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### 1



### U.S. DEPARTMENT OF ENERGY

+ + + + +

PUBLIC MEETING ON ENERGY CONSERVATION STANDARDS PRELIMINARY ANALYSIS FOR GENERAL SERVICE FLUORESCENT LAMPS (GSFLS) AND INCANDESCENT REFLECTOR LAMPS (IRLS)

+ + + +
TUESDAY, APRIL 9, 2013

+ + + + +
The public meeting convened in Room 8E

- 089, U.S. Department of Energy, 1000 Independence Avenue, SW, Washington, D.C., at 9:00 a.m., Doug Brookman, moderator, presiding.

PRESENT
DOUG BROOKMAN, Public Solutions, Inc., Moderator ALEX BOESENBERG, NEM A SUSAN CALLAHAN, Osram Sylvania KEITH COOK, Philips HAYDEN COOK, Navigant Consulting LUCY deBUTTS, DOE ANDREW deLASKI, ASAP KARINA GARBESI, LBNL BRIAN GERKE, LBNL JOHN GREEN, Cooper Lighting PEKKA HAKKARAINEN, Lutron JOSEPH HOWLEY, GE AISHA HUSAIN, Navig ant Consulting MAUREEN KIENLE, Navigant Consulting ALI McDONALD, Navigant Consulting MIKE McGARAGHAN, Energy Solutions JULIE PIERCE, Navigant Consulting STEPHEN ROSENSTOCK, EEI ERIC STAS, DOE CHARLIE STEPHENS, NEEA

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### 2



### PRESENT VIA WEBINAR

ANDREA ALSTONE, LBN L JENNIFER AMANN, ACEEE TIMOTHY BALLO, Earthjustice MICHAEL BRANCATO, Navigant Consulting ROB CARMICHAEL, Navigant Consulting NATASHA COLLINS, PNNL JAMES CYRE, Philips RACHEL DICKENSON, Navigant Consulting ANTHONY FRYER, ASAP AUSTIN GELDER, ICF Internation al TOM HARDING, Venture Lighting International TANYA HERNANDEZ, ICF International ROBERT LINGARD, PNNL DAVID LIS, NEEP ARIS MARANTAN, Navigant Consulting SCOTT MORRIS, PNNL MICHAEL MYER, Battelle/PNNL ERIK PAGE, Erik Page & Associates STEVE STOCKDALE, Adva nced Lighting Technologies ALEX VALENTI, LBNL JUAN VELEZ, Westinghouse Lighting Corp VAGELIS VOSSOS, LBNL LINDA WILSON, NYS OAG

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### 3



### A

- G

- E

- N

- D

- A

Welcome, Introductions, Opening Statements, Overview, Statute, Context 4
Market and Technology Assessment, Screening Analysis 52

Engineering Analysis 85

Break 135

Product Price Determination 202

Lunch 211
Energy Use, Life

- Cycle Cost 212 Analysis
Shipments, National Impact 269 Analysis
Preliminary Manufacturer Impact Analysis, NOPR Analyses 338
Closing Remarks 360
Adjournment

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### P

- R

- O

- C

- E

- E

- D

- I

- N

- G

- S 1



### 9:00 a.m. 2


### MR. BROOKMAN: Good morning, 3


### everyone. Welcome. This is the U.S. 4


### Department of Energy's public meeting on 5


### conservation standards preliminary analysis for 6


### general service fluorescent lamps and 7


### incandescent reflector lamps. 8


### Today is Tuesday, April 9th, 2013, 9


### here in the Forestall Building at the 10


### Department of Energy in Washington, D.C. 11


### My name is Doug Brookman from Public 12


### Solutions. Glad to have you here with us this 13


### morning. We'll star t with welcoming remarks 14


### from Lucy deButts. 15


### MS. deBUTTS: Good morning, 16


### everyone. Thank you for coming. Good to see 17


### you all here. I'm happy to see quite a few 18


### members of the industry here. 19


### We will be presenting the 20


### preliminary analysis for GSFLs and IRLs today 21


### and without further ado we can begin. 22

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### MR. BROOKMAN: Thank you. Let's 1


