16,18

76:21 96:20 118:4

164:22 167:22

171:21 184:9,11

203:6 204:6,19,20

205:17,18,19

208:15 214:16

222:8,16 223:2

226:5 233:8 248:9

248:10

modeled 135:12

212:14

modeling 174:15

models 118:10

161:3 222:11

230:2

moderate 242:4

modest 242:6

modified 13:2 127:5

module 204:17

205:4,8,10,14

moment 199:8

monetary 256:5

Monetization 256:3

money 41:11 181:3

186:13 233:14

247:4,5,9,10,17

monitored 61:6

143:12,13

Monte 145:4

month 156:15,15

monthly 157:10,17

157:18

months 99:13

160:18 230:21

mood 139:12

morning 5:3,10

7:21 8:2 12:5 64:4

102:1 203:9

motivation 173:13

move 8:8 13:14

15:13 32:18 43:16

48:13 63:22 64:1

72:5 85:15 118:22

143:17 144:14

151:18 163:11

172:17 182:6

187:22 195:9

198:15 226:14

moved 172:1,13,21

movements 213:16

moves 171:19

moving 29:14 50:21

60:18 75:9 86:20

89:4 130:1 158:6

173:12 237:2,7

245:16 246:14

255:1

MR16 39:5,7 40:1

multi-pack 107:10

112:11 113:15

multi-packs 108:4

113:11

multi-photon 56:17

multiple 22:21 87:4

88:14 116:4

143:13

multiply 138:19

multiplying 141:11

Mustaba 4:9

mute 9:16

N

N 5:1

name 5:8 9:6 15:15

64:5 103:15 116:3

119:5 247:20

names 116:3 152:11

nanophosphor

58:11

narrow 57:3 137:22

narrowed 27:10

national 5:19 7:8,10

7:12 8:17 15:11

87:19,22 104:20

119:6 121:10,12

134:7 150:20

159:10 202:4,10

203:5,7 222:7

230:12 233:4,5,11
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Natural 6:17,22

190:11

nature 85:11 155:7

Navigant 5:19 7:13

7:14,16,18 15:16

64:5 152:21 159:4

161:10 189:17

246:16 247:21

Navvab 4:9

NDA 189:17

necessarily 33:11

50:4 97:12 100:22

125:18,22 167:18

251:9,18,20

necessary 65:1

89:11 98:18

NEEA 60:10 80:1

need 15:10 30:16

36:22 42:22 46:4

47:6 49:2 53:3

61:12 74:7 83:20

99:6,7 101:2,13

101:16 103:15

109:17 118:19

131:20 142:6

177:12 187:9

209:5 214:22

needed 52:6 55:15

64:20 200:10

228:11

needless 256:11

needs 31:21 49:3

73:7 133:10 154:5

164:11 200:3,11

200:14

negative 168:6

198:3,10 250:4

252:15

negligible 147:14,17

234:22 244:8

NEMA 38:2 54:17

155:9 209:13

nervous 81:12 97:6

NES 247:8,8

net 168:11 183:19

185:1 196:8 233:5

233:19 255:13

never 40:15 186:13

244:10

new 7:21 24:7,8

45:2 48:12,14

60:1 79:20 129:8

129:8,9 156:12

161:15 179:16

180:3 204:21

209:17 240:1

newer 59:15 173:9

179:20

Nexxus 63:8

Ngo 3:13

NIA 233:4,7,16

234:2,3 242:7

nice 5:10 13:10

niche 221:11 226:18

night 143:4

NMV 247:8

Noah 2:5 6:16 12:4

12:5 24:1,3 36:8,9

42:4,5 46:19,20

47:12 48:1,2

55:12,13 59:21,22

60:15 61:4 62:12

67:4,6 83:18,19

92:2,3 98:4,19,20

100:19 103:9,10

104:6 107:4

117:21,22 130:12

130:13 132:21

135:22 136:1

141:2 151:20,21

152:5,8 160:11

162:10 173:2,3

194:8,9 196:17

216:7,8 228:6,7

229:13,15 250:8,9

Noah's 100:6

nodding 197:14

nominal 80:3,4,5

non 88:10 191:22

non-ANSI 24:7,13

25:15

non-dimmable

170:8,12

non-energy 50:9

non-general 23:18

non-incandescent

132:5

non-integrated 18:7

18:18 30:8 39:12

40:5 42:2 52:5,7

52:16,18,22 53:5

65:6 66:14,17

70:7,10 71:7

75:12,19,20 76:1

76:6,14 77:3

89:16 92:21 93:4

93:22 94:19 95:10

95:17 106:16,18

166:4 198:18,19

220:21 221:5,10

221:11 224:5

244:15,18 247:4

247:14

non-reflector 41:21

42:2

non-regulatory

256:7

noon 8:14

NOPR 8:19 18:20

60:18 61:2 140:17

245:5 246:18

248:2 249:2,12

255:3,10

normal 76:15

249:17

normalize 114:2

182:1 219:5

Northwest 6:14 7:1

131:12,14 137:4

140:21 142:8,15

151:5 166:14,14

181:14 253:13

note 19:3 37:11

38:12 42:12 46:5

50:10 54:21 71:13

72:18 77:6 100:6

144:4 148:4 165:5

166:3 169:8

174:22 188:8

255:15

noted 20:7 21:2

23:6 76:17

notes 15:20 16:4

Notice 14:21

noticed 155:2

161:16 231:5,6

noting 38:10 43:13

134:14 147:10

notion 191:10

NPV 241:21

NRDC 6:16 12:6

24:3 36:9 42:5

46:20 48:2 55:13

59:22 67:6 83:19

92:3 98:20 100:22

117:22 130:13

136:1 151:21

152:8 173:3 194:9

216:8 228:7

229:16 250:9

number 11:18,19

27:5,17 31:8,17

31:21 48:8 55:17

61:18 76:1 96:12

97:14 114:22

116:15 128:1,19

136:2,12,17

138:19 141:10,11

141:13 142:14

154:17 170:15,15

174:7 177:4,17

178:22 182:8,12

182:13 200:10,19

217:4 221:20

222:1 223:10,11

228:11 239:7

241:4 246:2,6,7

252:2

numbering 11:2

192:6

numbers 11:7 49:9

54:10 118:4

123:22 124:1

137:17 152:16,21

158:16 177:11

190:12,21 191:8

192:18 196:22

199:11

O

O 5:1

observation 112:9

154:20,21 211:7

observations 212:19

227:14

observed 106:2

112:14

obsolete 101:10

156:14 161:8

207:19 208:16,20

208:22 211:2

obsoleted 156:15

obstacle 34:22

obtained 105:2

obvious 42:7 155:22

199:17

obviously 59:15

238:11

occur 26:21 59:17

219:16

occurs 176:3 207:16

odd 239:10

odds 218:19

off-brand 152:11

offer 10:1 47:21

52:10 53:14

132:22 133:2

139:5 156:18

239:16

offered 118:6

offering 154:14

155:19 156:20

offers 131:6

office 7:4 11:20

offices 139:10

offset 38:4

oh 8:20 238:13

242:14 246:21

okay 5:2 15:4 17:16

20:5,6 23:15,22

25:7 27:13 29:12

29:14 30:8 35:17

37:9 38:9,11,12

39:1,21 41:9,18

42:11 43:16 46:1

46:19 47:9 48:17

49:16 50:20,22

59:3 61:3,19

63:12 64:1 68:20

68:21 71:11 75:12

78:14 86:20,21

88:6 89:3,5 92:21

94:18 95:7 98:19

100:12 101:20

102:11 103:1,7

105:8 108:2,10

111:22 118:11,21

118:22 119:1,2

124:7 130:11

131:10 133:11,11

143:17 144:16

149:9,11 151:2

157:22 160:9

165:15 167:14

170:4 174:11,13

175:11 182:6

183:2 187:7,22

189:12 192:13

194:8,16 198:12

198:16 199:15

200:17 202:8,15

202:18 210:10,17

212:6,8 217:3

219:7 223:8,14

224:1 229:4 231:2

232:22 233:2

240:21 244:5,9

245:15 246:9,12

246:13 247:18

254:22 255:1

256:22

old 33:4,7 129:9

156:14 171:19

230:5

older 59:11 129:11

161:3,13 189:10

OLED 16:13 19:6,9
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On-line 115:4