### start with introductions as we typically do. 2


### We'll start to my left, your name and 3


### organizational affiliation. 4



### MR. HAKKARAINEN: Pekka Hakkarainen 5



### with Lutron Electroni cs. 6



### MR. K. COOK: Keith Cook with 7


### Philips. 8



### MR. GREEN: John Green with E a ton 9


### Cooper Lighting. 10


### MR. BOESENBERG: Alex Boesenberg, 11



### NEMA. 12



### MS. CALLAHAN: Susan Callahan, Osram 13


### Sylvania. 14


### MR. HOWLEY: Joe Howley, GE 15


### Lighting. 16



### MR. STEPHENS: Charlie St ephens, 17


### Northwest Energy Efficiency Alliance. 18



### MR. ROSENSTOCK: Steve Rosenstock, 19



### Edison Electric Institute. 20


### MR. STAS: Eric Stas, DOE General 21



### Counsel Office. 22

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### 6



### Dr . GERKE: Brian Gerke, Lawrence 1


### Berkeley National Lab. 2


### MS. KIENLE: Maureen Kienle, 3



### Navi gant Consulting. 4


### MS. HUSAIN: Aisha Husain, Navigant 5


### Consulting. 6


### MS. PIERCE: Julie Pierce, Navigant 7


### Consulting. 8



### MR. BROOKMAN: Please introduce 9


### yourself. 10



### DR . GARBESI: Karina Garbesi, 11


### Lawrence Berkeley National Lab. 12



### MR. BROOKMAN: Thanks to all of you 13


### for being here on time, getting us a good early 14


### start on the day. 15


### All of you received a packet of 16


### information as you came in this morning and an 17


### agenda, a packet of PowerPoint slides and a 18


### Federal Register notice. 19


### Let me do very briefly a g eneral 20


### review. Immediately following this agenda 21


### review there is the opportunity for anyone that 22

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### 7



### wishes to do so to make brief summary remarks 1


### about issues that matter to you for this 2


### meeting today. 3


### Following that we'll have overview 4



### and statute and c ontext review. Then 5


### technology

-- market and technology assessment 6


### and screening analysis and following that 7


### engineering analysis. We'll take a break mid

8


### morning

- ish, 10:30, 10:45 or so. 9


### Following the mid

- morning break, 10


### product price determination an d then energy use 11


### analysis and life

- cycle cost analysis. We'll 12


### take lunch around about noon today or whenever 13



### we get to noon

- ish. 14


### Then following straight from there 15


### shipments analysis, national impacts analysis, 16


### preliminary manufacture impact analysis , NOPR 17


### analyses plural, and then closing remarks at 18


### the end of the day, another opportunity for 19


### anybody that wants to to raise additional 20



### issues. 21


### Make sure your issues are covered 22

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### 8



### during the course of this meeting today. 1


### Okay. So that's the plan. 2


### Questions or comments about any or all of that, 3



### Keith? 4



### MR. K. COOK: Keith Cook from 5


### Philips. Question

-- is there anybody on the 6



### line that

-- 7



### MR. BROOKMAN: We have five

-- how 8


### many? Twelve individuals on the line. 9


### MR. K. COOK: And who are they? 10



### MR. BROOKMAN: Do you want to

-- can 11


### you read off their names, Jack? 12


### Why don't you hand Jack that 13


### lavalier mic? That's a good question. 14


### MR. GRAUL: Okay. We've got Anthony 15


### Fryer, Aris Marantan, Austin Gelder, David Lis, 16


### James Cyre, Jennifer Amann, Linda Wilson, 17


### Michael Myer, Rachel Dickenson, Robert Lingard, 18


### Steve Stockdale and Tom Harding. 19


### MR. BROOKMAN: Okay. Thank you. 20


### Many of you have participated in these meetings 21


### previously. I'd ask if you would please speak 22

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### 9



### one at a time. Please say yo ur name for the 1


### record each time you speak. 2


### There will be a complete transcript 3


### of this meeting made available. If you could 4



### be concise

-- please share the air time. There 5



### is much to be said and we don't want to waste 6


### anyone's time. 7


### Please keep t he focus here. Put 8


### your cell phones on silent mode. Limit sidebar 9


### conversations. You've already gotten used to 10


### turning these microphones on and off, and 11


### webinar participants, we welcome you. 12


### The Department of Energy wants to 13


### make these meetings acce ssible to all via the 14


### web. Please turn your phone on mute as you are 15


### listening and you can raise your hand using the 16


### software to be recognized to speak. And I'll 17


### be doing my best as we go along, queuing 18


### individuals by name. 19



### Sometimes the follow

- on, t he back 20


### and forth between different perspectives is 21


### very useful for the department. So I wish to 22

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### 10



### encourage that as well. 1


### Do you want to do a few preliminary 2


### slides or do you just

-- Lucy deButts. 3


### MS. deBUTTS: Hi again. I just want 4


### to tell everyone that webinar participants, 5


### just like Doug mentioned, can actually talk to 6


### us if they raise their hand. Their 7


### comments are going to be made part of the 8


### transcript so they will be available on the web 9



### as well. 10


### Okay. Well, let's begin with the 11



### purpose of this public meeting. The purpose 12


### is, of course, is to present the preliminary 13


### analysis for GSFLs and IRL products. 14


### We invite participants to comment on 15


### our analysis. We do appreciate your feedback. 16


### Any data you can provide will be useful to us. 17

18


### We will discuss the next steps in 19


### the rulemaking process and, again, whether it's 20


### written comments or you just want to express 21


### your opinion right now in our open forum you 22

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### 11



### are more than welcome. 1


### We encourage that. In order to 2



### facilitate the discuss ion we are going to be 3


### using the issue boxes so throughout the 4


### presentation you will see those boxes. They 5



### will not be numbered in order. 6


### They will be numbered by

-- in 7


### according to the issues that are presented in 8


### the preliminary analysis so if you'd like to 9


### comment on more than what we're asking you're 10



### more than welcome as well. 11


### Technical support documents are 12



### available in the docket and here's the link to 13


### the docket, and as I mentioned the deadline for 14



### written comments was extended. It's now Ma y 15



### 13th of 2013. 16



### And this is a slide on how to submit 17


### written comments. Again, please if you're 18


### submitting written comments write the title of 19


### the rulemaking, include the docket number and 20



### RIN number into the comment. 21



### Comments can be submitted in a 22

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### 12



### num ber of ways. One is, of course, in an 1


### email, and then Brenda Edwards, who everybody 2


### met coming in today, she can receive the 3


### comments that are sent via postal service or 4


### courier. And, again, May 13th is when the 5


### comments are due to the Department of Ener gy. 6


### Okay. Opening remarks? 7



### MR. BROOKMAN: Remarks here at the 8


### outset summarizing concerns, issues that you 9


### wish to bring to the fore. Alex? 10


### MR. BOESENBERG: Alex Boesenberg 11


### from NEMA. First, I want to thank the 12


### department for granting the extensio n on the 13


### comment period that industry and the advocates 14


### together have requested. 15


### That gives us more time to process 16


### the large amount of information and provide a 17


### better response and we appreciate that. 18


### And as far as my opening remarks 19


### regarding the content which we'll be discussing 20


### today, for now I'll restate the concerns as we 21


### stated them back on October 5th, 2011, the last 22

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### 13



### public meeting

-- concerns over whether or not 1


### there really are any feasible energy savings 2


### left given that the previous rule was very 3



### close to max tech. 4


### And as we get into those individual 5



### areas we will examine or will comment on some 6


### of the analysis that pushes up into max tech or 7


### even beyond and we look forward to hearing the 8


### answers to our questions there about how the 9



### anal ysis came to those findings. So we'll get 10



### to that. 11



### But we are concerned that the minor 12


### percentages being pursued in this rule, unlike 13


### some others, are detracting resources, both the 14


### department and in industry, away from rules 15


### that have a larger amount o f savings which we 16


### could be tackling faster, arguably, by focusing 17



### on them first. 18



### But this rule ’ s underway so we're 19


### going to, you know, do it and comment and we 20


### look forward to today's meeting. Thank you. 21


### MR. BROOKMAN: Thank you. Steve? 22

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### 14



### No? Other comments here at the outset? Okay. 1


### Then let's just dive right into the content. 2


### MS. deBUTTS: All right. So the

-- 3


### Doug already went through the agenda and the 4


### presentation overview so right now let's start 5


### with regulatory history. 6



### And this slide re presents the 7


### regulatory history for this rulemaking. As you 8


### can see, the EPCA, Energy Policy and 9


### Conservation Act of 1992, amended the Energy 10


### Policy Act of 1975 and established energy 11



### conservation standards for certain classes of 12



### GSFLs and IRLs. 13



### It also authorized DOE to conduct 14


### two rulemaking cycles to determine whether 15



### these standards should be amended and also 16


### direct the DOE to adopt standards for the 17



### additional GSFLs as warranted. 18


### So DOE completed the first cycle of 19


### review in July of 2009 and that rule amended 20


### the existing standards for GSFLs and IRLs and 21


### adopted standards for additional GSFL types. 22

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### 15



### The standards require compliance

-- required 1


### compliance. It started in July of 2012. 2


### So for the rest of this presentation 3


### we're going to be calling that rule “ 2009 lamps 4



### rule ” and the standards for those rulemakings 5



### as “ July 2012 standards. ” 6


### DOE initiated the second rulemaking 7


### cycle for evaluation of GSFLs and IRL standards 8


### in September of 2011 and we published the 9



### framework document. 10



### We prese nted the framework document 11


### on October 4th of 2011 and now the preliminary 12


### analysis that is the subject of this 13


### presentation is the next stage of the second 14



### review of GSFL and IRL standards. 15



### This is the

-- this slide represents 16



### the schedule for GSFL and IRL rulemaking and as 17


### I mentioned already the framework document 18


### public meeting for presentation was held in 19


### September of 2011. 20


### The notice for the preliminary 21


### analyses was published on February 28th of this 22

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### 16



### year. 1


### What we're projecting next is two 2



### m ajor notices to be published

-- the notice of 3


### proposed rulemaking, or NOPR, which we are 4


### anticipating in March of 2014, and the final 5


### rule, which we're anticipating in November of 6



### 2014. 7



### MR. BROOKMAN: Lucy? 8



### MS. deBUTTS: So that's it? 9



### MR. BROOKMAN: Yes. We have a 10


### question. I'm sorry. 11


### MS. deBUTTS: Sorry. 12



### MR. BROOKMAN: Steve Rosenstock. 13



### MR. ROSENSTOCK: Steve Rosenstock , 14



### EEI. M ore of a comment than a question. I 15


### appreciate the regulatory history but I think 16


### there is missing is the legisla tive history

-- 17



### EPACT 2005 and EISA 2007 which set standards 18


### for fluorescent lamp ballast, certain 19


### incandescent reflector lamps and I believe 20


### certain fluorescent lamps were

-- standards 21


### were set in those pieces of legislation. 22

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### 17



### Again, I'd have to double check. 1


### There's a couple thousand of pages of things 2


### going through my head right now. 3



### Also, the November

-- I think it was 4


### November 2011 final rule on fluorescent lamp 5


### ballast, all of which can have a bearing on the 6


### analysis later on and, you know, I know you're 7


### talking about the regulation but you just can't 8



### -- the legislative history was just as 9


### important in this case for these products. 10


### Thank you. 11



### MR. BROOKMAN: I think this was 12


### meant to be a very short summary. 13


### MS. deBUTTS: Right. 14



### MR. BROOK MAN: Okay. Okay. Thank 15



### you. 16


### MS. deBUTTS: Thanks. Okay. And 17


### the last piece, basically the compliance for 18


### this rulemaking, the compliance date would be 19


### in November of 2017, which is three years from 20


### the publication of the final rule. 21


### Now, while D OE is establishing 22

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### 18



### standards it has to consider seven factors 1


### which are presented on this slide and they also 2



### -- we're also doing the analysis for each 3


### factor and we are going to present our analysis 4


### throughout this meeting. 5


### All right. So now we can go into 6


### the scope of this rulemaking. So DOE defines a 7


### general service fluorescent lamp as any 8


### fluorescent lamp that can satisfy the majority 9


### of fluorescent lighting application. 10


### Currently, standards cover six 11


### fluorescent lamp types shown on this slide w ith 12


### certain wattage ranges. This include 4

- foot 13



### medium bi

- pin base, 2

- foot U

- shaped, 8

- foot 14


### slimline, 8

- foot high output and the 4

- foot 15



### mini bi

- pin standard output and high output 16


### lamps. 17


### In addition to reviewing and 18


### amending standards for the six covere d 19


### fluorescent lamp types, the rulemaking also 20


### considers expanding coverage to additional 21


### fluorescent lamp types and wattages. 22

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### 19



### To make this assessment, DOE 1


### determines whether a lamp that is a candidate 2


### for a standard meets the general technical 3


### descripti on of fluorescent lamp and does not 4


### fall under any exceptions specified in DOE's 5


### definition of the general service fluorescent 6


### lamp. 7



### Then DOE determines whether the 8


### standard for the candidate lamp would result in 9


### significant energy savings and, further, if the 10


### standards would be technologically feasible and 11


### economically justified. 12


### In assessing whether to extend 13


### coverage for additional lamp types, DOE 14


### considered fluorescent shapes not covered such 15


### as circline lamps and also lengths that are not 16



### covered s uch as 5

- foot and 6

- foot lamps. 17



### However, DOE was not able to 18


### identify any additional lamp types that have 19


### market share or energy consumption that could 20


### result in substantial energy savings from those 21



### standards. 22

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### 20



### So DOE is not extending scope of 1



### coverage for additional lamp types. We, 2


### however, decided to consider exclusions of 3



### additional

-- inclusions of additional wattages 4


### for fluorescent lamp types already covered. 5



### DOE determined that certain covered 6


### lamp types are being offered in low wattages. 7



### S pecifically, the 8

- foot slimline is now 8


### offered in 49, 50 and 51 watts. The T5 9


### standard output is in 25 watts and T5 high 10


### output in 44 and 47 watts. 11


### Because those low wattage lamps have 12


### the potential to gain market share, standards 13


### for these lamps may o ffer energy savings. 14


### Therefore, DOE is considering including these 15


### wattages under the scope of coverage. 16


### The new wattage limit under 17


### consideration are shown in green in this table. 18



### We also

-- DOE is also considering 19


### modification to clarify the definiti on of 20


### general service fluorescent lamp as well as 21


### definition that exempt lamps and definition 22

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### 21



### exempt

-- of exempt lamps designed and marketed 1



### for certain non

- general applications. 2


### These definitions include impact 3


### resistant fluorescent lamp, reflectorize d and 4


### aperture lamp, fluorescent lamp design for use 5


### in reprographic equipment, lamps primarily 6


### designed to produce radiation in the 7


### ultraviolet region of the spectrum. 8


### We're also considering to define the 9


### term designed and marketed in similar 10


### terminolog y as it applies to the

-- all 11


### lighting products. 12


### Okay. That's all for the scope for 13



### GSFLs and we can move to IRLs. So DOE is also 14


### considering notification

-- oh, I'm sorry. 15



### Now IRLs are

-- IRLs under the scope 16


### of coverage for this rulemaking must m eet DOE 17



### definition of in candescent reflector lamps 18


### which are specified in this box that you can 19



### see on this slide. 20


### Even though we don't set the upper 21


### limit of wattages, existing IRL standards are 22

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### 22



### set between 40 and 205 watts because anything 1


### greater th an 205 watts are mainly specialty 2


### lamps that comprise a small portion of the 3


### market and probably would not result in 4


### significant energy savings. 5


### We confirmed in our analysis that 6



### this remains the same so therefore we are 7


### keeping the range of wattages f or this 8


### rulemaking between 40 and 205. And that brings 9


### us to the comments on the scope of coverage. 10



### MR. BROOKMAN: I see two comment 11


### boxes there. They list the specific lamp types 12


### they wish

-- the department wishes to receive 13



### comment on both for GSFLs and then GSFL 14


### definitions. But let's start with scope first. 15


### Alex Boesenberg? 16


### MR. BOESENBERG: Regarding issue 17



### one, I wanted to

-- I guess less a comment and 18


### more of a question and more of a clarifying 19



### statement. 20


### While we don't necessarily disagree 21


### with the addition of low wattage lamps, I do 22

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### 23



### want to point out that those often being energy 1


### savers are subject to some performance 2



### restrictions. 3


### As we noted in the 2011 public 4


### meeting, some of these have difficulty 5


### operating in low temperatures and we 'll make a 6


### greater point later on regarding the difference 7



### between 32

- and 28

- watt lamps that the 32 8


### watts, which are

-- I would characterize as 9


### endangered by the TSD

-- are the ones that are 10


### dimmable, and dimming is a performance feature 11


### that is highly de sired and in fact the DOE 12


### claims energy savings based on dimming systems 13



### later. 14


### So we'll give that in greater 15



### detail. And as far as

-- I did want to make a 16



### -- ask a question about IRL, the scope you're 17


### keeping the same as the previous rule. It

-- 18



### bec ause of how recently the 2011 standard or 19



### the 2012 standard went into effect it's 20



### difficult know where the market is. 21


### But I'm curious if Navigant or the 22

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### 24



### labs for the DOE and the analysis noted there's 1



### -- are there any 130

- volt products yet still 2



### availabl e because our fear was they were going 3



### to be eliminated as a result of conformance. 4



### MS. deBUTTS: Aisha? 5


### MS. HUSAIN: No, we didn't find any 6


### 130 volts products that were compliant. 7


### MR. BOESENBERG: All right. Thank 8



### you. 9


### MR. BROOKMAN: Aisha, that' s -- 10


### thank you, Aisha. I wanted to get your name in 11



### the record. Steve Rosenstock. 12



### MR. ROSENSTOCK: Steve Rosenstock , 13



### EEI . I have to say just from personal 14


### experience when I go to the hardware store to 15


### replace an outdoor IRL at my house I did find a 16



### ve ry highly efficient halogen IRL that was 17


### rated 39 watts to replace I believe it was a 18



### 60

- watt I'll say older version non

- IRL, non

-- 19


### less efficient IRL. So, again, I'm not sure in 20


### the marketplace because of the

-- I'll say the 21


### July 2012 standard there cou ld be some things 22

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### 25



### going on at that lower end of the range where

- 1



### - again, just because of personal observation I 2



### did see one that was rated 39 watts so I don't 3



### know if that would be covered or not. 4


### MR. BROOKMAN: Okay. Pekka? 5



### MR. HAKKARAINEN: Pekka H akkarainen 6


### and Lutron. Following to what Alex said a few 7


### minutes ago on dimmable lamps, I would also 8


### like to point out for the record that the full 9


### wattage lamps in both the T8 and T5 categories 10


### are the only ones for which there are dimming 11



### standards in t he industry. So if we get 12


### rid of the full wattage lamps that are argon

13


### filled we also get rid of dimming. 14


### MR. BROOKMAN: Okay. Thank you. 15



### MR. HAKKARAINEN: I have a second 16


### comment on this IRL scope. The

-- I'm a little 17


### bit confused about the scope as it reads right 18



### now. 19


### We have an ongoing rulemaking, I 20


### believe, on residential R , ER and BR lamps that 21


### where the final rule has not been published 22

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### 26



### yet. Is this rulemaking going to affect those 1


### lamps as well? 2


### MS. deBUTTS: No. Unfortunately 3


### right now, due to the appropriations rider DOE 4


### is not allowed to work on any standards that

-- 5


### implementation or enforcement of any 6


### incandescent technology, all those R , ER and B R 7


### lamps. So we are not including those. They 8


### are still in a separate rulemaking. We're just 9



### now allowed to work on it. 10


### MR. HAKKARAINEN: Okay. That wasn't 11


### clear to me in the presentation. That's all. 12


### Okay. Thank you. 13


### MR. BROOKMAN: Okay. Thank you for 14


### the question and thank you for the good 15


### comment. Keith, and then I'm coming to you 16



### next. 17


### MR. K. COOK: I'm still trying to 18


### understand a little bit on the regulatory 19


### implications of this thing because I'm trying 20


### to understand why we're going through this 21


### rulemaking now. 22

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### 27



### The two rulemaking cycles that were 1



### authorized under EP ACT 1992 was there a time 2


### when they would expire? Do those have to be 3


### completed by a certain date? 4



### MR. BROOKMAN: Eric Stas? 5


### MR. STAS: Eric Stas, DOE. I mean, 6


### there were deadlines in the statute. As you 7


### can see, DOE missed those deadlines. But, yo u 8



### know, we're not

-- we haven't

-- that doesn't 9


### absolve us of our obligation to do those 10


### rulemaking s
. 11


### So we completed the first one in 12


### 2009 and trying to follow on a similar schedule 13


### for what there was and we keep this

-- we've 14


### also kept the same lead ti mes. So now we're 15


### progressing with round two of the rulemaking. 16


### MR. K. COOK: Even though round one 17


### never was fully implemented? 18



### MR. STAS: Well, no. You had the 19


### 2009 rule, 2012 implementation date

- 20



### MR. K. COOK: Due to the rare earth 21



### -- but due t o the OHA stay a lot of the 700 22

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### 28



### series is still in the marketplace and so we 1



### never saw the full effect then of the first 2



### round. 3


### MR. STAS: Right. Well, I guess 4


### that should be in your comments, obviously. 5



### MR. K. COOK: It will be. 6



### MR. STAS: And it s hould factor in 7


### the analysis I would

-- 8



### MR. K. COOK: But then if this one 9


### ends up being a no rule that's it then, 10


### correct? I mean, it's only authorized for two 11


### rulemakings, right? 12


### MR. STAS: Well, except the EISA 13



### 2007 added the six

- year look back so now all of 14


### the rules, you know, are looked at at least no 15


### later than six years later. 16


### So we do an ongoing review of 17


### standards and test procedures now

-- test 18


### procedures on the seven

- year cycle. 19


### But the specific authority we're 20


### going with our speci fic mandates first so this 21



### is the (i)( 4 ) rulemaking

-- sixth issue , ‘ 95 22

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### 29



### (i)( 4 ) , so we're completing that. 1


### But Congress at this point probably 2


### doesn't need to keep putting in specific 3


### provisions like that because we're going to be 4



### on a six

- year cycle un less they choose for some 5


### urgent reason to direct us to do something much 6


### faster. But so it's not the end of lamps 7


### rulemakings. 8


### MR. K. COOK: Okay. Thanks. 9


### MS. deBUTTS: And I just wanted to 10



### add that we heard Susan when she was 11


### representing NEMA in t he HID rulemaking one 12


### week ago she wanted us to coordinate the 13


### schedules for this rulemaking with HID so, you 14


### know, we'll try to accommodate this. 15


### MR. BROOKMAN: Thank you. Please 16



### say your name. 17


### MR. MCGARAGHAN: Good morning. It's 18


### Mike McGaraghan wit h Energy Solutions. I'm 19


### here representing the California investor

- owned 20



### utilities. 21


### That's Pacific Gas & Electric, 22

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### 30



### Southern California Edison, San Diego Gas & 1


### Electric and SoCal Gas. I apologize for coming 2


### in a couple minutes late there. 3



### But a cou ple of comments to start 4



### off here. 5


### First, just on the timing, we think 6


### that this is an appropriate time line for this 7


### rulemaking and applaud DOE for pushing forward 8


### with the mandate to complete the second rule. 9


### We commented in the previous

-- at 10



### the framework stage that DOE should wait until 11


### the first lamp rule was in effect before coming 12



### out with the P

- TSD, and DOE did that. 13


### By the time that this rule takes 14


### effect that would be, I think, you showed in 15


### your slide 2018. That's a full six years aft er 16


### the previous rule and we think an appropriate 17



### amount of time. 18


### MS. deBUTTS: '17. The compliance 19



### date is 2017. 20


### MR. MCGARAGHAN: Okay. It sure 21


### looked like 2018 on the slide so maybe was it 22

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### 31



### end of 2017? 1



### MR. BROOKMAN: November 2017. 2



### MS. deBUTTS: Right. 3


### MR. BROOKMAN: Very close to 2018. 4


### MS. deBUTTS: Let's be specific now. 5


### MR. MCGARAGHAN: Yes. Thank you for 6


### clarifying, and then a couple of scope items. 7


### First, on GSFL I have a question on cold 8


### temperature lamps and it's my understanding 9



### t hat in the last rule cold temperature lamps 10


### were given an exemption but I'm not sure if 11


### they were clearly defined. 12


### You mentioned in a slide a page or 13


### two earlier that you're considering a 14


### definition for the term designed and marketed 15



### so I assume that t hat definition might apply to 16


### something like cold temperature. 17


### I would recommend developing a 18


### technical recommendation for cold temperature 19


### lamps. 20



### The next comment I have is on 2

- foot 21


### lamps. It looks like DOE did some assessment 22

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### 32



### of the market and decided that 2

- foot lamps are 1



### not common. 2


### I don't know what your criteria are, 3


### if you came to the conclusion that they are 4


### specialty lamps, but in my experience they're 5



### all over the commercial sector. 6


### I've spent several years working as 7



### a commercia l lighting auditor and they're in 8


### virtually every building you walk into now, at 9


### least in the California buildings that I've 10


### been working in. 11


### So very surprised to find that you 12


### didn't see larger shipments of 2

- foot lamps and 13


### would encourage you to take a closer look at 14


### that lamp category. 15



### MR. BROOKMAN: Is that U

- shaped? 16


### MR. MCGARAGHAN: No. Straight 2

- 17


### foot lamps. 18


### MR. BROOKMAN: Okay. 19


### MR. MCGARAGHAN: Lastly, comment on 20


### IRL definitions and just to follow up on 21



### Steve's comment I don't think hi s observation 22

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### 33



### in the hardware store was unique. 1


### I think there are a lot of products 2



### at 39 watts and I don't think it's a 3



### coincidence. I think it's because the 4



### standards end at 40. 5



### So I would recommend that DOE take a 6


### look at extending that wattage r ange. 7


### MS. deBUTTS: Okay. Thank you. 8


### MR. BROOKMAN: Okay. Steve 9



### Rosenstock? 10



### MR. ROSENSTOCK: Steve Rosenstock. 11



### In terms of the 2

- foot lamps, a lot of those 12



### are in the

-- not the general service. Aren't 13


### they mostly a lot of the task lighting type and 14


### in the furniture type or are you saying in the 15


### general

-- 16



### MR. MCGARAGHAN: Yes. 17



### MR. ROSENSTOCK:

-- saying in the 18


### general ceiling? 19



### MR. MCGARAGHAN: There are a lot of 20



### two

- by

- two fixtures that were previously U

- bins 21



### that are now retrofitted with 2

- foot lamps. 22

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### 34



### Lobbies

- 1



### MR. ROSENSTOCK: Not the 2

- foot U

2



### tubes? 3



### MR. MCGARAGHAN: No. 4


### MR. ROSENSTOCK: The skinny U

- tubes, 5



### 2

- foot straight bi

- pin? Interesting. And 6


### yeah, just I'll follow up. Those 39 watts were 7


### close to the efficacy of the other ones too. 8


### They were replacing the 60

- watt 9


### halogen with a 39 so, you know, the efficiency 10


### went up by 30, 40 percent. 11



### MR. MCGARAGHAN: I think there's a 12


### wide range of efficiency of those 39

- watt 13


### products. 14


### MR. BROOKMAN: And Mike, just 15



### curious

-- your experience is it mostly in 16



### California? 17



### MR. MCGARAGHAN: Yes. 18


### MR. BROOKMAN: I'm wondering about 19


### the rest of the country, just as I'm wondering. 20


### But anyway, following on, did you have a 21



### comment, Joe? 22

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### 35



### MR. HOWLEY: Yes. Joe Howley with 1


### GE, just to sa y that, you know, data was 2


### provided to Navigant when they did this 3


### analysis and it basically showed that the sales 4



### of 2

- foot lamps are substantially less than the 5



### sales of 4

- foot lamps. 6


### So from an overall economic impact, 7


### although they're

-- you know, maybe the 8


### buildings that you happened to be in happened 9



### to have 2

- foot lamps, as a national standard 2

- 10


### foot lamps are not very common and they're not 11



### -- the volume of them is much less frequent 12



### than 4

- foot lamps. 13


### MR. MCGARAGHAN: Okay. 14



### MR. HOWLEY: So we agree with DOE's 15


### assessment on extending. Also, the

-- you 16



### know, the rule

-- the '92 rule

-- started at 40 17


### watts. We think that's appropriate. 18


### We don't feel that there is any 19


### reason to go lower. Quite frankly, lamps that 20



### are under 40 watts aren't using a lot of energy 21


### and that's the whole point of the rule is to

-- 22

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### 36



### is to put in lamps that use less energy. 1



### But we also think it's

-- a 40

- watt 2


### is an appropriate lower limit for IRLs in this 3


### regulation. 4



### MR. BROOKMAN: Andrew deLaski? 5



### MR. deLASK I: Comments

-- Andrew 6


### deLaski from ASAP. Joe, did you say that NEMA 7


### had provided data on the sales of

-- for across 8


### the market including the portion that's 2

- foot 9


### lamps? Maybe I misheard you. 10



### MR. HOWLEY: We

-- yeah. I don't 11


### know that NEMA provided d ata but there was 12



### manufacturers interviews where we discussed 13



### verbal ly proprietary data. 14



### MR. deLASKI: So was that data in 15


### the docket? Does anybody know? 16



### MS. deBUTTS: Aisha? 17


### MS. HUSAIN: So in assessing those

- 18



### - the 2

- foot linear lamps' inclusion

-- we did 19



### take into account manufacturer feedback which 20


### indicated that there wasn't a strong shift 21


### towards these lamps. 22

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### 37



### We also looked at the Lighting 1



### Market Characterization in the 2010 report, 2


### which also was showing that the less than 4

- 3


### foot category didn't have a great market share 4



### as well. 5


### MR. deLASKI: Okay. I know we're 6



### not

-- so just to follow on, we know it's not 7


### great. The question is what is it. So is it 5 8


### percent? Is it 10 percent? 9


### MS. HUSAIN: Yeah, I think it was 10



### around like

- 11



### MR. deLASKI: Because if it's 5 or 12


### 10 percent that's a lot of

-- that's a lot of 13


### watts. So that's kind of where we're coming 14


### down on this is what's the data. I'm hearing 15


### it's not a lot, it's a lot. 16


### You know, so but my view if it's on 17



### the order of even a few percent of commercial 18


### lighting wattage is a lot of watts and it's 19


### something that we should potentially be taking 20



### a look at. 21



### So that would be our

-- our point 22

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### 38



### would be we'd like to see the data. 1


### MR. BROOKMAN: Aisha, can you 2



### comment further? 3



### MS . HUSAIN: I'd have to check. I 4



### do have the LMC data here and I can circle 5



### back. 6



### MR. BROOKMAN: We'll circle back 7



### too. 8


### MR. deLASKI: That would be great. 9


### That would help us to assess sort of the

-- 10


### what's going on here. 11



### MS. HUSAIN: Sure. 12



### MR. deL ASKI: For those of us who 13


### don't have the data, Joe, since some of us are 14



### manufacturers, some of us aren't and we would 15



### like to see the data. 16



### MS. HUSAIN: We would also welcome 17


### any other data that you can provide on this. 18


### MR. deLASKI: Right. So the o ther 19


### question I have on the 40

- watt question is is 20


### that a statutory limit or is that something the 21


### department has authority to go lower than 40 22

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### 39



### watts? Sort of an Eric question, I think. 1



### MS. deBUTTS: I don't think it's 2



### statutory. 3



### MR. STAS: I haven't looked at the 4


### definition lately but unless it's in the 5


### definition and would throw something outside 6


### the particular type of lamp, you know, we've in 7


### the past, if Congress set standards at a 8


### certain wattage level we've said when we do 9


### amendments we can expan d that to some extent or 10


### go into some related types of lamps that they 11


### didn't particularly tackle in the statutory 12



### standard. 13



### So I don't think we're

-- it's not 14



### in the definition where I can see. 15



### MS. deBUTTS: No. 16



### MR. STAS: So then we would have 17



### fl exibility to tackle things. 18


### MR. HOWLEY: Eric, if you look at 19



### this slide

-- I'm reading a slide from a few 20


### slides ago

-- it does have listed here directly 21



### - 22

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### 40



### MR. BROOKMAN: What's the number? 1



### Joe, what's the number? 2



### MR. HOWLEY: Slide 16. 3



### MR. BROOK MAN: Thank you 4



### MR. HOWLEY: Ten CFR 430.2 does have 5



### it in the

-- has listed a statutory definition 6


### of 40 watts and higher. I do believe that was 7


### in the original 1992 law. 8


### MR. BROOKMAN: Thank you for that. 9


### MR. STAS: All right. You're going 10



### to mak e me pull out my statute now. 11


### MR. BROOKMAN: Aisha, were you going 12


### to dig something out? Can you find it there? 13


### MS. HUSAIN: Yeah, I was just going 14


### to say that for the LMC reports .2 percent for 15



### T8s less than 4

- foot of installed stock as well 16



### as the T 12s and that's about one terawatt 17


### energy consumption for the T8s less than 4

- foot 18



### as well as the T12s less than 4

- foot. So those 19


### are the numbers they're reporting. 20


### But, again, if you have other data 21


### at the national level or any other data that 22

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### 41



### would b e helpful. 1


### MR. deLASKI: So just to read

-- 2


### just to repeat it back to you to make sure I 3


### got it right. So you said .2 percent

- 4


### MS. HUSAIN: Installed stock, yeah. 5



### MR. deLASKI:

-- of installed stock 6



### -- 7



### MS. HUSAIN: Yeah. 8



### MR. deLASKI:

-- is two feet or less 9



### than

-- 10



### MS. HUSAIN: Is less than 4

- foot. 11



### MR. deLASKI: It's less than 4

- foot. 12


### MS. HUSAIN: Right. 13


### MR. deLASKI: Okay. 14



### MR. BROOKMAN: And then back to the 15


### statutory question, Eric. 16


### MR. STAS: I may stand corrected 17


### here. Okay. So unless I'm missing

-- so 18


### 629130(c), let's see, has the definition of 19


### incandescent lamp. 20


### It says any lamp commonly referred 21


### to as a reflector lamp which is not colored and 22

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### 42