on-time 168:7,8

169:19 174:22

175:6

once 17:11 33:7

35:6 105:3 125:2

127:17 129:1

133:6 162:14

165:20 170:14

214:19,21 251:6

one's 130:19

ones 11:6 29:16

30:6,9 57:10

62:17,17 86:18

128:19 129:9

136:8 150:1

161:14,15 188:15

ongoing 57:18

online 111:1 115:9

117:2,6,11 153:3

159:10,11 161:15

164:8

onset 104:11

open 55:15

opening 8:5 12:1,3

operate 20:16 22:16

75:5,13 77:8

119:19 134:13

139:14

operated 22:20 76:2

139:16

operating 22:18

41:3 44:3 119:14

121:13,16 123:12

131:13 133:15

134:8 138:18,20

144:4 145:2,8,14

145:15 148:7

165:17 179:6

180:1 196:4,4

operation 15:7 52:7

76:2 101:13 122:2

122:4 151:11

235:13

opinions 256:16

opportunities 73:14

170:22

opportunity 8:4,21

12:3 78:3 148:8

245:14

opposed 55:17,18

94:13 135:21

236:11

opposite 61:11

optics 57:9 91:19

optimistic 31:11,18

169:18 224:19

optimized 59:18

option 51:10 56:14

56:19 57:5 58:2

62:4 63:3,6 73:12

74:2 90:16 92:16

128:15 184:20

186:4 199:2

207:13 219:12

221:10,11,13

options 51:7,9,16,17

56:7,8,9,11,16

57:1,2,7,10,12

58:5,5 59:9,20

62:14,16,18,19,21

63:14 64:15 72:19

74:3 78:3 87:14

90:19 150:15,17

184:16 198:21

204:4 207:13,17

207:21 208:4

order 11:5,15 69:10

75:15 90:3 93:10

144:10 146:4

157:19 164:11

168:22 184:22

185:7 229:6

ordinarily 240:13

organic 16:13 19:8

organization 104:8

original 17:8 26:16

79:17 85:1 159:7

originally 32:5

186:21

OSHA 73:8 84:21

85:10

Osram 6:6 94:3,11

outcome 13:12

outdoor 35:8

127:18,19 128:2

outlier 97:8 115:1

outliers 97:18

115:10,14

outline 44:13

outlining 62:10

Outlook's 201:9

output 12:15 20:19

41:22 42:2,3

45:18 65:4,5,7,20

66:7,11 68:12,14

68:19 69:4,11

70:13,15,16 71:1

75:16 86:3 90:3

90:13,19 93:3,20

94:7,8 98:14

132:16 133:4

136:11 160:22

166:22 190:3

197:18 214:5

215:19 216:15

223:21,22 230:3

outputs 42:10 93:10

193:3 205:11

outs 131:21

outset 8:6 12:4

13:13 103:18

outside 127:20

205:2,5 252:21

overall 12:17 20:17

21:17 23:8,11

28:6,8,10,12,12

36:3 38:5 59:8

119:19 128:22

252:13

overdrive 77:19

overly 31:11

overstate 42:7

overview 8:9 11:22

13:15

owing 219:22

221:11

Owned 6:20

oxide 201:1,3,5

oxides 147:12

148:18 207:8

228:14,16

P

P 5:1

p.m 202:21 257:1

PA 9:21

Pacific 142:7

pack 116:6,6,15,16

116:17,17 117:18

117:18 118:6,18

118:18,20

package 53:11 57:6

57:20 91:18

118:13 153:18

215:1 216:2,3

packages 95:5

213:8 215:6,20

216:10

packaging 81:5

packet 8:1

packs 113:12

page 3:16 58:13,14

104:1 187:20

188:1 199:16

paid 172:14,15

186:20 187:2

pair 76:8

paired 76:5,11 77:7

83:14,15

paragraph 49:16

58:13

paragraphs 62:10

parameters 13:7

62:2 146:5

pardon 22:7 124:14

parse 140:21

parsible 143:11

part 26:1 40:12

48:3 68:3 71:6

143:6 155:4

158:14 165:10

184:8 193:8

230:19 254:2

255:17

partially 216:9

participants 3:9 4:1

9:13

participate 10:15

particular 12:11

22:3 42:16 70:21

74:18 78:8 80:21

80:21 94:8 95:13

96:20 97:8 109:10

112:18 117:1,5

151:17 152:4

162:18 166:11

183:9,9,13,20

184:6 186:20

187:2 197:4

237:18 244:20

245:11

particularly 34:21

75:3 90:6 93:14

pass 246:15

passed 79:17

patience 5:16

pattern 138:6

pause 249:4

pay 176:10,13

179:12 185:14,19

197:11

payback 144:21

145:12,16 178:19

179:5 186:9,10

190:8 196:5,15

paying 117:13

176:21 187:13

195:21

pays 232:9

peek 63:21 101:20

199:8

penalize 182:4

penetration 234:11

people 30:18 35:1

43:7 116:2,16

117:11 118:18

130:18,21 132:7

141:13 143:4

153:11,16 154:18

160:9 171:15

173:9 179:16

181:2 189:3

192:10 198:6

236:5,9 237:20

239:1 242:16,20

250:22 252:22

253:14,18 256:12

percent 118:17

188:16 190:22

191:13,20 195:20

198:5

percentage 48:14

48:15,21 78:11

87:15 107:1

141:10 170:7

198:8,9 205:22

210:1 219:18

percentages 106:15

107:3 111:15

218:15

perception 237:8

performance 15:10

46:21 47:16 51:22

77:20 83:6 90:6

93:14 97:12

101:11

performed 204:6

227:7,15 234:17

234:22

period 11:21 36:4,6

120:16 121:3,18

144:21 145:12,16

147:7 175:17,17

176:1 179:5 180:7

196:5,15 203:12

203:14 204:2

206:9 207:5 210:9

219:13 220:13,16

221:4,8,15 224:15

224:16,18,21,22

225:6 226:12

228:1 230:18

234:6,15,16,20

236:6,19 247:16

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person 36:12 77:16

perspective 61:15

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phase 14:5 56:21

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249:2,2 251:6

phases 248:5 255:8

Philips 6:4 33:14

41:11 47:11 61:4

78:6 96:10 109:16

123:14 179:9

188:21 204:10

228:13

phone 2:21 128:5

171:11 242:20

246:20

phones 9:11

phosphor 62:9

94:21

phosphors 56:11,17

91:10

photon 56:18,19

physical 54:15,19

physically 41:14

132:2

pick 79:10 149:19

203:2

picks 68:9

picture 99:12

piece 73:20 187:10

pin 30:10 39:13

40:6,8,11 41:13

42:2 72:18 73:14

73:15 74:20 75:3

75:6,8 77:9,9,22

78:4 84:13 224:6

224:17 226:17

pin-based 41:4

172:9 182:20

pinned 77:13

place 43:19 140:9

208:9 225:14

248:13 253:11

placed 35:21 85:5

170:8

places 23:16 33:5

60:16 114:11

177:18 232:12

238:4

plan 17:8

plans 17:1 249:13

plateau 226:9

play 155:11 185:12

239:13

plays 37:13

pleasant 13:11

please 9:5,6 10:6

11:9,17 24:3 25:8

32:11 34:5 39:14

48:1 87:17 92:4

98:21 102:10

103:1 104:18

107:4 108:11

185:22 244:13

pleased 105:4

plotted 68:7 174:17

plug 239:13

plus 122:3,3,4

point 43:13 79:18

83:16 107:14

124:11,20 141:18

141:19 149:12

152:10,15 155:15

159:8 160:19

162:12 178:22

187:12,12 190:14

191:19 192:18

194:10 215:17

223:14 228:8

246:1 252:13

253:20 256:9

pointed 47:13 60:15

107:16 213:7

points 46:5 49:14

56:5 62:12 64:12

111:9 112:13

113:10 161:12

pollution 256:3

popular 40:19,19

40:20 188:9

portable 127:13,18

128:2 138:9

166:17 171:2

portion 147:11

148:17 207:6

posit 152:13

position 20:3 50:1

136:12

positive 233:19

possibility 207:3

possible 49:14 69:5

86:6 98:6 103:12

229:16 250:19

possibly 81:11

postal 11:20

posted 14:18

potential 26:18,21

27:11,12 30:17

77:19 120:10

249:9 252:18

254:4,11 256:7

potentially 38:21

189:22 193:15

231:11 249:8

power 7:1 44:3,21

47:1 57:19 119:14

139:1 181:14

205:19 214:21

234:21 239:10,11

239:15,17,18

240:3 242:2

243:11,11,20,22

244:2

powered 57:19

powers 76:21

practicability 58:2

practical 51:11

practice 75:13

preceding 45:8

197:13

predicated 33:16

predict 254:9

predicted 190:21

191:1 220:2

predicting 99:17

prediction 197:20

prefer 56:1

preferentially

135:10 188:10

preliminary 1:3 5:5

5:17 8:18 10:13

14:17 16:17 29:17

30:6 51:2 64:21

147:15 203:15

206:5 212:14,19

244:7 245:3

246:17 247:22

prematurely 33:2

premise 32:8

premium 46:16

present 51:1 79:11

126:15 127:4

202:10 233:5,19

239:15

presentation 10:21

38:11

presented 70:7 91:1

93:22 249:2

presenting 119:7

presents 69:14

144:9

preserve 74:19 98:6

208:21

press 202:14

presumably 139:16

presume 82:1

138:10

pretty 60:12 62:7

79:1 86:8 109:12

124:18 125:2

137:22 215:22

225:22 247:3

prevalence 135:8

224:4 234:5,13

preventing 49:5,11

prevents 77:15

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165:22 195:19

199:12,16

previously 20:7

21:2 109:5 201:19

255:9

price 8:13 34:21,21

35:13 103:6,8

105:10,15,22

106:14 107:18

110:15 111:5

112:3,13,15

113:10,22 114:6

115:4,17,20 116:7

116:9,12,17,18

117:5 118:7 125:7

125:8 128:20

145:1 146:5,21

147:1,2,5,10,11

148:5,16,18,20,22

149:5 152:3,10,12

152:19,22 153:4

153:13,20,21

155:2 156:16

158:17 159:3,8,8

161:11 162:19,20

162:22 164:7,8

175:22 176:2

178:12 179:21

180:3 185:15,19

186:21,22,22

187:2,9,11,12,12

188:9 192:17

197:5,7,11 201:1

201:3,4,5,6,7

202:6 205:9,13,16

205:22 206:3,9,10

206:15,17 207:6,7

207:10,11,12,15

207:18 208:1,5,10

208:13,15,18

209:11,15,18,22

209:22 210:4,4,7

211:3,6 212:11,12

212:13,15,20,21

214:12,15 216:20

217:19,20,21

227:17 228:3,22

priced 49:1 160:14

161:8,14 208:11

218:20

prices 35:2,3 105:11

105:12,17,17,18

105:22 106:2,13

106:22 108:5,6,8

113:5,7,19,22

114:2 116:11

117:6 147:1,2

148:2 150:13

152:11 153:5

154:3 155:11

157:11,11 159:1,7

159:11,12 161:15

162:21 163:15

164:7 187:21

193:5 201:7,11

205:14,19 207:9

209:4 210:13,15

213:9 214:20

227:16 228:17

239:1

pricing 153:10

154:3,4,5 158:4

159:15 185:20

192:20 213:11

primarily 73:17

135:1 138:3

primary 88:9 183:5

principal 37:20

print 165:13

prior 22:16 88:8

219:18 220:18

pro-rated 176:4

probabilities 167:20

175:9,11

probability 174:16

174:21 175:1

probably 8:20

23:10 36:1,19

40:14 48:7,10

68:6 105:2 111:19

124:10 126:19

131:20 142:11

157:18 171:5,17

173:11 176:20

177:4,19,20

179:20 182:9

186:4 191:2

224:17,19 230:21

237:11 238:18,20

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problems 31:9

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procedure 18:13,20

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proceed 245:2

246:3

process 49:10

103:11 251:16

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processes 156:22

processing 174:1

procurement

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113:4

produce 77:19

205:16 250:17

produced 252:16

producers 250:13

produces 27:19

228:18

product 8:13 13:3

22:21 23:17 31:14

35:11,13 46:11

50:5 51:8,19,21

52:4 53:9,10,16

53:17,19 58:5

64:9,12,20,22

65:3,9,11,18,20

66:2,3,5,9,14,15

66:18,19,20 67:1

69:8,16,17,20,22

70:2,4,7 71:3,7

72:15,17 73:21

74:6 77:3 80:14

80:15 88:9 89:13

89:16,20 90:5,21

91:1,4,6,8,9,13,14

91:16 92:22 93:4

93:7,14,21,22

94:9,12,19 95:6

95:10 97:12 98:9

100:8,17 103:6,8

105:10 107:15,16

108:16 109:6

110:10 115:5

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159:3 160:15

162:19 163:17,17

164:1,7 165:11

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178:6,16 181:10

181:11 182:2

186:3,3,5,22

188:4 196:2

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209:17 210:7,8

214:22 215:15

217:22 219:11

221:11 225:19

226:18,20 227:1

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251:14

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228:20,21 255:19

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27:1,16 31:18

32:22 33:20 39:18

40:13 45:3,21

47:18 48:6,21

49:7 50:11 51:20

52:2 74:18 75:2

88:18 89:1 94:17

96:7 98:16 99:11

101:18,18 106:19

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155:1,5 156:7,18

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162:2 172:13

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211:2 215:4,14

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237:6 252:16,18

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programs 85:18

141:22 142:3,4

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prohibitive 61:15

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projection 203:18