### is blah, blah, blah. Rated voltage or voltage 1


### range lies at least partially w ithin 115 and 2


### 130 volts, a diameter which is exceeds 2.25 3


### inches and has a rated wattage that is 40 watts 4


### or higher. 5



### MS. deBUTTS: So it's in the 6



### statute. 7



### MR. STAS: So it is in the statute. 8


### MS. deBUTTS: Right. 9



### MR. STAS: So that does stand 10



### correc ted. It wasn't just in DOE's regulations 11



### so it seems like a limit more bound. 12


### MS. deBUTTS: Yeah. Okay. 13


### MR. BROOKMAN: Thank you for that 14


### clarification. Charlie Stephens? 15


### MR. STEPHENS: Charlie Stephens. I 16


### guess if it's in the statute I don't thi nk 17


### anybody's going to be messing with it anytime 18


### soon but it's increasingly less useful as we 19


### shift technologies, and when you have a 20


### standard that's in lumens per watt and you're 21


### trying to deliver a certain number of lumens 22

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### 43



### and as we move toward fewer and fewer watts 1


### that eventually you're going to just hit those 2


### lumens and wattage is not a very good way to 3



### define what's covered. 4


### The whole point is to use fewer and 5


### fewer watts and, you know, eventually you're 6


### going to be getting down into those lower 7



### w attages down into the 20

- watt category to 8



### deliver the same number of lumens that a 60

- 9


### watt lamp used to use. And I mean, that's kind 10


### of the way we're headed. 11


### But so for now you may not be able 12



### to mess with it but I'd

-- you know, some of us 13



### have sort of seen this coming for a long time 14


### now and we're seeing it in the marketplace in 15


### things like street lighting. But so at some 16


### point we may have to do something about this. 17


### MS. deBUTTS: Now it's a legal 18


### question, Eric. 19



### MR. BROOKMAN: Keith? 20



### MR. K. COO K: Keith Cook from 21


### Philips. I'm a little concerned that we're 22

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### 44



### losing sight of the original intent of EPACT 1


### here. The original intent was to get rid of 2


### less efficient lights, period. 3


### It was not to cover every fricking 4


### product that's made. If it's al ready efficient 5


### it was not supposed to be covered. I think 6


### that we've lost sight of that in this whole, 7


### you know, process. 8



### MR. BROOKMAN: I don't think we've 9


### had much comment yet on the IRLs, which is the 10



### second issue

-- no, pardon me. GSFL is issue 11



### tw o -- GSFL definition. So comments on that as 12



### well. 13


### We haven't got

-- we have one 14



### comment on IRLs. Comments on the definition 15



### before we move on? No comments? Joe? 16


### MR. HOWLEY: The proposed changes 17


### look acceptable to industry. 18


### MR. BROOKMAN: Okay . Are you 19


### speaking on behalf of NEMA there? 20


### MR. HOWLEY: Yes, in this case. We 21


### had a discussion on this, yes. 22

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### 45



### MR. BROOKMAN: Thank you. Okay. 1


### We're moving on. 2



### MR. MCGARAGHAN: Doug? 3


### MR. BROOKMAN: Oh, yes. Mike? 4



### MR. MCGARAGHAN: Hi. Mike 5



### M cGaraghan. I had one other question on how 6


### you intend to structure the rulemaking, 7


### following up on Charlie's point that lumens are 8


### a better metric to identify lamp performance 9



### than watts. 10


### Even if the scope remains based on 11


### wattage will DOE consider a lu men - based 12


### standard rather than a wattage

- based standard? 13


### Or is that something we can talk about later? 14



### MS. HUSAIN: This is for IRLs. 15



### MR. BROOKMAN: This is Aisha 16


### speaking. 17


### MS. HUSAIN: This is Aisha. Sorry. 18


### So we're not planning on changing the way or 19



### we aren't

-- in this preliminary analysis we 20


### haven't considered changing the metric. 21



### We did look at

-- I know in the 22

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### 46



### framework we had discussed possibly using an 1


### application

- efficacy

- based metric and just 2



### based on manufacturer feedback and talk ing with 3


### industry we found that there wasn't a lot going 4


### on in developing such a metric and such a 5


### metric would require probably encompassing all 6


### types of directional lamps. 7


### So the scope of it seemed to be 8


### bigger than what we have here and would 9


### require, you know, the inclusion of looking at 10


### LEDs as well and other directional lamps. So 11


### at this time for this analysis we didn't 12



### consider it. 13


### MR. MCGARAGHAN: Okay. Thank you. 14


### My question was slightly different. Whether we 15


### look at lumens per watt or beam lumens per watt 16


### or some other application efficacy, the 17


### question is about whether the standards are 18


### tied to your wattage as a product or whether 19


### they're tied to your lumens in terms of how you 20



### calculate the standard. 21


### And we would recommend following up 22

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### 47



### on Charlie's comment just that we move in the 1



### direction of lumen

- based standards because 2


### lumens are really what's useful to a consumer 3


### and watts is not a useful metric anymore. You 4


### end up with packages that say 55 equals 70 and 5


### that just doesn't make any sense. 6


### So in general as much as possible 7


### the DOE can help shift that discourse to be 8



### lumen

- based instead of wattage

- based and the 9


### standards are one way to help do that. 10



### MS. HUSAIN: So it is the

-- we are 11


### using the power law equation that relates 12



### lum ens and wattage. 13


### But we would welcome any comments on 14


### that when we get into the engineering analysis 15


### if you have other ideas. 16


### MR. BROOKMAN: Thank you, Aisha. 17



### Pekka? 18


### MR. HAKKARAINEN: Pekka Hakkarainen, 19


### Lutron. Mike, I'm not understanding where y ou 20


### are getting at. What problem are you trying to 21



### solve with that? 22

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### 48



### MR. MCGARAGHAN: So just there's a 1


### focus on wattage and what you might see is for 2


### a specific product type manufacturers 3


### accustomed to designing to a wattage because 4



### that's what consumer s are used to. 5


### So you might design to 50 watts 6


### regardless of your

-- the efficiency of your 7


### product. So then you end up with a slew of 8


### products giving more or less light. 9


### MR. HAKKARAINEN: But the efficiency 10


### standards would not allow you to design t o just 11


### any lumen output. 12



### So are you

-- is this a way to 13


### extend the coverage of what products are 14


### covered or is this to help consumers understand 15


### what's going on? 16


### MR. MCGARAGHAN: It's just to help 17


### ensure that as we improve efficiency we're 18


### reducing w attage rather than increasing light. 19



### MR. BROOKMAN: Steve Rosenstock? 20



### MR. ROSENSTOCK: Steve Rosenstock , 21



### EEI . I know for the last I don't know how many 22

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### 49



### years any time a consumer looks at a compact 1


### fluorescent bulb in the store the box is going 2



### to say something like 26 watts equals 100 watts 3


### just so the consumer knows that if they have an 4


### incandescent baseline at home if they replace 5



### it with the 26

- watt, the light output should be 6


### equivalent or even possibly even higher, 7


### depending on the manufacturer an d the 8


### technology used. 9


### I think that it's not, you know, I 10



### think it's

-- and again, it's all about making 11


### sure the consumer understands what they're 12


### getting and, you know, hopefully, you know, 13


### they're looking for a performance and so by 14


### doing

-- showing the watts and also showing the 15


### lumens there, the consumer has an idea of, you 16


### know, what are they getting compared to what 17


### they used to have and, you know, the standard 18


### are in lumens per watt and it is a formula. 19



### So I mean, there are

-- there is a 20



### requ irement for those lamps to be more 21


### efficient on an efficacy basis. I think when 22

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### 50



### you're talking about what's important to 1



### consumers that's

-- you know, I think that 2


### still has to be played out just because we're 3


### in a transition phase for all these products. 4


### And so I think, especially

-- I'll 5


### just say for the incandescents, the boxes that 6


### I've seen, again, in the hardware store say 7



### this 72

- watt halogen bulb is equal to your old 8



### 100

- watt incandescent bulb so people know what 9


### they're getting and they know wh at the 10


### relatively equivalent light output is. 11


### Otherwise, again, whether we like it 12


### or not over the years, over the last, you know, 13


### 100 years most people associate higher watts 14


### with higher lumens and even with the CFLs and 15



### LEDs that's still the case. 16


### MR. BROOKMAN: I think these points 17


### have now been made. We're going to move on. 18


### They've been made. 19


### MS. deBUTTS: Okay. So this slide 20


### shows the preliminary analysis stage and the 21


### analys e s that were done by DOE. At this point, 22

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### 51



### Aisha will present the a nalysis for marketing 1


### and technology assessments and screening 2


### analysis. 3


### MS. HUSAIN: Hi. My name is Aisha 4


### Husain. I'm with Navigant. So we will first 5


### discuss the market and technology and screening 6


### analyses. 7


### The purpose of the market and 8



### technolo gy assessment is to determine product 9


### classes and identify technology options that 10


### improve lamp efficacy. 11


### Technology options are identified

-- 12


### are then evaluated against four criteria, which 13


### are that the option is technologically 14


### feasible, that it is pra ctical to manufacture, 15


### install and service on a commercial scale by 16


### the compliance date of the standards, that it 17


### doesn't have any adverse impacts on utility to 18


### the consumer or availability and it doesn't 19


### have any adverse impacts on health or safety. 20



### Tho se technology options not 21


### screened out are analyzed as design options in 22

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### 52



### the engineering analysis. 1


### For product classes, DOE divides 2


### covered products into classes by type of energy 3


### used, capacity of the product or any other 4


### performance

- related features th at might impact 5


### consumer utility. 6


### A separate standard is then set for 7


### each of these categories of products. DOE is 8


### considering maintaining the same product class 9


### divisions established in the 2009 lamps rule. 10


### For GSFLs three product class 11


### setting fact ors are being considered. DOE is 12


### considering establishing a product class based 13


### on correlated color temperature, or CCT. 14


### CCT is a measure of perceived color 15



### of white light and therefore different CCTs can 16


### have different utilities for consumers. Also, 17


### because the spectral emission of the lamp is 18


### modified to change CCT, the lamp efficacy also 19


### changes. 20


### DOE has specifically observed that 21


### there's a decline in efficacy in lamps with 22

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### 53



### CCTs greater than 4,500 K and therefore is 1


### considering establishing a sep arate product 2


### class for lamps with CCTs less than or equal to 3


### 4,500 K and those greater than 4,500 K. 4


### DOE is also considering product 5


### classes based on physical constraints. 6


### Consumer utility may be impacted when consumers 7


### have to change, for example, the ceiling design 8


### or architecture in order to substitute lamps 9


### with different geometries. 10


### Additionally, lamp length impacts 11


### efficacy. The 8

- foot linear lamps are 12


### generally more efficacious than the 4

- foot 13


### linear lamps. 14


### Shape is also a factor. The 2

- f oot 15



### U

- shaped lamps are less efficacious than the 4

- 16


### foot linear lamps even though they are 4

- feet 17


### when straightened out. Therefore, DOE is 18


### considering establishing product classes based 19


### on lamp length and shape. 20


### DOE is also considering lumen 21


### package as a class setting factor. Lumen 22

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### 54



### package of fluorescent lamps is

-- which is the 1


### quantity of light produced by the lamp and 2


### ballast system

-- provides different utilities 3



### to consumers. 4


### High lumen outputs are

-- tend to be 5


### used in high ceiling applications or outdoors 6


### and, further, a high lumen package is run at 7


### higher currents, which results in a decrease in 8


### efficacy. 9


### Therefore, DOE is considering 10


### establishing separate product classes for 11


### standard output and high output lamps. 12


### So this table presents the resulting 13


### 12 product class divisions DOE is considering 14


### for GSFLs. As you will note, these are the 15


### same product classes established in the 2009 16


### lamps rule. 17



### MR. BROOKMAN: Steve Rosenstock? 18



### MR. ROSENSTOCK: Steve Rosenstock , 19



### EEI

. O n that last one about the high lumen 20


### package in terms of designing to run with 21


### ballast at high currents, did the November 2011 22

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### 55



### rule change that? Did those ballasts also 1


### increase in efficacy as well as part of the 2



### November 2011 rule? 3



### MS. HUSAIN: The ballast rule? 4



### MR . ROSENSTOCK: Yes. 5


### MS. HUSAIN: I'm not sure. Maybe 6



### Maureen can answer that. 7



### MS. KIENLE: Yes. The standards 8



### increased for that 2011 rule. 9


### MR. ROSENSTOCK: Thank you. 10


### MR. BROOKMAN: Say your name again. 11



### MS. KIENLE: Maureen Kienle. 12



### MR. BROO KMAN: Maureen, leave that 13


### thing on. 14


### MS. KIENLE: Okay. 15


### MR. BROOKMAN: Thank you. Alex? 16


### MR. BOESENBERG: Alex Boesenberg, 17


### NEMA. I had a similar question. So let me ask 18


### the same question in a different way, I think. 19

20



### Is that

-- is for the lumen package 21


### and related analysis, did the DOE use 2011 rule 22

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### 56



### conforming ballast s for their analysis? 1



### MS. KIENLE: Yes. 2


### MR. BOESENBERG: Okay. That's

-- 3


### thank you. 4


### MR. BROOKMAN: Thank you. 5


### MS. HUSAIN: So for IRLs, DOE is 6


### also considering three produ ct

-- three product 7


### class setting factors. 8



### Let's see

-- DOE is considering 9


### spectrum as a class setting factor. Modified 10


### spectrum lamps provide a different type of 11


### utility for consumers and they also change the 12


### spectrum because they absorb a portion of the 13


### visible light. 14


### So DOE is considering establishing a 15


### separate product class for modified spectrums 16


### and standard spectrum lamps. 17


### DOE is also considering a product 18


### class setting factor as diameter. Small 19


### diameter lamps provide a different utility for 20


### consumers because they can be installed in 21



### smaller fixtures. 22

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### 57



### They also have an inherently lower 1


### optical efficiency than larger diameter lamps 2


### and they

-- and they cannot utilize the same 3


### technology options as larger diameter lamps 4



### such as the doubl e - ended capsule. 5


### So DOE is considering establishing 6


### separate product classes for lamps with a 7


### diameter of 2.5 inches or less and lamps with a 8


### diameter greater than 2.5 inches. 9


### So DOE is also considering voltage 10


### as a class setting factor. DOE has fou nd that 11


### most consumers operate 130

- volt IRLs at 120, 12


### which reduces efficacy while increasing 13



### lifetime. 14


### However, existing DOE test 15


### procedures require lamps rated at 130 volts to 16


### be tested at 130, and similarly, lamps rated at 17



### 120 to be tested at 120. 18


### Therefore, compared to a 120

- volt 19


### lamp, a 130

- volt lamp will test at a higher 20


### efficacy. 21


### So when technologies

-- so when you 22

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### 58



### have a single efficacy level for all voltages, 1



### the 130

- volt lamp would not require as 2



### e fficient technologies to meet the standar d as 3



### a 120

- volt lamp. 4



### The need for less efficient 5


### technologies could make the 130

- volt lamp less 6


### costly to produce and cheaper to buy. This 7


### could potentially result in a migration to 130

- 8


### volt lamps. 9


### Further these lamps are partially 10


### dimmed when oper ated at 120 volts and therefore 11


### to meet their light output consumers could 12


### purchase higher wattage 130

- volt lamps or even 13



### more than one. 14



### This could result in an increase in 15


### energy consumption. Therefore, DOE is 16


### considering separate product class divisio ns 17


### based on lamps with a rate d voltage less than 18



### 125 volts and rate d voltage greater than 125 19



### volts. 20



### MR. BROOKMAN: Steve Rosenstock? 21



### MR. ROSENSTOCK: Steve Rosenstock , 22

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### 59



### EEI

. A couple of quick comments. When you say 1


### a large number of consumers, what do you mean 2


### by that? 3



### What are

-- what do you say is 4


### large? Is this 50 percent? Eighty percent of 5


### customers? Residential, commercial 50 percent? 6



### Twenty percent? 7



### MS. HUSAIN: I don't think we have a 8


### specific percentage but generally we got the 9


### impr ession that most consumers are operating 10



### them at 120 volts. 11



### MR. ROSENSTOCK: Well, I understand 12


### that, yeah. But that's the voltage that 13


### they're getting in their house or their 14


### business. Yes, they are operating 120

- volt. 15



### But you say

-- yeah, I would say 16


### it's close to probably 100 percent. But, 17


### again, it's a matter of

-- the issue is what 18


### percentage of

-- I was really getting at what 19


### percentage of the market or sales is 130

- volt 20


### lamps. 21



### MS. HUSAIN: So as we stated 22

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### 60



### previously, we didn't find a lot of 130

-- we 1


### didn't find any compliant 130

- volt products. 2