204:19 205:11

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203:16

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promoting 46:10

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proposal 47:3 71:12

217:1 232:22

proposals 12:12

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proposed 14:14,21

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prototype 62:20

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provide 10:3 11:8

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28:9 43:2 50:16

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144:18 159:22

160:4 189:15,21

215:22 218:17

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public 1:2 5:4,9

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publish 13:22 14:20

published 14:16,17

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purchase 81:8

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188:14,15 195:15

purchased 106:4

129:9 162:18,21

180:8,12 184:14

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197:3,22 201:16

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purchasers 145:4

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198:10

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purple 217:11

purpose 10:8,12

51:6 119:8 144:17

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purposes 71:17 72:2

177:12 178:18

222:20

pursue 244:19

push 43:6 198:9

put 25:16 34:15

35:4 63:20 75:4

77:11 79:19 83:9

86:9,10 96:11,18

112:21 128:20

130:17,20 131:1

132:4 156:4

157:12 171:18

196:20 209:12

215:1 226:5 229:2

237:20,22 238:4,6

238:8 242:20

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quads 233:18

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qualifications 50:12

qualified 48:6

qualitative 248:19

254:2,3,4,11

qualities 46:16,17

quality 13:7 35:13

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50:4,9,14 103:4

130:22 156:16

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quantitative 248:16

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quick 103:10 126:7

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quickly 22:15 78:16

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reflectors 223:9,12

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149:16 220:17

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regardless 50:12

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regions 119:22

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regulating 129:18

regulation 19:21

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remainder 205:7

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removing 57:9

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renovation-driven

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renovations 168:22

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repeat 98:7 128:9

replace 27:5 41:13

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resulting 90:7,21

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retail 105:17 107:8

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retrofits 169:1

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returning 8:15

reverse 105:14

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revert 226:1

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rid 99:7 173:10

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rightly 78:7

risk 84:4

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rock 32:13

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roll-up 184:12

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166:9,12 170:19

171:19 202:17

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room- 166:11

room-type-specific

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rooms 127:21 138:5

139:10 140:13

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rotary 136:10

rotate 171:17 172:3

rotated 129:11

rotating 129:7

rough 22:5

roughly 133:3 220:9

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roundabout 8:10,14

row 67:7 92:6,8

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rows 87:4 88:12

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rule 11:19,19 14:1

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60:21 120:10

203:13 246:4

rulemaking 10:17

11:18 13:17,19,20

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15:18 16:21 17:5

17:9,14 18:3,13

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rulemakings 39:3

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running 62:14

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Ryder 104:2

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sales 111:21 112:7

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249:1,12

thought 49:17

74:15 115:18

126:9 230:6 244:1

251:15

thoughts 26:13 28:1

29:6,13 32:18

38:9 41:16,18

43:12,15 49:15

53:8 56:5 63:13

63:22 67:3,19

75:11 139:6

149:15 155:12

217:4 219:8

226:14

thousand 46:7

thousands 61:8

thread 29:8

three 15:3 65:3

168:16 169:13

174:18 254:14

three-way 12:22

22:4

throat 203:8,9

throw 32:6 36:22

171:16 179:17

thrown 47:17

171:22 172:2

tied 33:17

Tigges 4:10

Tim 7:15

time 9:5,6,9,19 18:4

30:15 33:22 36:4

36:6,6,12 44:4,21

72:12 98:6 99:3

104:8 109:8

118:17 126:15

127:4 136:11

140:2 144:22

153:14 156:13
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January 20, 2015