### The manufacturers can also maybe weigh in on 3



### the market share. 4



### MR. ROSENSTOCK: Well, I have a 5


### couple other follow

- up comments. 6



### MR. BROOKMAN: Let's hear from the 7


### manufacturers. Joe, do you want to start? 8



### MR. HOWLEY: The

-- well, a few 9


### points. One is that the efficiency of a 130

- 10


### volt as you go higher in voltage, the 11


### efficiency actually decreases. It doesn't 12



### increase. 13


### We believe this was misanalyzed in 14


### the first rulemaking, the 2009 lamps rule, 15


### which led to an extremely high efficiency being 16


### set on them which led to the fact that today 17


### you don't see any 130

- volt lamps in the market. 18

19


### They've essentially been regulated 20


### out of the marketplace by the somewhat 21


### misanalysis, let's say, in the 2009 rule, which 22

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### 61



### produced a higher standard for lamps which are 1



### less efficient at 130 volts. 2


### And that's why we have the market 3


### condition we have today, which is since July 4


### 2012, these products essentially no longer are 5



### manufactured. 6



### MR. BROOKMAN: Oka y. Steve? 7


### MR. ROSENSTOCK: Thank you. I 8


### really appreciate that. I guess a couple of 9


### other thoughts is I recall after my going to 10


### the lighting school is that the 130

- volt lamps 11


### operating at 120 volts, that the lifetime is 12


### increased by approximately 2.9 times. 13


### So if a standard lamp was 1,000 14



### hours that the 130

- volt on a 120

- volt system 15


### would last about 2,900 hours, that give or 16



### take. 17


### I think that was the ratio, again, 18


### based on what I had seen, again, for

-- a 19


### little less? Okay. Let's say 2,500, two and a 20



### half times. Does DOE consider that a bad 21


### thing? 22

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### 62



### MS. HUSAIN: No, DOE doesn't 1


### consider that a bad thing. 2


### MR. ROSENSTOCK: Okay. I'm just 3



### kind of curious because

-- 4


### MS. HUSAIN: That was incorporated 5


### when we were determining the scaling f actor. 6


### MR. ROSENSTOCK: Okay. And when you 7


### say, you know, again, reduced efficacy probably 8


### before or after, again, just thinking with a 9


### lot of these lamps on dimmers it's even

-- 10


### again, there was a reason for people putting in 11


### these lamps and, again, fo r some areas that 12


### they

-- sometimes the voltage was higher than 13


### 120 volts and they worried about, you know, 14


### sometimes lamps blowing out. 15


### If they put 130 volts give a little 16


### bit of a safety factor. Now they've been 17


### regulated out, the consumers have los t that 18


### utility. 19



### So I think

-- and again, I know 20



### there's an anti

- backsliding rule but, again, 21



### there's been

-- for those consumers it's been a 22

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### 63



### loss of utility and if they've had to switch 1


### from 130 to 120 volts guess what? Their number 2


### of lamps they've h ad to buy has increased. 3


### MR. BROOKMAN: Alex, do you want to 4


### comment here? Okay. 5


### MR. deLASKI: I just have a data 6


### question, which is, Joe, what was the

-- what 7


### were the sales of these lamps prior to the 2009 8


### rule going into effect? 9



### MR. HOWLEY: I do n't know the exact 10


### number but I think industry sold quite a few of 11



### them. But I don't know what the number is. 12


### MR. deLASKI: Was it 50 percent of 13


### the market or 1 percent of the market? 14


### MR. HOWLEY: It wasn't that high. 15


### MR. deLASKI: Was it 1 percent? 16


### MR. HOWLEY: It was higher than 1 17


### percent. Somewhere between 1 and 50 percent 18



### but I don't know what

- 19


### MR. deLASKI: Joe, your precision 20



### astounds me. 21


### (Laughter.) 22

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### 64



### MR. BROOKMAN: Does that data exist? 1



### MR. deLASKI: Does NEMA

- 2



### MR. BOESENBERG: W ell

-- Alex 3


### Boesenberg, NEMA

-- that would have been part 4


### of the previous rule since our strong 5


### inclination is to say there are no more 6


### products available. So we don't have a new

-- 7


### MR. deLASKI: Yeah, but we're trying 8



### -- so what Joe is describing for u s is an 9


### unintended consequence of the rules. We're 10


### trying to understand

- 11


### MR. BOESENBERG: Right. 12



### MR. deLASKI:

-- what the breadth of 13


### that impact is and, you know

-- 14


### MR. BOESENBERG: Well, perhaps since 15


### there was a previous rule perhaps Navigant h ave 16


### that data resident. They can dig it out. I 17



### don't have it with me. 18


### MR. deLASKI: Okay. 19


### MR. BROOKMAN: Lucy deButts? 20



### MS. deBUTTS: There's also data 21



### available in the docket which is online. So if 22

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### 65



### you'd like to visit the docket for the previous 1



### r uling you can do so as well. 2


### MR. BROOKMAN: Do you think the data 3



### is there? 4


### MS. deBUTTS: Well, whatever is 5


### included in the docket is there. But, Aisha? 6



### MS. HUSAIN: I'm not sure if that 7


### specific data would be there but you can check. 8



### MR. deLASKI: I mean, you guys know 9



### -- Keith, Susan, Joe. You've got some better 10



### sense of

- 11



### MR. HOWLEY: Individual 12



### manufacturers know but I do not believe NEMA 13


### captures that

-- 14


### MR. deLASKI: Okay. 15



### MR. HOWLEY:

-- particular product 16


### as a market segment. So th e industry doesn't 17


### have any data and I don't believe any data from 18


### the industry was provided on that. 19


### MR. deLASKI: Okay. 20



### MR. HOWLEY: Individual 21



### manufacturers knew what their sales were 22

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### 66



### previously and there were manufacturer 1



### interviews where that was somewhat discussed 2


### but some of that information was proprietary. 3


### So I'm not sure if they'll

-- 4


### MR. deLASKI: So it wasn't rolled up 5


### by NEMA into data submitted by the department? 6



### MR. HOWLEY: I don't believe it was. 7


### MR. deLASKI: Okay. All right. 8



### Thanks. 9



### MR. BROOKMAN: Mike? 10


### MR. MCGARAGHAN: Mike McGaraghan. I 11


### just want to clarify. Steve, you mentioned 12


### that there might be a utility that was taken 13



### from the consumers. 14


### I think my assumption and I think 15


### everyone would agree is that the overw helming 16


### majority of those lamps, maybe even 100 17


### percent, which I think you said, were used at 18



### 120 volts. 19


### The real utility that they provided 20


### was that they were long

- life lamps. So maybe 21


### there's data on exactly how many people use 22

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### 67



### them because of volta ge spikes. 1


### That would be great to see. But 2


### assuming their primary utility was long life, 3


### that utility has not been eliminated from the 4


### market. There are still lots of long

- life 5


### lamps on the market. 6


### MR. BOESENBERG: Alex Boesenberg, 7


### NEMA. I was goi ng to comment that the feedback 8


### I have received, you know, when I get a phone 9


### call from somebody it's about voltage spikes. 10


### They put in a 130

- volt because it's more 11



### survivable. 12



### The lifetime

-- what they want to do 13



### is have it not burn out all the time. The 14



### added lifetime is a

-- that's gravy. 15



### The fact that it survives at all was 16


### the sales point, the purchase point, whatever 17


### you want to call it. 18


### MR. BROOKMAN: Is there anything

-- 19



### where are we at this moment? 20


### MS. HUSAIN: We're summarizing the 21



### I RL product class division. 22

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### 68



### MR. BROOKMAN: Okay. So keep going. 1


### MS. HUSAIN: So this table presents 2


### the resulting eight product class divisions 3


### being considered for IRLs. As noted, these are 4


### the same as those for establishing the 2009 5


### lamps rule. 6



### DO E requests comments on the product 7


### classes that it is considering for GSFLs and 8



### IRLs. 9


### MR. BROOKMAN: Comments on product 10



### classes? No comments here. Steve Rosenstock? 11



### MR. ROSENSTOCK: Steve Rosenstock , 12



### EEI . I guess the issue is if the regulations 13


### have pretty much eliminated the production of 14



### 125

- volt

-- 130

- volt IRLs, I'm not sure what 15


### more analysis gets you. 16


### MR. BROOKMAN: Okay. Thank you. No 17


### additional comments. We're moving on. Okay. 18


### MS. HUSAIN: Okay. Now we will move 19



### on to a discussio n of technology options. DOE 20


### has identified the following technology options 21


### that can improve GSFL efficacy. 22

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### 69



### These technology options include 1


### such technologies as high efficiency phosphors 2



### which increase conversion of UV to visible 3


### light, glass coatin gs which help phosphors 4


### absorb more UV light and high efficiency 5



### diameters. 6


### For IRLs, DOE identified the 7


### following technology options that can improve 8


### IRL efficacy. These include technologies 9


### related to the filaments such as coiling, 10


### placement and orien tation

-- also the use of 11


### high efficiency fill gases , as well as 12


### coatings, such as infrared glass coatings that 13


### are used to reflect radiant energy back onto 14



### the filaments. 15


### DOE requests comments on the 16


### technology options being considered for GSFLs 17



### and IRL s. 18


### For GSFLs in particular, DOE would 19


### like feedback on whether high efficiency 20


### diameters should be retained as a technology 21


### option in light of a possible market shift away 22

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### 70



### from less efficient diameters. 1



### MR. BROOKMAN: Alex? 2



### MR. BOESENBERG: Alex Bo esenberg, 3


### NEMA. If you'd bear with me a second I'm 4


### trying to find the comment here. Well, it's

-- 5


### we had it in the wrong spot and I don't 6


### remember where I put it. 7


### Perhaps one of my members can chime 8


### in. Regarding technology options, one thing 9



### that we didn't agree with was glass coatings 10



### and that those shouldn't be included. And does 11


### anybody remember the other one? 12



### MR. BROOKMAN: Keith? 13


### MR. K. COOK: Keith Cook, Philips. 14


### We did not understand what you meant by 15


### optimizing diameters. We couldn't fi gure that 16



### one out to save us. 17


### MS. HUSAIN: The high efficiency 18



### diameters for

- 19


### MR. K. COOK: Yeah. Could you 20


### clarify that one for us, please? 21


### MS. HUSAIN: So we're talking about 22

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### 71



### when you're able to

-- for small diameter lamps 1



### increase the diameter a nd increase efficacy 2


### that way. 3


### Now, there is a limit when in large 4


### diameter lamps you wouldn't want to increase 5


### the diameters too much. So there's an optimal 6


### sort of range of a larger diameter that you 7


### could achieve that would improve efficacy. 8



### MR. HOWLEY: Are you referring to 9


### GSFLs here or IRLs? Which technology? 10



### MS. HUSAIN: This would be GSFLs. 11


### MR. HOWLEY: Okay. So with GSFLs 12


### the reason it doesn't make any sense to us is 13


### T12s, which are mostly being eliminated by the 14


### 2009 rule, have actual ly a less efficient 15



### diameter. 16


### You said you're shifting towards 17



### less efficient diameters but indeed it's the 18


### opposite of that. We're shifting towards more 19



### efficient diameters. 20


### The T5 to T8 range is the most 21


### efficient diameter range for fluorescent 22

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### 72



### technology which is why the industry has 1


### gravitated to those diameters around the world. 2


### It does produce the highest efficiency. 3


### So this is why this comment doesn't 4



### make a lot of sense to us because where we've 5


### gone is to the most efficient diameters for 6


### fluorescent technology. 7


### MS. HUSAIN: Right. So we were 8


### asking that

-- so the trend you're describing 9


### is the shift away from the less efficient 10



### diameters. 11


### MR. HOWLEY: Right. 12



### MS. HUSAIN: And if that is 13


### happening and all the diameters that are on the 14


### market right now are of optimal efficiency then 15


### we wouldn't consider this as a technology 16


### option. 17


### So that's what we were trying to 18


### assess. If all the products have this in the

- 19



### - if all the products have this characteristic 20


### then there's, like, no r oom for using diameters 21


### as a means for improving efficacy. 22

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### 73



### MR. HOWLEY: That's correct. 1



### MR. BROOKMAN: That's correct. 2



### MS. HUSAIN: That's all we were 3


### trying to ask. 4


### MR. HOWLEY: Okay. Good. 5


### MR. BOESENBERG: Alex Boesenberg. 6


### So industry feels t hat T5 and T8 are highly 7


### efficient optimized diameters and what we 8


### specifically were worried or want to state is 9


### that we can assure you is not the case, a T4 or 10


### a T7 is not the way to go. 11



### MR. BROOKMAN: Pekka? 12



### MR. HAKKARAINEN: My comment

-- 13



### Pekka Hakk arainen in Lutron

-- my comment is 14


### about the higher efficiency fill gas 15



### conversation

-- again, very similar to what we 16


### already discussed before. 17


### If you mean fill gases that include, 18


### say, krypton you will find that those lamps are 19


### going to be unsatisfact ory under dimming 20



### conditions. 21


### So I caution against going in that 22

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### 74



### direction because the savings that the 1


### technical support document attributes to 2


### operation under dimming systems will be lost 3


### and I think appendix whatever number it was 4



### indicated that the actual energy savings from 5


### those systems are 33 percent. We can argue 6



### whether that's the number or not. 7


### But I generally agree that that's 8


### the sort of actual energy savings that you are 9


### going to get as opposed to these on

- paper 10


### energy savings that we are talking about here 11


### with regard to increased lamp efficacy. 12



### MR. BROOKMAN: Alex? 13


### MR. BOESENBERG: Alex Boesenberg, 14


### NEMA. I have two other points to raise 15


### regarding technology options. Listed on that 16


### is integral transformer low

- voltage halogen IR 17



### a nd we disagree that that is suitable. 18


### That is not a viable technology for 19


### higher wattages. So in terms of Navigant 20


### terminology that's not scalable. So it's a 21


### niche product. 22

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### 75



### It works well at what it does. It's 1


### not a good option to apply across th e board. 2


### And another note is we disagree that high 3


### efficiency or filament placement is a big deal 4


### for improving efficacy or efficiency. 5


### The filament placement is where it 6


### is, you know, largely because of the beam 7


### spread you're trying to achieve. 8



### T hat's one of those, you know, as 9


### listed in EPCA and already mentioned there on 10


### Slide 20 that's a performance characteristic. 11



### You want the beam to be thrown a 12


### certain way. So where you place filament is 13


### directly

-- affects that. So could it be a 14



### little more efficient if you rammed it down 15


### farther in the case? I don't know, but you 16


### won't get the same beam spread. That's the 17


### whole point. So you're

-- when you push on one 18


### your raise the other and down, vice versa. 19


### So we disagree that that being a 20



### tech nology option for increasing efficiency. 21



### It's there for a reason. 22

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### 76



### MR. BROOKMAN: Mike? 1


### MR. MCGARAGHAN: Mike McGaraghan. 2


### MR. BROOKMAN: Hey, Mike, we have a 3


### comment from Navigant. 4


### MS. PIERCE: Sorry. Julie Pierce, 5


### Navigant. For the integrally b allasted low 6


### voltage lamps what wattage ranges did those not 7



### work on? 8


### MR. BOESENBERG: Good question. All 9


### I know is we disagree that it shouldn't go up. 10


### Anybody make one here? 11



### MR. BROOKMAN: Yes. 12


### MR. BOESENBERG: I can relay that in 13


### our public comments

-- written comments. 14


### MS. PIERCE: Okay. Thank you. 15



### MR. BROOKMAN: And then Eric has a 16


### question. 17


### MR. STAS: Early you mentioned that 18


### you disfavored the use of glass coatings. Can 19


### you explain why, briefly? 20


### MR. BOESENBERG: I will also ampl ify 21


### on that in our public comments. 22

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### 77



### MR. BROOKMAN: Okay. Mike? 1



### MR. MCGARAGHAN: No comment. 2


### MR. BROOKMAN: Okay. I can circle 3


### back if we need to. We're moving on. 4


### MS. HUSAIN: Okay. I think we 5



### covered all the comments here. So now I'll 6



### move in to screening analysis. 7


### For the screening analysis, DOE 8


### reviewed the technology options identified and 9


### assessed them based on the four screening 10



### criteria to determine which ones should be 11


### considered as design options in the engineering 12


### analysis. 13



### Of the technology options identified 14


### for improving GSFL efficacy, DOE determined 15



### that multi

- photon phosphors should be screened 16


### out. Since this technology remains in the 17


### research phase, DOE determined that it is not 18


### technologically feasible. 19



### Of the technol ogy options identified 20


### for improving IRL efficacy, DOE determined that 21



### those shown in red here should be screened out. 22

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### 78

1


### The majority of these technology 2


### options were screened out because they were not 3


### found in commercially available lamps and 4



### therefore could not be determined to be 5


### practical to manufacture on a commercial scale. 6

7


### Some of the options were also not 8


### technologically feasible and a few had an 9


### adverse impact on product utility. 10


### DOE requests comments on the 11


### technology options eliminated du ring the 12


### screening analysis. 13



### MR. BROOKMAN: Alex? 14


### MR. BOESENBERG: Alex Boesenberg, 15



### NEMA. I'll add a comment on the reference to 16


### high efficiency fill gases and such like that 17


### and will expand on this in our public comments. 18

19


### But relative to my earli er comment 20


### about driving to the

-- increasing the use of 21


### low wattage lamps and the trade

- off for 22

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### 79



### utilities, which is cold temperature, 1


### striation, dimmability and things like that, 2


### that's one of those things that we

-- when you 3


### drive up the krypton in a lam p to increase its 4


### efficiency but krypton doesn't want to dim. 5


### So that's a performance 6


### characteristic, both the dimmability and the 7


### flicker instability, striations and things like 8



### that. 9



### So that's another trade

- off that we 10


### encourage Navigant to explo re and make sure you 11


### get the balance right. 12



### MR. BROOKMAN: Steve Rosenstock? 13


### MR. ROSENSTOCK: One thing to follow 14


### up on that issue is I'm involved with building 15


### codes with ASHRAE and IECC and in many

-- most 16



### of the more recent iterations there was a 17



### re quirement for more and more lighting controls 18


### to provide maximum energy savings and maximum 19


### flexibility for the occupants. 20


### So especially when talking about 21


### dimmability that's a very big issue especially 22

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### 80



### when it comes to build newer buildings or 1


### totally r enovated buildings because there is a 2


### requirement for pretty much lighting controls 3


### everywhere in those commercial buildings under 4


### the new codes. Thank you. 5


### MR. BROOKMAN: Interesting. Alex? 6


### MR. BOESENBERG: Alex Boesenberg, 7



### NEMA. I have one other t hat I forgot and, 8


### again, I'll expand on this in our public

-- in 9


### our written comments. This is our public 10



### comment. 11


### In our written comment, we'll expand 12



### on the issue in IRLs for xenon. That is 13


### another efficiency

- boosting fill gas, high 14


### efficiency fill gas that was on that list. 15


### Xenon is, we believe, sort of an 16


### endangered species in terms of gases. Its 17


### availability is decreasing. 18


### Therefore, if the rule pushes 19


### efficiency up to require the use of xenon we're 20


### going to increase the use of it, drive up 21


### price, reduce availability. 22

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### 81



### And as a corollary I would point out 1


### that the, as was already mentioned, the current 2



### rule all over the OHA waivers for rare earth 3


### element phosp h ors, the T700 series lamps, 4


### that's the exact same sort of a thing

-- 5



### availab ility versus demand. 6


### Rule drives up demand and if the 7


### availability is going down price goes up and 8


### that is a factor for the cost analysis, et 9


### cetera. Thank you. 10


### MR. BROOKMAN: Okay. Thank you. 11


### Additional comments? Technology options 12



### eliminated d uring the screening analysis

-- 13



### the lists are there on 33 and 34. Mike? 14


### MR. MCGARAGHAN: Mike McGaraghan. 15


### On efficient filament placement, which is what 16


### Alex commented on a minute ago, I wonder if 17


### that is referring to the placement of the 18



### filament in an infrared glass capsule. 19


### I understand that the placement of 20


### that filament does impact the amount of 21



### reflected radiation that hits the filament and 22

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### 82



### would then in turn impact the amount of light, 1


### so maybe that's what DOE is going after with 2



### that. 3



### MR. HOWLEY: This is Joe from GE. I 4


### think our response to that is that the 5



### filaments are

-- do have to be optimized. 6


### They do have to be placed at the 7


### exact center of those IR capsules and they are 8


### optimized already, and the whole point of those 9


### products is to optimize them for maximum 10


### efficiency. 11


### But it certainly is a technology 12



### consideration but

-- we agree with that but we 13


### would state that yes, it's a consideration that 14


### has already been optimized within our products. 15



### MR. BROOKMAN: Keith? 16



### MR. K. C OOK: Keith Cook from 17


### Philips. Elaborating a little bit on what Joe 18


### was saying, today that is very, very precisely 19


### controlled, that filament placement. 20


### If DOE knows of a better way of 21


### doing it, we would love to be made aware of it. 22

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### 83



### We don't know how to do it any better, 1


### honestly. It's been thoroughly studied. 2


### MR. BROOKMAN: Okay. Thanks. Joe, 3


### do you have anything additional? Nothing. 4


### Okay. 5


### MS. HUSAIN: Just to follow up on 6


### that. So would you say that that filament is 7


### placed optimally in every lamp as a matter of 8


### just process? 9



### MR. K. COOK: Of course not. There 10


### is manufacturing variation. There's no way to 11


### get around that. 12


### MR. HOWLEY: I would say as a design 13



### -- as a design, yes. It's designed to be 14


### placed optimally. 15


### MS. HUSAIN: Okay. Okay. 16


### MR. BROOKMAN: Okay. That's useful. 17


### Thank you. 18


### MS. HUSAIN: So now I'll be turning 19


### it over to my colleague, Maureen Kienle, who 20


### will discuss the engineering analysis. 21


### MS. KIENLE: Good morning. My name 22

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### 84



### is Maureen Kienle and I'm with Navig ant. We're 1


### going to get started now with the engineering 2


### analysis. 3


### DOE used the following general 4


### methodology to develop the engineering for 5


### GSFLs and IRLs. Of the product classes 6


### identified, DOE first selected certain 7


### representative product classes to analyze. 8


### DOE then selected baseline lamps for 9


### each representative product class to use as 10


### reference points. 11


### After that, for each baseline lamp, 12



### DOE identified more efficacious substitutes 13


### based on design options identified in the 14


### screening analysis. 15


### DOE then developed candidate 16


### standard levels, or CSLs, that span the range 17


### of efficacy from baseline to the maximum 18


### technologically feasible level. 19


### Finally, DOE scaled its results to 20


### the product classes not analyzed. We are first 21


### going to cover the GSFL engineering analysis. 22

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### 85



### We will discuss the request for comment 1


### pertaining to GSFLs during this time. 2


### The request for comment regarding 3


### IRLs will be discussed during the portion of 4


### the presentation that covers the IRL 5


### engineering analysis. 6



### So as s tated earlier, DOE is 7


### considering standards for 12 product classes 8


### for GSFLs. From this list, DOE plans to focus 9


### its analytical efforts on the product classes 10


### highlighted in the darker green shade here. 11


### DOE directly analyzed all product 12



### classes with CCT s less than or equal to 4,500 K 13


### with the exception of the 2

- foot U

- shaped 14


### product class. 15


### These representative product classes 16


### were primarily chosen on the basis of high 17


### market volume. DOE requests comment on the 18


### representative classes for GSFLs. 19



### MR. B ROOKMAN: Alex? 20


### MR. BOESENBERG: Alex Boesenberg, 21


### NEMA. Just a question. We're confused as to 22

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### 86



### why the recently implemented previous rule 1



### doesn't

-- hasn't the baseline for all products 2


### since it was just put through all products have 3



### to meet that minimu m. Why isn't that the 4



### baseline? 5


### MS. KIENLE: So we're actually going 6



### to cover baselines a little bit later. But if 7


### we can defer just for a few minutes before we 8


### get there. 9


### MR. BOESENBERG: Okay. 10


### MS. KIENLE: If that's okay with 11



### you. Great. 12



### MR. B ROOKMAN: Okay. Steve 13



### Rosenstock? 14



### MR. ROSENSTOCK: Steve Rosenstock. 15


### I'm just kind of curious. Since you're looking 16


### at a separate standard for 2

- foot U

- shaped then 17


### there is a decent, you know

-- it might not be 18


### as high volume as a 4

- foot medium bi

- pin . Why 19



### wasn't it

-- isn't it going to be used as a 20


### part of the analysis? 21


### MS. KIENLE: It was on the basis of, 22

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### 87



### I guess, the market share like we said so

- 1



### MR. ROSENSTOCK: I understand that 2


### but since you're doing a separate product, 3


### you're doing a separ ate efficiency standard, 4


### and there are a significant number of

-- you 5


### know, it's not as high as a 4

- foot. 6


### I'm still a little bit puzzled just 7


### because I'm thinking that the 2

- foot U

- tubes 8



### have as much of in terms of sales and in terms 9



### of market data as s ome of the other products on 10



### this list. 11



### MS. HUSAIN: So we didn't

-- 12


### MR. BROOKMAN: Aisha, say your name. 13



### MS. HUSAIN: So I think what Maureen 14


### was trying to say was for representative 15


### product classes we choose product classes based 16



### on the market sha re and for the 2

- foot U

- shapes 17


### we didn't find a high market share, and based 18



### on manufacturer feedback we also confirmed 19



### that. 20


### But if anyone has any input on that 21


### at this point. So we wouldn't directly analyze 22

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### 88



### the 2

- foot U

- shaped unless the market shar e 1


### increased greatly or we found that to be true. 2



### MR. BROOKMAN: Steve? 3



### MR. ROSENSTOCK: Steve Rosenstock. 4



### I understand that but I think in this case 5


### since you are giving a separate efficiency 6


### standard using a 4

- foot medium bi

- pin as a 7


### proxy for the 2

- foot U

- tube is a little

-- 8


### analytically I don't know if I agree with that. 9


### Thank you. 10


### MR. BROOKMAN: Okay. Thank you. 11


### Charlie Stephens? 12


### MR. STEPHENS: Charlie Stephens. Is 13


### there some reason why you are not going to 14


### analyze even one of the greater t han 4,500 K 15


### categories? 16


### I mean, the department makes a case 17


### that they're different. It seems to me you 18


### ought to analyze at least one of those to see 19


### what the magnitude of that difference is, if it 20


### shows up in your analysis. 21


### MS. KIENLE: Okay. So, a gain, it's 22

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### 89



### on the basis of high market share but we do 1


### consider the greater than 4,500 K in the 2


### scaling analysis and we can cover that a little 3



### bit more later on. 4


### MR. BROOKMAN: Joe Howley? 5


### MR. HOWLEY: Just a couple of 6



### comments. First is on the T5 la mps. During 7


### the 2009 rulemaking we had a lot of discussion 8


### about how it was critical and necessary to test 9


### these at 25 degrees Celsius. That's where our 10


### labs are capable of testing these. 11


### Testing becomes very unreliable at 12


### 35 degrees C. That's a signi ficantly higher 13


### temperature and we do not have capability of 14


### having reliable test results at those levels. 15


### The data that you have listed here 16


### though is based on 35 degrees C data. Again, 17



### we had this discussion in 2009 where we all had 18


### agreed that we wou ld do test measurements and 19


### use numbers at 25 degrees C measurement but 20



### that

-- we're having the same discussion over 21


### again that we had three years ago where this is 22

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### 90



### not appropriate to use. A lumen per watt level 1


### is based on 35 degrees C measurements for T5 2


### lamps. So we'll make that comment once again. 3


### MR. BROOKMAN: Thank you. 4


### MS. KIENLE: Can I just respond to 5


### that quickly? We're actually

-- one of the 6


### reasons why we're using the 35 C data in 7


### particular is because we actually don't have 25 8



### C data in manufacturer

-- for all the 9



### manufacturers. 10


### Some manufacturers don't actually 11



### offer that data. So if we could collect the 12


### data we could also consider using that as well. 13


### But, again, the standard is set at 25 C so 14



### it's accounted for there. 15



### MR. HO WLEY: There was one other 16


### comment I was wanting to make. 17


### MR. BROOKMAN: Joe Howley? 18


### MR. HOWLEY: Yes. That was again 19



### not related. This

-- there was a comment about 20


### whether replacements of lamps or lamps less 21


### than 10 percent of the mean lumen output

-- 22

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### 91



### with the replaced system occur in practice. 1


### Generally, not. 2


### People will not go in and replace 3


### lighting systems lamp for lamp that are more 4


### than 10 percent lower in light output unless 5


### it's felt that the space was overlit to begin 6


### with or the space was repurposed and they're 7


### using it for some other, you know, some other 8


### process than was used there before. Then they 9


### might lower the lumen output. 10


### But in general if the same tasks are 11


### being done, then customers will try to maintain 12


### the same light ou tput or certainly within 10 13


### percent of the light output. That was a 14


### specific question asked here. 15



### MR. BROOKMAN: Final comments on 16


### these product classes for GSFLs? 17


### MS. KIENLE: Okay. So next we're 18


### going to move on to the baseline lamp 19



### discussion fo r GSFLs. A baseline lamp 20


### represents the most common least efficacious 21



### model available on the market. 22

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### 92



### To note, when we refer to efficacy 1


### in this analysis we're referring to the rated 2


### efficacy of the lamp. 3


### So for GSFLs rated efficacy is the 4


### catalog initial lumen output divided by the 5



### ANSI

- rated wattage and the ANSI

- rated wattage 6


### is listed as rated wattage in the table shown 7



### here. 8


### In the case of GSFLs, one baseline 9


### lamp was chosen for each product class. The 10


### baseline lamps, again, are shown in th e table 11


### here. DOE requests comment on the baseline 12


### lamps chosen for GSFLs. 13



### MR. BROOKMAN: Steve Rosenstock? 14



### MR. ROSENSTOCK: Steve Rosenstock, 15



### EEI. The values in this table reflect

-- these 16


### are the July 2012 minimums, correct? 17



### MS. KIENLE: Not ex actly, no. So I 18


### can actually address that question now too. 19


### Thanks for letting me defer that to now. 20


### So essentially the 2009 lamps rule 21


### set the standards based on the catalog 22

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### 93



### efficacies and then those were then adjusted 1


### for compliance data. So there might not 2


### actually be lamps that show up at that minimum 3


### point. 4


### So these are actually just the 5


### commercially available lamps that we found that 6



### were the

-- that we considered the most common 7


### and least efficacious that were actually 8



### available on the mar ket. 9



### MR. ROSENSTOCK: Steve Rosenstock , 10



### EEI

. D o these meet the July 2012 standard? 11


### MS. KIENLE: They do, yes. 12


### MR. ROSENSTOCK: Thank you. 13



### MR. BROOKMAN: Mike? 14


### MR. MCGARAGHAN: Mike McGaraghan. I 15



### would echo NEMA's concern that these values 16



### shoul d be placed at the standard levels 17



### themselves. 18



### I took a look at the certification 19


### database, which I think is a pretty good tool 20


### at this point for assessing actual reported 21


### compliance values, and there are products right 22

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### 94



### at the level, particularly for t he 4

- foot 1



### medium bi

- pin class. I didn't look closely at 2



### all the other classes. 3



### So and then the follow

- on question 4


### to that is would DOE agree that the 5


### certification database is now a great reference 6


### point for us to be using for this analysis or 7



### is ther e something about it that makes it 8


### inappropriate for that? 9



### MS. deBUTTS: I can answer that. 10


### Lucy deButts, DOE. We actually used the 11


### certification database for our analysis right 12


### now on, basically, all lighting rulemakings. I 13



### know that for a fact. But I think on every 14



### other rules as well. 15


### MR. BROOKMAN: Okay. 16



### MR. HOWLEY: This is Joe from GE. 17


### And I would agree as well that you should use 18


### the 2009 regulatory levels as your baseline. 19


### If lamps aren't at that today and 20


### perhaps when you did your ana lysis and I'm not 21


### sure when you started

-- it maybe a year ago

-- 22

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### 95



### it could be very well be that when you looked 1


### at the database at that point there were no 2


### lamps right at that level. But the market will 3


### drive to lamps at that level due to the cost of 4



### rare earth materials. 5


### And so even though you may not find 6


### them right now I think you could

-- it's easy 7


### to make an assumption that lamps will gravitate 8



### towards that bare minimum level over time and 9


### that that should be the analysis you're using 10


### going forwar d over the next, you know, six to 11



### ten years. 12


### MR. BROOKMAN: Okay. Final comments 13



### here? 14



### MS. KIENLE: DOE then identified 15



### more efficacious substitutes for each baseline 16


### lamp. DOE sought to keep characteristics such 17


### as the rated life, CRI and CCTs sim ilar to the 18


### baseline lamp. 19


### So as you can see in this 4

- foot 20



### medium bi

- pin example table, reduced wattage 21


### lamps were identified as more efficacious 22

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### 96



### substitutes as were full wattage lamps with 1


### higher efficacies. 2


### Additionally, the table presents 3



### both instant start and program med start 4



### lifetimes because both were considered when 5


### selecting more efficacious substitutes for 6



### GSFLs. 7



### MR. BROOKMAN: Mike? 8


### MR. MCGARAGHAN: Sorry to interrupt. 9


### A question

-- Mike McGaraghan, California 10



### IOUs. On the rated wa ttage can DOE explain the 11


### purpose of using the ANSI

- rated wattage or 12


### anyone in the room, really, specifically now 13



### that we have the DOE

-- the compliant 14


### certification database where products are 15


### listed with specific wattages, some of which 16



### aren't ANSI

- rated wattages? 17


### MS. KIENLE: So ideally we use the 18



### ANSI

- rated wattage, and maybe the manufacturers 19


### would like to comment on this more too, but 20


### ideally we use the ANSI

- rated wattage to more 21


### accurately reflect the lamp operation, and it 22

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### 97