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164:16 168:4

170:14 176:3

177:4 190:17

192:16 206:1,2,11

210:4,7 212:15

215:2,21 224:21

225:21 226:11

230:18 231:5

233:13 236:6,11

237:9 242:6

243:16 249:3

timers 134:16

times 45:14 48:20

116:17 141:11

153:12 187:14

201:6

tipping 246:1

title 11:18 123:20

today 5:6,16 8:19

27:6 33:20 48:13

55:9 61:15 76:6

99:13 107:21

123:17 125:12

129:21 133:2

152:9 153:13

155:15 156:19

160:22 179:17

216:22 225:20

226:21 239:22

250:12

today's 10:13 25:14

160:18

told 237:20,20

238:3,8

Tom 2:12,22 6:12

7:1 22:7 37:2,10

82:20,21 127:9

136:19 143:11

151:4,5 154:6

181:13,14 235:11

237:16 238:16

Tom's 137:8

tons 190:16

tooth 239:20

top 47:15 58:14

132:8 217:9

topic 192:22

total 15:9 129:21

134:12 136:21

137:3 144:20

146:19,20 233:8

totally 9:15

touch 30:22

touched 141:4

229:7

tough 97:13

toward's 219:15

track 100:21 111:16

111:19,20

trade 250:19

trade-off 37:15 83:7

traditional 67:15

134:15

traditionally 16:2

20:9 46:6 55:4

239:14

transcript 9:7

transformation

183:22 184:17

201:14

translate 98:2

125:18

travels 256:22

treat 24:10 169:4

treated 30:21

119:18 161:7

treatment 12:21

trend 161:16 207:1

208:5 210:4 212:1

212:10,15 213:7

215:5 217:15,20

218:5

trends 90:3 93:9

148:2 156:16

212:10,21 214:10

214:11 215:9

217:16 219:3

229:11

triangular 167:3

tried 76:8 114:2

triggering 120:11

trivial 110:4,8

243:13,14,15

trouble 61:7

true 48:10 82:16

83:3 138:4 171:8

215:3 229:8,9

truncated 163:21

truncates 168:19

169:5

try 54:17 61:13

80:17 82:13 83:16

180:6 181:2

186:16

trying 9:14 33:21

61:9 116:1 132:9

132:10,10 155:21

156:16 160:13

171:21 181:4

189:19 197:16

225:10 254:9

TSD 45:11 58:10

74:1 80:12 110:17

110:19 111:9,12

114:17 115:8

120:3 135:15

144:9 148:11

155:12 192:7

196:14 205:18

222:4 223:15,18

tube 70:10

Tuesday 1:6 5:6

turn 9:11,16 33:6

56:13 83:10 119:3

154:17 235:14

240:10,13

turn-over 173:6

203:19

turned 240:17

turning 6:2

turnover 168:22

TV 129:13 139:22

171:18,19 173:22

TV's 60:1,4 61:5,8

171:18 174:2

twice 181:8 214:2,5

two 13:19 19:8

37:19 70:6 72:1,1

73:21 109:1

118:10 124:3

134:2 173:4 183:4

198:21 202:5

204:16 206:6,19

208:3 211:14

213:12 219:10

223:4 226:13

227:21 229:4

232:13 246:13

two-fold 123:18

two-thirds 153:20

type 19:21 21:17

25:22 29:18,20

31:3,19 46:10

51:20 54:22 69:7

71:8,20 76:5

83:11 88:1 89:18

100:16 127:11

134:14 144:8

146:18 149:4

156:3,5,7 165:22

166:9 167:4

184:10 186:3

244:20

types 15:20 16:4,16

18:18 21:1,21,22

22:3 29:15 30:4

38:13,19 40:5

42:9 87:20 88:14

95:19 133:14,16

140:22 166:2

182:2

typical 99:19 152:8

152:14 156:9

173:6 252:22

typically 9:4 23:17

65:12 66:7 79:20

80:12 81:5 85:2,4

112:10 117:10

148:22 190:19

193:2 251:15

U

U.S 1:1 5:3 14:13

119:11,22 120:2

128:22 133:14

203:20 250:16

Um-hum 97:1

un-mute 128:5

unbreakable

109:20

uncertainty 200:18

unchanged 37:17

unclear 48:13

undergo 208:1

understand 16:19

22:17 23:2,15

42:6 79:9 82:22

107:20 109:17

142:10 152:3

160:13 178:2

180:2 211:22

214:9 232:7

247:10 251:12

understanding

16:21 32:7 81:7,9

131:19

understood 29:5

222:15

undertaking 21:11

Unfortunately

237:17

UNIDENTIFIED

29:10

unintended 27:21

unique 65:9 109:22

unit 52:12 67:1

90:14,17 95:2

96:21 105:19

108:6,8 116:7,20

153:20

United 221:3

units 67:4,20 76:12

93:18 113:18

unmute 9:20 171:11

246:20

unreasonable

115:15

unusual 214:18

update 13:6

updated 45:2

updating 44:18

46:21

upper 199:20 200:4

upper-bound 55:16

usage 129:10 172:3

243:1,2

use 8:16 23:7 27:12

30:18 31:3 40:16

40:18 45:19 50:5

54:22 56:2 57:9

57:12 58:20 60:2

60:15 64:12 75:15

82:3 94:4 95:13

97:5 101:7 106:14

108:14 119:7,9,10

119:11,18,19,22

120:18,19,21

121:2,8,8 122:6,6

123:3,3 124:6,11

126:10,12,21

127:15,16 130:16

132:10,12 133:13

133:17,18,19

134:1,12 135:20

136:21 137:1,3,17

138:21 143:4,20

143:22 144:2,3,10

144:11,12 146:5

150:18 164:20

165:18,19,20

166:10,12,13,18

166:20,22 167:4,5

167:6,7,9 168:4,9

172:21,22 196:22

232:3 236:10,17

237:8,21 238:1,7

238:9,10 239:21

242:11,20 253:9

useable 155:6

useful 53:8 189:15

189:21

user 79:5 105:11,17

106:2,21

uses 36:12 89:22

93:2 177:1 233:8

usual 99:4

usually 19:7 77:7

138:13 251:22

utilities 6:20 132:17

256:1