### is n’t in the CCMS databa se. They generally do 1


### include the measured wattage. Sometimes it's 2


### not but maybe the manufacturers have another 3



### response. 4



### MR. MCGARAGHAN: So wouldn't measured 5


### wattage be a more accurate value than an ANSI 6


### standard wattage? 7



### MS. KIENLE: Well, we a ccount for 8


### the measured wattage too. That's what we do 9



### with the

-- using the compliance data. 10


### MR. BROOKMAN: When you say you 11



### account for it what did

-- I didn't get that. 12



### MS. KIENLE: Yes. So we'll discuss 13



### that a little bit more later on too. But 14



### e ssentially we're using the ANSI

- rated wattage 15


### because it's a complete set of values to go by 16


### and it most accurately would represent lamp 17


### operation. 18


### It's obviously different than the 19


### nominal wattage so we

-- it's generally higher, 20


### generally. So we woul d go with that. 21


### But, again, and when we consider the 22

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### 98



### compliance which would be a measured value 1


### ideally , that's when we can adjust for any 2



### differences. 3


### MR. BROOKMAN: Alex Boesenberg? 4


### MR. BOESENBERG: Alex Boesenberg, 5


### NEMA. The industry has a quest ion in for 6



### clarification of the DOE on the use of the 7


### terms rated versus nominal, et cetera. 8


### But fundamentally the rated wattage 9


### in practice for reporting is based on a very 10


### large number of samples that you then average 11


### out and decide, ah, when we manu facture it we 12


### fall on and around that point. 13


### So hence your rated value, which may 14



### differ

-- probably will differ for any 15


### individual lamp chosen and tested. 16


### But when you decide where to put 17


### your stake in the ground as far as yes, we 18


### produce a 32

- wat t lamp that's how you get there 19



### -- hundreds of data points, not thousands. 20


### MR. MCGARAGHAN: So you support the 21



### use of ANSI

- rated wattage rather than taking a 22

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### 99



### look at actual measured wattage of the products 1



### on the market? 2



### MR. BOESENBERG: I'll defer to other 3


### members, but my understanding is yes. 4



### MR. BROOKMAN: That was Alex. Now 5



### to Joe. 6


### MR. HOWLEY: Well, it's

-- and it 7


### is. I agree. It's a somewhat discussed topic 8


### within industry because we do have nominal 9


### wattages, rated wattages, measured wattag es and 10


### it is not always clear, even in the reporting 11


### forms, what to use in which case. 12


### In fact, we have a question in to 13


### DOE right now that talks about clarification 14


### and exactly how we should report which wattage 15



### to use and what

-- I think what was not ed 16


### already is you find a selection of different 17


### wattages being reported depending on how people 18


### are interpreting this. 19



### But I'm not sure that we have a firm 20


### position on this. We recognize there's lots of 21


### different wattages you could be using and 22

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### 100



### that's why I can't give you a real strong 1



### response. 2



### MR. MCGARAGHAN: Well

-- Mike 3


### McGaraghan

-- my recommendation would be 4


### looking at this

-- from what I can see here 5


### you're basing a standard assuming the lamp has 6


### a rated wattage of 32.5 so that gives you your 7


### target efficacy when maybe a lot of these lamps 8



### aren't at 32.5. 9


### It would be worth looking at in the 10



### database to see whether a lot of them are 11


### coming in at different levels and setting your 12


### baseline and your standards around more

-- 13



### around measured dat a rather than a rated 14


### wattage. It seems logical to us. 15


### MR. BROOKMAN: Okay. 16


### MS. KIENLE: Okay. So as I was 17


### saying before, the table here presents both the 18


### instant start and program med start lifetimes 19


### because both were considered when selecting 20



### more efficacious substitutes for this product 21



### class. 22

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### 101



### And this is because multiple system 1


### pairings were analyzed for the 4

- foot medium 2



### bi

- pin product class and I'm going to explain 3



### that a little bit more in the next few slides. 4


### Fluorescent lamps operate on a 5


### ballast in practice. Therefore, DOE analyzed 6


### lamp and ballast systems in the engineering 7


### analysis in order to capture real

- world energy 8


### use and light output. 9


### DOE used manufacturer input and 10



### information from the 2011 ballast rule to 11


### identify the balla st type most commonly paired 12


### with each lamp. 13


### So as you can see by this table, the 14



### 4

- foot medium bi

- pin lamps were paired with 15


### multiple ballast types. Both instant start and 16



### program

med start ballasts were analyzed as well 17


### as ballasts that operate both two and four 18


### lamps. 19



### All of the other product classes 20


### analyzed were paired with one ballast type. 21


### When developing lamp and ballast systems, DOE 22

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### 102



### tried to select ballast models to pair with 1


### lamps that would maintain system mean lumen 2


### output within 10 perc ent of the baseline when 3


### possible. 4



### This is an example table of the 4

- 5



### foot medium bi

- pin two

- lamp instant start lamp 6


### and ballast replacement scenario and so I have 7


### a few things to highlight here. 8


### At the higher CSLs, DOE selected a 9



### ballast with a lower b allast factor when 10


### possible to further improve the energy savings. 11

12


### Specifically, DOE selected the 13


### lowest ballast factor possible that still 14


### maintained system mean lumen output within 10 15


### percent of the baseline. 16


### So as you can see, the full wattage 17



### rep resentative units at CSL 1 and CSL 2 were 18


### paired with low ballast factor ballasts. 19


### Both systems still maintain system 20


### mean lumen output within 10 percent of the 21



### baseline. 22

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### 103



### In the case of the 25

- watt reduced 1


### wattage lamp, DOE would have had to pair the 2


### lamp with a high ballast factor ballast in 3


### order to maintain lumen output within 10 4


### percent of the system of the baseline system. 5


### So instead, DOE selected a normal 6



### ballast factor ballast and is the same ballast 7



### that's used at the baseline so as to not 8



### i ncrease energy consumption. 9


### The system mean lumen output is 10


### approximately 14 percent lower than the 11



### baseline. 12



### MR. BROOKMAN: Steve Rosenstock? 13



### MR. ROSENSTOCK: Steve Rosenstock , 14



### EEI . I appreciate this table because it's 15


### really giving a sense of wh at's going on and I 16


### think the issue here especially is in all of 17


### these cases you're reducing light output. 18



### That's a fact. All of these CSLs 19


### you might say it's maintaining but you're 20


### reducing by anywhere from, I'll say, like 8 to 21


### 13.8 percent in all of t hese cases. 22

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### 104



### And, again, now I know you went to 1



### the lowest ballast factor but some of the 2



### lowest ballast factors are the same or almost 3


### equal to the baseline ballast factor. 4



### So in all these cases

-- and the 5


### reason it's important especially for new 6



### bui ldings is, you know, you're doing

-- you 7


### have to meet the code, you're meeting your 8


### watts per square foot but you also have to meet 9


### the lumen output on the surface for the people 10


### is you might be saving watts but you're going 11


### to have to put in more fixtures to meet the 12


### requirements of that space. 13


### So, you know, you might be showing 14


### some saving s on this table in terms of system 15


### input power but once you design a space the 16


### savings are going to be

-- will almost 17


### disappear probably. 18


### It all depends on the d elta lumens 19


### versus the delta watts because you have to put 20


### in more fixtures for that space. 21



### And I think

-- and again, I think 22

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### 105



### the

-- you know, it's not

-- you know, when you 1


### say maintain if it's always less than it's not 2


### maintaining, in my book. I'm sor ry. 3



### MR. BROOKMAN: Keith? 4


### MR. K. COOK: I tend to agree with 5


### Steve on this. The problem you've got is 6


### putting in more fixtures is not going to help. 7


### It's typically in the middle of a room. 8


### It's still going to be just those 9



### fixtures above. It i s not common practice to 10


### replace lamps with lower output lamps because 11


### most spaces are designed for recommended 12


### practices from IES. So there is a minimum 13


### light output that that space was designed for 14


### originally. So now you come in. 15


### Now you're going t o be below those 16


### minimums and that's going to create problems 17


### and a lot of consumer dissatisfaction, which 18


### will be totally unacceptable. And there's 19



### other reasons too we have to be careful on the 20


### selection of these lamps. 21


### As Pekka pointed out earlier, in 22

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### 106



### some cases the lower output lamp will not work 1


### satisfactorily in dimming conditions. So if 2


### you've already got dimming installed in that 3


### application you just can't arbitrarily go to a 4


### lower output light. It may not work. 5


### MR. BROOKMAN: Okay. Yes, M ike? 6


### MR. MCGARAGHAN: Mike McGaraghan, 7



### California Utilities . Just speaking from the 8


### experience of the utilities running a huge 9


### amount of rebated lamps through our programs

-- 10


### retrofit programs

-- I completely agree that 11


### maintaining light output is an im portant part 12


### of a lighting retrofit and the last thing we 13


### would want to do is to promote retrofits that 14


### result in not enough light and can dissatisfy 15



### consumers. 16



### If consumers come to work and don't 17


### like the new project or whether you're talking 18



### resident ial or commercial or any sector of 19


### people don't like the result that's a bad 20



### outcome. 21


### They're not going to do it again. 22

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### 107



### They might actually retrace their steps, undo 1


### it. That said, nine times out of ten you 2


### change out the lights in a commercial space and 3


### everybody complains that it's too bright. 4


### Most spaces were not designed exactly to 5


### IES standards. They were often given a little 6


### extra light initially. Systems degrade. 7


### Lumen maintenance is a huge issue 8


### with fluorescent systems, particularly older 9


### systems, T12 systems. You come in and you 10


### retrofit all the lights to exactly the same 11


### level and it seems blinding to everybody in 12



### there. 13


### That's the comment you get over and 14


### over. Nobody comes in after a lighting 15


### retrofit and says oh, you took a way all my 16


### light. So yes, it's important to provide 17


### enough light for people. 18


### It's important to meet the 19


### guidelines in IES. But scenarios where you add 20


### 5, 8, 12 percent light are not going to fly 21



### with consumers. 22

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### 108



### Scenarios where you subtract 2, 4, 1


### 6, 8 percent those

-- a lot of those will still 2


### seem too bright to people too. So we would 3


### definitely recommend that you stick in that 4


### less than equal lumens range for your

-- you 5


### know, equal to or less than in your scenarios 6



### here. 7



### MR. BROOKMAN: Alex? 8


### MR. BOESENBERG: Alex Boesenberg, 9



### NEMA. I would add to that or caveat Mr. 10


### McGaraghan's statement with remember that a lot 11


### of these retrofits, especially in California 12


### due to Title 24, include dimming as we already 13


### stated. So if you drive the lamp watt age too 14


### low you're sacrificing the dimmability. 15


### So when NEMA encourages high 16


### efficiency fluorescent retrofits through one of 17


### our marketing programs and we always try to 18


### encourage lighting controls and so yes, you 19


### relamp it and oh, my God, it's brighter

-- we 20



### don't want that. 21


### Oh, well, there's this handy button 22

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### 109



### right here and it drops it right down. And we 1


### believe that is where the largest amount of 2


### savings lies. 3


### So reducing the capability, as we 4


### already said. I won't belabor it any further. 5



### B ut preserve the dimmability. 6



### MR. BROOKMAN: Steve? 7



### MR. ROSENSTOCK: Steve Rosenstock , 8



### EEI . I also work for a utility that had very 9


### big rebate programs, Pepco actually. 10


### In fact, this building took 11


### advantage of Pepco rebates, and the T12 to T8 12



### marke t shift over the last 20 years has been a 13


### huge success story and going from magnetic to 14


### electronic ballast has been a huge success 15



### story. 16


### But now, you know, we're almost

-- 17


### in many areas we're past that. We're talking 18


### about T8 to T8. We're talking el ectronic 19



### ballast to electronic ballast. 20


### We're talking limited depreciation. 21


### That's at most, you know, 10 percent over 25 22

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### 110



### or 40,000 hours versus a 20 or 30 percent that 1


### we got with the T12. Going from T12 to T8 has 2


### always been a success story. 3



### We' re just

-- but the scenario now 4



### is T8 to T8 and it could make a difference 5


### especially

-- and again, it may be my building 6


### code point of view, especially for new 7


### buildings or total renovations that are meeting 8


### the building codes. 9


### It will have an impact in terms of 10


### some of the possible designs. Thank you. 11



### MR. BROOKMAN: John? 12


### MR. GREEN: Yes. John Green, Cooper 13


### Lighting. I'd like to point out that personal 14


### perception of the light level is not the 15


### driving reason for IES recommended levels. 16


### It's p erformance, how to

-- how to 17


### accurately and correctly do a task that's given 18


### them in that space. So I'd like to add that 19


### keeping light levels is important for 20


### efficiency in the work place. 21



### MR. HOWLEY: And this is Joe and 22

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### 111



### last

-- one last comment to add on. One of the 1


### reasons you get that reaction that there's a 2


### lot of light right after a retrofit is that 3


### these systems are designed to maintain mean 4


### lumens over approximately a five

- year period. 5


### So day one is when you have your 6


### highest light output and , you know, the end of 7



### year five, let's say, where they're going from 8


### is when you have your lowest light output. 9


### That's why we design for mean 10


### lumens. You know, in the beginning you're 11


### above that mean lumen level. At the end you're 12



### below that mean lu men level. 13


### But still you have to factor in that 14


### over the course of five years you want to 15


### maintain approximately the same mean lumen 16


### output so that when you get to the end of that 17



### five

- year period you're not

-- people aren't 18


### bringing flashlights into w ork trying to figure 19



### out where all their lumens went. 20


### And you have the lumen depreciation 21


### from the lamp but you also have the dirt 22

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### 112



### appreciation, fixture depreciation. 1


### There's other depreciation factors 2


### as well that factor in. So you have, you know, 3



### t here could be a considerable difference in 4


### light output between the beginning and the end 5



### that is

-- that's noticeable. 6


### But I think in this system on some 7


### of these I notice are not within 10 percent. I 8


### mean, you're dropping it more than 10 percent 9



### and I don't believe that is a fair comparison 10


### that you have to get these or you should strive 11


### to have these essentially equal as we go from, 12


### as Steve said, T8 to T8. 13


### It's no longer older T12 systems, 14


### many of which were overlit, to mere T8 systems. 15


### Right now, we've had a lot of retrofitting 16


### happen in the last two decades. A lot of light 17



### levels now have been reset at levels that are 18


### appropriate for computer use. They are 19


### fairly low today and we have to recognize that 20


### in terms of this analysis

-- that we should try 21


### to maintain approximately the same light output 22

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### 113



### we have today as we look at this in terms of 1


### energy savings. Thank you. 2


### MR. BROOKMAN: Okay. Maureen, why 3


### don't you queue up the comment boxes? 4



### MS. KIENLE: Sure. 5



### MR. BROOKMAN: I think we 've begun 6


### to cover these but just let us

-- give us

- 7



### MS. KIENLE: Sure. So the first 8


### request for comment is on the more efficacious 9



### substitutes identified for GSFLs. 10


### DOE also requests comment on its 11


### methodology and the representative lamp and 12



### balla st systems for GSFLs, in particular, the 13


### ballast luminous efficiency of each system and 14


### also the ballast factor of the reduced wattage 15



### systems. 16



### MR. BROOKMAN: Mike? 17


### MR. MCGARAGHAN: Mike McGaraghan, 18



### California Utilities . So this is your

-- this 19



### comm ent is about more efficacious substitutes 20


### so how you set each CSL level, essentially? 21



### MS. KIENLE: We're not at the CSLs 22

### NEAL R. GROSS
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### 114



### yet but essentially these will feed into the 1



### CSLs. So the more efficacious substitutes that 2


### we identified, essentially. 3



### MR. MCGARA GHAN: Okay. So I'll ask 4


### my question now. The certification database 5


### seems to have a large number of products that 6


### far exceed anything DOE has acknowledged in 7



### this document. 8


### So the question is is there

-- why 9


### did DOE not include those products. 10



### Th ey're in the range of

-- there's 11


### probably 20 or 30 products that are above 96 12


### lumens per watt in the database looking at just 13


### one product class. I believe that's less than 14


### 4,000 or 4,500 Kelvin in 4

- foot lamps. 15


### MS. KIENLE: I guess I would ask do 16


### you ha ve specific examples or

-- 17