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January 20, 2015

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utility 15:9 29:22

51:14 52:1,10

53:14 95:19

100:16 108:22

109:13 209:2

237:19 243:5

255:22

utilize 24:4

utilized 90:1 93:8

UV 56:19

V

vacation 240:16

Vagelis 3:19

value 90:11 93:17

95:1 134:18 145:9

147:19,21 152:13

175:14,15,16,19

175:21 176:4

178:2,8,8,11,15

179:1,11,14

180:10 181:4,5,10

193:11,16 233:5

233:13,19 247:8

values 233:12

vanish 212:22

vanishes 217:20

variability 140:6

146:4 163:14

165:16 166:20

167:9,19

varied 122:11

variety 86:17

various 12:8,18

58:14 120:2 204:7

253:14

vary 121:9,16 144:7

151:10

varying 227:8

vast 76:14 100:8

110:21

vein 83:17 103:5

verification 89:14

verses 197:1

version 226:22

versus 46:16 50:8

55:9 61:17 98:12

108:16 117:2,18

118:18 126:10

137:11 140:10

153:17 156:8

231:17 236:6

238:2

vertical 91:4

viable 73:12

vibration 12:22

22:4

view 13:2 43:7 50:8

73:15 83:16

152:15 190:14

viewed 237:5

252:20

viewing 139:22

vintages 190:4

virtue 128:20

visible 56:18 102:6

110:8

volatile 149:3

volt 22:22,22,22,22

voltage 20:16 22:17

22:18 23:7,13,19

23:19

voltages 22:21

volts 23:6 41:4

volume 26:17 65:9

74:3,17 97:21

98:2 148:21 149:1

210:12,14,16

216:16 218:20,21

218:21

Vossos 3:19

W

waist 102:6

wait 103:15 124:7

149:13 239:18

walk 113:9

Wallace 3:21 104:3

walls 170:20

Walmart 113:1

Wannakay 104:1

want 10:8 12:11

23:2 32:6 35:1,16

37:11 39:16 45:19

46:2,11 49:13,20

59:20 63:3 74:18

84:13 96:4 98:4

98:15 112:2,10

118:1 124:19

128:9 132:7,22

154:8 160:1

170:17 178:2

180:14 182:4

185:21 186:7

191:7 194:9

202:12,15,15,17

208:21 222:15

225:14 239:22

240:18 244:14

245:13 249:6

252:11 256:16

wanted 32:19 38:12

42:12 50:10 78:15

124:20 212:6

wants 10:2 49:19

132:1 150:14

warrant 22:1

wary 126:3

Washington 1:12

5:8

wasn't 84:18 117:8

129:5 239:5

251:20

watched 232:10

watt 14:7 31:2 32:9

33:6 53:21,21

54:1 55:4,5,5,6

66:6,9 67:8,16

72:22,22 74:11,11

74:13 75:8 77:12

77:13,16,18 78:18

78:18 88:19 99:20

99:21,22 113:20

116:5 129:20

130:2 131:20

133:6 173:16,18

214:8,9 230:5,19

230:19 235:2

243:12,13,13,14

243:15

watt- 164:2,3,3

165:7

watt-equivalent

133:2 151:22

152:9 164:4 165:5

wattage 68:11 70:4

70:12,14,16 72:20

73:3,3 75:4,9 77:8

79:17 80:4,4,7,15

80:15 81:1,6,9

83:22 84:3 93:4

94:9,20,22 95:2

133:4 221:9,10

224:15 226:17,22

227:2 239:21

wattages 68:12

193:3

watts 55:3 73:1 84:6

84:6,8,9,14

125:20 173:18

wavelengths 57:3

way 9:3 24:8 29:8

30:21 35:19 53:1

54:6 73:22 77:14

77:14,22 84:19

94:15 96:6 99:1,4

101:8 102:4

117:17 136:20

137:12 155:13

156:1,9 157:2,15

181:22 182:14

185:22 216:20

224:19 232:14

ways 11:16 35:3

141:22 212:2

250:4

we'll 124:7 159:17

192:18 202:19

250:21

we're 94:13 100:22

186:7 218:8

we've 49:6 60:16

190:18 238:22

wear 170:1

weather 126:21

web 9:15 10:6 14:19

105:5 128:5

228:15

webcast 10:1

Webinar 3:9 4:1

9:13

website 159:13

weeds 28:7

week 34:10

weeks 240:16,18

Weibull 167:21

168:21 169:6

weigh 25:20

weight 112:6,7,8

116:8,13,14,16,17

117:17,19 118:19

146:16 150:21

154:13 158:6

181:9

weighted 106:14

113:6 114:13

116:22 118:3

128:2 136:18

153:4 154:8

162:15 163:3

weighted- 121:12

weighted-average

134:7

weighting 106:12

113:2 115:10

118:15 153:10

154:13,15,17

163:7 173:5

weightings 112:19

153:1 160:1

weights 150:18

162:1

weird 109:3 190:8

welcome 5:3 7:20

9:13 109:9,14

117:19 160:2

167:11 189:14

203:1,4 212:4

welcomes 148:12

235:8 250:5

welcoming 5:13

went 48:11 84:2

103:2 210:16

230:20 231:9

weren't 58:19 159:6

251:9

Westinghouse 6:10

22:10 23:14 25:9

34:6 39:15 45:10

54:4 73:19 79:3

80:10 82:10 97:3

114:19 148:15

158:1 177:14

185:10 208:8

222:14 238:15

white 43:7 57:4

wider 98:9 140:6

wife 239:4

WIFI 239:20 252:4

willing 179:11

Wilson 104:3

wireless 134:16

174:2

wish 246:8

wishes 8:4,22

woke 203:8

wonder 137:9 155:4

wondering 107:12

141:13 152:15

158:9,16 160:16

213:19 231:15

244:19

words 145:15

153:16 175:20

185:6 252:3

work 43:9 67:22

68:4 79:10,12

80:8 81:22 82:1,5

83:10,21 102:4

192:17 209:6

215:16 222:12

240:5

working 9:19 34:8

99:5

works 7:5 82:17

182:15

world 53:3 75:15

world's 228:19

worse 39:20 115:5

worst 125:19
Energy Conservation Standards Preliminary Analysis for General Service Lamps

January 20, 2015

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worth 134:14

147:10 246:4

wouldn't 78:19

172:2 186:6

191:15 213:20

218:13 240:4

241:8 253:10

wow 153:19

wrap 256:10

writing 128:10

written 10:3,6 11:9

11:15 43:2,15

46:18 100:15

155:13 162:10

229:2

wrong 32:11 77:11

82:14,14 127:10

158:15 232:12

X

X 68:13

Xin 4:5

Y

yeah 29:2 34:7 37:4

37:11 46:3 62:15

63:9,19 80:11

81:4 82:10 84:16

85:16 101:4 108:5

116:20 136:20

140:20 142:5

153:8 172:6 191:7

192:14 193:20

195:2,9,10,11

214:18 225:7

240:7 243:16

246:21

year 7:22 14:22

33:7 35:7 36:15

36:15 38:7 60:17

123:8 145:14

148:7 156:14

173:8,19 176:6

179:6 180:7,8,9

180:10,11,12

184:8 186:10

196:4,13 199:19

201:21 203:12

204:20 205:14,17

206:9 211:13

218:7 219:19

224:14 225:5,20

227:22 231:1

233:9 238:10

years 15:3 31:13,15

33:4,7 35:20,21

36:1,18 40:14

41:6 46:8 59:10

85:19 99:19

160:19 168:17,21

169:7 171:4 173:7

173:8,20,20

174:17,22 175:3

180:11 181:8

186:12 201:21

205:12 206:22

217:15 219:16

224:19 228:9

Yep 17:15

yield 120:10

yields 183:18

231:11

Z

zero 107:7 170:15

216:12 217:2,2,17

218:13,14 219:5

228:1 235:5 236:4

238:19 240:2

242:22 244:10,10

245:22

Zigbee 239:20

0

02 233:18

1

1 45:18 72:9 76:16

116:7 118:14,18

120:14,16 173:18

188:8 194:12

233:20 235:2

241:9

1% 170:15

1,000 43:21 137:5

1,050 231:19 232:18

1,300 200:7,8

1,490 222:9 223:1

1,500 137:5 199:21

199:22 200:14

215:11

1,600 54:14 215:14

215:15 216:18

1,650 100:1

1,800 54:14

1,900 137:4

1,999 53:18 65:4

1.0 48:11

1.00 176:14

1.1 48:12 54:1

1.5 190:22

1.50 107:10 118:7

1.7 192:2

1/2 191:20

1:00 202:19

1:05 202:21

10 35:8 47:6 92:11

122:10 131:15

173:17 177:2

178:10 180:9,11

181:8 202:13,14

243:13,15

10-ish 160:22

10% 69:4 70:17

71:1 73:4,11

74:22 86:8 113:4

138:19 176:12

10,000 46:13 50:13

145:4 146:6 178:5

178:11 179:12

194:3

10.00 115:4,13

152:1,9 158:10

10.00-ish 152:12

10.7 134:8

10:30 8:11

100 35:5 55:6 84:9

99:22 133:2 165:7

173:17 214:8

100-watt 164:3

200:7

100% 45:14 80:11

82:18 83:13

234:19 242:10

1000 1:9

10C 135:15

11 243:13,15

11% 86:8

11:00 102:2,13

11:15 102:11

11th 14:17

12 22:22 23:6 35:8

36:15,18 95:21

230:20

12,000 92:11 96:14

120 41:3 53:21

120% 167:6

125 53:21 54:1 66:9

13 66:22 74:11,11

116:5

130 41:3

14 33:4,7 70:18

133:13

14% 134:22 138:2

141:6,12,12,15

142:13

14.00 162:5,15

15 77:1 102:2

158:11

15% 122:10 227:21

15,000 35:4

1500 132:1

16 95:8

1600 133:3

17 31:13,14 35:20

35:21 36:1,15

95:11 199:19

17% 242:11,13

18 24:2 74:11 77:13

77:16 95:15

103:21 160:18

19 106:20

19.00 115:12

1999 54:9 55:16

222:9

1A 92:9

1C 118:8

1st 13:22 14:1

2

2 55:7,9 62:6 64:11

72:8,18 75:3,8

77:9 87:5,14 88:7

89:10 99:18 100:7

100:17 101:1

116:6,16,17

117:18 153:18,20

160:14,18 161:3

177:11 185:13,16

188:11 190:19

194:12 198:8

211:1 213:13,13

213:13 233:20

240:16 255:8

2-47 58:13

2-ish 8:20

2,000 46:12 53:16

53:20 54:2,12

65:5 66:11 99:18

100:3 163:22,22

199:13,21,22

200:8,14 215:22

221:21 222:8,18

223:3

2,200 124:17 143:12

2,549 54:2

2,600 53:16 65:6,7

66:11 199:13

223:1

2,700K 170:20

2.00 107:10 118:7

118:11 153:17

2.3 121:14 122:1

131:8 137:1

2.5 122:13

2/3rds 157:19

2:00 202:20

20 1:6 5:6 40:14

86:7 122:20

168:21 216:13

20% 49:2 226:9

20,000 178:10

2003 146:14

2007 13:18 120:11

121:19 163:20

203:21

2009 146:11

2010 133:14

2013 14:16

2014 13:22 14:17

18:21 147:2

162:20 201:4,6

2015 1:6 5:7 11:11

11:22 14:22

156:20

2016 15:1

2017 14:1

2018 125:13

2019 15:3

2020 60:12,13 76:10

100:2 120:14,16

123:17 125:11

127:5 146:21

147:1 162:20

201:20 203:15,22

219:18,20,22

220:10,15,18

224:10 233:7

2025 196:15 201:20

2049 203:15 227:21

233:7

2050 224:10

20585-0121 1:12

21 78:18 84:6

121:18 124:22

129:16

22 21:5,9,12 135:17

216:13

2200K 42:19

23 74:11 135:19

24 22:22 123:21

24/7 243:15

25 115:12 173:8,19

188:12 192:5,6

25-$30.00 160:20

25% 47:15 48:7

25,000 35:4 36:11

92:12 151:18

174:17 194:15

25.00 187:12
Energy Conservation Standards Preliminary Analysis for General Service Lamps

January 20, 2015

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Page 290

26 72:22,22 73:1

75:8 77:12,18

78:18 84:5 192:5

2600 26:20 38:15,16

41:3,22 42:10

26th 18:21

27 119:22

27% 198:2

28 180:8,12

29 149:12

2A 92:9

2B 92:9

3

3 22:22 36:13 59:2

62:6 105:7 116:17

158:14 168:14

188:11 190:19

198:8 204:20

210:21 213:13

233:14 238:4

240:18 248:5

255:8

3% 221:2,20 225:4

225:9 230:2

3,500K 170:21

3:03 257:1

30 85:19 140:4,4

174:22 180:7,10

188:16 192:6

203:12 224:14,19

225:5

30% 86:7 134:12,18

136:2 137:2

138:18 140:2,8

235:19

30.00 161:22 162:4

162:14 187:12

197:5

300 215:9

31 47:20 141:12

310 20:19,21 26:19

41:3,22 53:18

65:4,7

32 74:13

34.00 195:1,2,3,4

197:7

35 177:6 182:10

247:5

35% 177:5

4

4 55:1,8,19,20 59:4

75:6 77:8 80:20

106:5 118:6,11,13

118:14,18,20

150:7 153:19,19

188:8,10 201:6

213:14 222:17

238:9

4.00 172:15

40 42:19 55:3,4

164:2 217:5

230:19

40% 43:21 177:6

182:10,21

42 67:6

430 108:18

45 14:7 32:9 92:4

96:12 129:20

130:1 131:19

450 216:16

49% 195:4

5

5 40:1 44:2 47:3,5

99:15 112:11

118:6 141:12

152:14 169:7

173:7,8,20,20

174:10 188:8,10

199:18 201:20

202:19 203:17

210:21 213:14

220:4 228:9

233:18

5% 113:4 135:2

142:20

5.00 118:8 172:16

50 35:5 111:2

168:17 171:4

172:14 177:10

50% 129:22 228:1

234:15 235:22

50/50 87:8

500 215:9

52 98:21

55 100:13

57 108:11

6

6 22:22 40:1 99:13

116:6,15,17

117:18 118:11

6,000 46:8

6.00 107:8 118:9

60 33:6 55:5 66:6

67:8,15 99:20

113:20 151:22

152:9 164:3,4

165:5 214:9 230:5

230:19 243:14

66 107:7

66.7 92:10,18

67 88:18 229:16

68 88:19

69 88:19

7

7 15:6 41:17 120:3

144:9

7% 233:14,20

70 177:21

70% 86:2

700 66:8 67:14

231:10,17 232:16

7000K 42:20

72 31:2 84:8

75 55:5 99:21 164:3

165:7

75% 47:17 48:7

113:2 115:10

75.9 96:13

750 67:9 68:4,16

231:7,17,17,18

232:16

8

8 45:5 180:11

8,000 46:9,14

8.00 38:8 113:15

152:10 158:12

80% 45:17,18 167:5

800 67:12 99:19

216:1,3,17

82,000 140:21

143:12

85 173:16

850 67:12

87 244:15,16,17

246:22

89 246:13

8B 201:21

8E-089 1:11

9

9 14:16 205:18

9.00 113:16

9:00 1:7

900 66:8 67:14

125:20 231:11,17

232:18

95 43:5

96% 228:18

9th 11:11,22 256:15
291 

TRANCRIPTION CERTIFICATE 

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