### MR. MCGARAGHAN: There were about 18


### ten manufacturers. They were MaxLite, Satco, 19


### Philips, Westinghouse

-- a lot of products. 20


### Unless I'm reading the database wrong it looks 21


### like there's a huge cluster above 100 lumens 22

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### 115



### per watt. 1



### MR. BROOKMAN: Joe? 2


### MR. HOWLEY: I would suggest that 3


### perhaps either you're reading the database 4


### wrong or you don't understand the data being 5


### inputted or manufacturers are confused about 6


### what to put in different categories so you're 7


### getting false calc ulations if you see numbers 8



### like that because those are not achievable in a 9



### measured basis. 10



### So I think there's database issues 11


### when you're coming up with numbers like that. 12


### MR. MCGARAGHAN: Thank you. I 13


### appreciate that. That was my reaction when I 14


### saw those high values as well. I didn't 15


### realize that there were products achieving that 16


### efficiency. So I'll double check. 17


### Maybe I can talk with one of you 18


### guys in the break to see if I'm misreading the 19


### database but I looked at it pretty closely. 20


### I suspect that there is some sort of 21


### reporting inconsistency or confusion with which 22

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### 116



### values get in there somehow. So I would 1


### encourage DOE to take a look at that. 2



### MR. BROOKMAN: Aisha? 3


### MS. HUSAIN: Yes, this is Aisha. So 4


### as Maureen has said, we did l ook at the 5


### compliance database and we will look at it 6


### again. 7


### So these new products

-- the March 8


### deadline for certification just came along so 9


### we will be looking at the data again for the 10


### NOPR stage so we can look at those things. 11


### But the compliance data is taken in 12


### account not at this stage but this is based 13


### along catalog values because that's where we 14



### found the most data and then we took the 15


### compliance

-- w e looked at the certification 16


### database and then adjusted those levels that we 17


### came up with. 18



### MR. BROOKMAN: Steve? 19



### MR. ROSENSTOCK: Steve Rosenstock , 20



### EEI

. A gain, looking at that slide

-- the 21


### previous slide, 43

-- you have CSL 2 with three 22

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### 117



### different

-- three technologies there. 1


### So I'm just

-- you know, even though they 2



### have different efficac ies and different light 3


### output is, again, I'm not

-- I'm used to 4


### seeing, you know, one, two, three, four and 5


### usually the four is the highest efficacy, let's 6


### say, you know, typically. 7


### In this case, they're not really the 8


### same efficacy or light output. Is this because 9



### -- is the DOE thought process that it will just 10


### only use one of these in the final NOPR 11


### analysis as at CSL 2 or

-- I guess I'm a little 12


### confused by the

-- by the labeling of three 13


### different technologies as the same candidate 14



### standard level. 15


### MS. KIENLE: Right. So DOE will 16



### consider all three of these at CSL 2 so we 17


### actually analyzed them separately and the 18


### impacts that any standard level or the life 19


### cycle cost analysis as well is analyzed for 20


### each representative unit. 21


### MR. ROSENSTOCK: Okay . And my

-- 22

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### 118



### MS. KIENLE: So the CSL

-- the CSL 1


### doesn't necessarily correlate to, like, one in 2


### particular. 3



### It would

-- generally you would 4


### think that it would go to the lowest and then, 5


### again, the CSLs are adjusted based on 6


### compliance so it might no t

-- might not 7


### actually fall at that lowest efficacy value. 8



### But these are

-- all three representative units 9



### were considered at CSL 2. 10



### MR. ROSENSTOCK: Steve Rosenstock , 11



### EEI . I thank you for that but I guess that 12


### leads to the next one and maybe you're n ot at a 13


### decision point yet but what it also kind of 14


### looks at is to say that it almost would say 15


### that for I'll say CSL 2 with a 25

- watt nominal 16


### wattage and CSL 2 with 28 nominal wattage would 17


### almost say that DOE is considering a standard 18



### that would almost e liminate the 32

- watt lamp in 19


### the marketplace. 20



### MS. KIENLE: No, that's not

-- 21


### MR. ROSENSTOCK: No? Okay. 22

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### 119



### MS. KIENLE:

-- what DOE is 1


### considering. We're going to discuss this in a 2


### little bit too but just to, I guess, to clarify 3


### at this point, DOE is not considering any CSLs 4


### that a full wattage lamp cannot meet. 5


### MR. ROSENSTOCK: Thank you very 6


### much. Appreciate that. 7



### MS. KIENLE: Sure. 8



### MR. BROOKMAN: Additional comments 9



### here on these two comment boxes? Aisha? 10


### MS. HUSAIN: This is Aisha. I ju st 11


### had a quick question on we discussed the 12


### baseline meeting the 10 percent of the light 13



### output. 14


### I was wondering if manufacturers had 15


### any recommendation as to a number we should be 16


### using or it should be. I know Joe had said 17


### approximately equal. Was t here any number that 18



### we could use? 19



### MR. BROOKMAN: Joe? 20


### MR. HOWLEY: I think just from a 21


### evaluation standpoint I think it's fairest if 22

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### 120



### you try to match up the systems as closely as 1


### possible with one another from a lumen output. 2



### And I understand it's n ot, you know, 3


### technically possible in all cases because 4


### you're dealing with different ballast factors 5


### and different lamps. 6


### But and I think you asked this 7


### before but if you stay within 10 percent at 8



### least it's

-- perhaps you could argue it's a 9


### fair comp arison. 10


### I think once you get beyond that 10 11


### percent range you no longer can say that's a

-- 12


### that's a fair comparison lighting system to 13


### lighting system. 14


### And I just noted that some of yours 15


### seem to go beyond the 10 percent where we no 16


### longer conside r that to be a fair comparison. 17


### So, again, try to make it as close 18


### as possible or certainly less than 10 percent 19



### would be our advice. 20


### MS. HUSAIN: Okay. Thank you. 21



### MR. BROOKMAN: Alex? 22

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### 121



### MR. BOESENBERG: And Alex Boesenberg 1



### from NEMA. I think in an action we will expand 2



### on that in our written comments. 3


### MR. BROOKMAN: Thank you. Steve? 4



### MR. ROSENSTOCK: Steve Rosenstock , 5



### EEI . I know I'm not a manufacturer but just 6


### seeing what can happen in the marketplace I 7


### would say equal to or higher to maxi mize 8


### customer utility. Thank you. 9


### MR. BROOKMAN: Thank you. Other 10


### comments on these two issues? Take a peek. 11


### Let's cover it here effectively. Okay. 12


### MS. KIENLE: So moving on to the 13


### CSLs, DOE used commercially available lamps 14


### when possible and th eir associated rated 15


### efficacy to determine the initial CSLs. 16



### Then to establish final minimum 17


### efficacy requirements for CSLs, DOE coupled 18


### publicly available compliance data with rated 19


### efficacy to determine if any adjustments were 20


### necessary to the initial CSLs. 21


### When determining CSLs, DOE only 22

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### 122



### considered CSLs at which a full wattage version 1


### of the lamp type was available because reduced 2


### wattage lamps cannot be used in all 3


### applications such as cold temperature 4


### applications and also because striations sti ll 5


### remain an issue for reduced wattage lamps. 6



### So to do th at full wattage 7


### requirement, DOE modeled a lamp for the 4

- foot 8



### T5 mini bi

- pin high output product class 9


### because no full wattage higher efficacy 10


### replacement was commercially available. 11



### In order to model the lamp, DOE used 12


### a commercially available reduced wattage T5 13


### high output lamp that was more efficacious than 14


### the baseline lamp to scale to a full wattage T5 15


### high output lamp of comparable efficacy. 16


### This table here displays the 17


### baseline lamp ch aracteristics and the 18


### performance characteristics of the model lamp 19



### at CSL 1. 20


### So as you can see, the model lamp 21


### has both the higher lumen output and lifetime 22

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### 123



### compared to the baseline lamp. 1


### The rated efficacy at 35 degrees C 2


### is improved from 92.9 lume ns per watt at the 3


### baseline to 97.3 lumens per watt at CSL 1. 4


### DOE requests comment on the 5


### methodology and performance characteristics of 6


### this model lamp. Specifically, DOE requests 7


### information on the manufacturability and 8


### functionality of this lamp as w ell as its 9


### expected efficacy when manufactured on a 10



### commercial scale. 11



### MR. BROOKMAN: Steve? 12



### MR. ROSENSTOCK: Steve Rosenstock , 13



### EEI

. T he CSL 1

-- is this also the max tech? 14



### Would this also be considered the max tech? 15


### Because as I recall that in yo ur 16


### analysis you're supposed to show some sort of 17



### max tech option. So I'm just

-- is this max 18



### tech as well? 19


### MS. KIENLE: Yes. At this point 20



### this would be considered the max tech level. 21



### MR. BROOKMAN: Keith? 22

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### 124



### MR. K. COOK: This whole thing kind 1



### of sca res me a little bit because it almost 2


### comes across now that DOE is designing and 3


### inventing new lamps and the problem is is this 4


### may not even be feasible. 5



### We don't know, and so as a result we 6


### may end up establishing a class where there is 7


### no products av ailable as a result of this 8


### approach. 9



### MR. BROOKMAN: Steve? 10



### MR. ROSENSTOCK: Steve Rosenstock , 11



### EEI . I also

-- again, just because of all the 12


### other rulemakings I don't know if I've ever 13


### seen another rulemaking where it's just been 14



### baseline and max tech

. 15


### Usually there's something in between 16


### and if there's nothing in between I think 17


### that's a significant issue. Thank you. 18


### MR. BROOKMAN: Okay. Thank you. 19



### Alex? 20


### MR. BOESENBERG: Alex Boesenberg, 21


### NEMA. Regarding that creation of this lamp, as 22

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### 125



### it we re, in the past in situations such as this 1


### the government, DOE, has commissioned the 2


### design and test of a product where one doesn't 3



### exist. 4


### Will the department make one of 5


### these lamps or actually several of these lamps 6


### and test them, confirm the performan ce? 7


### MS. KIENLE: So at this point we're 8


### looking for feedback from the manufacturers on 9


### the feasibility of this lamp. 10



### MR. BOESENBERG: Do you want us to 11



### make one? 12


### MS. KIENLE: If you'd like. No, any 13


### information that you can submit would be really 14



### hel pful on this in particular. Any reasons why 15


### you think this isn't feasible

-- for example, 16


### if you've tried it, if it hasn't worked. 17



### MR. BROOKMAN: Pekka? No? 18



### MR. HAKKARAINEN: Not yet. Next 19



### slide. 20


### MR. BROOKMAN: Okay. Joe? 21



### MR. HOWLEY: I think o ur engineers 22

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### 126



### do have concerns and have to get more 1


### information but they have significant concerns 2


### about how this T5 area was analyzed and this 3



### CSL 1 max tech level being proposed which also 4


### I think they have significant concerns about 5



### it. 6



### I notice in t his case it claims to 7


### reflect operation at 25 degrees C versus the 8


### other operation at 35 degrees C but I think 9


### this is where they thought this more was 10



### indicative of 35 degrees C as well. 11


### The levels seem very high to them. 12


### We need to get more feedback on this. But 13


### where you're heading with these T5s, because 14


### the T5 levels are significantly lower than this 15


### right now in the standard and it seems like 16


### you're going from a standard

-- you know, T5 17


### levels that are relatively easy to meet to 18


### levels that may not even be technically 19


### possible, and as Steve said he hasn't seen this 20



### before. 21



### We haven't seen this before either. 22

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### 127



### This is really concerning that DOE is taking 1


### this approach with these T5 lamps. 2


### MS. KIENLE: So just to clarify, 3


### this is lamp operation at 35 degrees C. 4


### MR. HOWLEY: It is lamp operation? 5



### MS. KIENLE: Yes. 6


### MR. K. COOK: You know, which we 7


### don't test at so we don't know. So you're 8


### asking us if it's been looked at. We test at 9



### 25 degrees C. I can't answer your questions. 10



### MS. KIENL E: Information on testing 11



### at 25 degrees C or any kind of information on 12



### that would be useful as well. 13


### MR. K. COOK: Okay. 14



### MR. BROOKMAN: Alex? 15



### MR. BOESENBERG: This is Alex 16


### Boesenberg, NEMA. Doesn't the test procedure 17



### state testing at 25 degrees C? 18



### MS. KIENLE: It does but there is 19


### performance characteristics in manufacturer 20


### catalogs at 35 degrees C. That's most 21


### commonly, I would say, reported. 22

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### 128



### MR. K. COOK: Those are particular 1


### amalgam lamps that were designed specifically 2



### for that environment . It's not generally 3


### applied, though. 4


### MR. BOESENBERG: Yes. We begged the 5


### government to stick to the test procedure. 6



### That's what it's for. 7


### MR. HOWLEY: So one other just 8


### comment and, again, the concern and confusion 9


### on Page 47 or Slide 47 you do hav e a footnote 10


### that says it reflects it at 25 degrees C, 11


### unless I'm misinterpreting that. 12



### But so we see that footnote at 25 13


### degrees C but yet the numbers do seem to 14



### reflect 35 degrees C. So that's

-- we're 15


### having some confusion here. Slide 47. 16



### MS. KI ENLE: Yes. So Slide 47 that 17


### is the T5 high output. That would be the 18


### proposed standard level at 25 degrees C. So if 19


### you compare it to the efficacy on the previous 20



### slide that's lower. 21


### MR. HOWLEY: But it's still a very 22

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### 129



### high

- 1


### MS. KIENLE: Okay. I s ee what 2


### you're saying. 3



### MR. HOWLEY:

-- and very concerning 4



### at those levels. 5



### MR. BROOKMAN: Pekka? 6



### MR. HAKKARAINEN: Since we are now 7



### on Slide 47

-- Pekka Hakkarainen from Lutron 8


### commenting

-- when I'm

-- this slide says that 9


### the following CSLs are no w under consideration. 10

11


### I'm looking at the final rule from 12


### 2009, Table IV.1 which lists max tech levels 13


### for GSFLs, and with the exception of the first 14



### item shown on Slide 47 where the CSL 2 is at 15



### the 2012 max tech level all the other CSLs are 16


### higher tha n the max tech levels in 2012. 17


### I'm now really curious to understand 18


### how you arrived at these numbers. 19


### MS. KIENLE: I guess I'd have to

-- 20


### can you clarify, like, what specifically are 21


### you interested at? 22

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### 130



### MR. HAKKARAINEN: Well, if I just go 1



### down the list we are currently saying that on 2


### this rulemaking the 8

- foot slimline lamp would 3



### have one candidate standard level at 99 lumens 4


### per watt and in 2012 the max tech was 98 lumens 5


### per watt. The next one down we are currently 6


### considering 97. In 2012, the m ax tech was 95. 7

8


### With the T5 standard output we are 9



### now at 98.2. Max tech was 90. The high output 10



### T5 at 86.2 when max tech was 76. 11


### Especially for the T5 lamps, this is 12


### a huge jump and I don't know anything

-- maybe 13


### somebody has invented something mi raculous but 14


### I know nothing that would justify going beyond 15



### max tech in 2012. 16



### MR. BROOKMAN: Keith? 17



### MR. K. COOK: Yes, I don't know of 18


### any new products that have come out in the last 19


### year or so that comes anywhere close to these 20


### new levels you're showi ng. 21



### MR. HOWLEY: Same. Just to 22

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### 131



### reiterate, there's been no major technology 1


### changes in this area in the last two or three 2


### or four years since the 2009 rulemaking. 3


### So, again, there would be no reason 4



### for max tech to jump with no technology changes 5



### dur ing this last couple year period. 6


### MR. BROOKMAN: Let's go to the 7



### comment boxes. 8



### MS. KIENLE: DOE requests comment on 9


### the CSLs under consideration for GSFLs, in 10


### particular the appropriateness of developing a 11


### CSL 1 for the T5 high output product class 12


### based on the model lamp. 13


### DOE also requests comment on whether 14


### additional adjustments to the CSLs are needed 15


### to account for compliance requirements. 16



### MR. BROOKMAN: Alex? 17


### MR. BOESENBERG: Alex Boesenberg, 18


### NEMA. Regarding item

-- issue 13, and I guess 19


### I'll just say number two, ability to comply but 20


### also relates to number one, you mentioned 21


### phosphor there. 22

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### 132



### What factor has DOE or Navigant in 1


### their analysis given the current shortage of 2


### rare earth elements and the existing practice 3



### of waivers? How do es that factor in to 4


### compliance capability, if you will? 5


### MS. KIENLE: So DOE is considering 6



### the waiver and also the rare earth. It's 7


### analyzed as an LCC sensitivity and then also in 8


### the NIA as an alternative scenario, which we'll 9



### cover a little bit more later on. 10


### MR. BOESENBERG: Thank you. 11



### MR. BROOKMAN: Other comments? What 12


### about compliance requirements? I think we need 13



### a break. 14



### It's

-- we may not be 100 percent 15



### finished with these two comments but let's 16



### break here and we can return to them an d give 17


### you a chance to dwell on them while we go and 18



### walk around a little bit. 19



### It's now 10:55. Let's resume here 20


### in this room at 11:10, 15 minutes. 21


### (Whereupon, the above

- entitled 22

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### 133



### meeting went off the record at 10:57 a.m. and 1



### resumed at 11:10 a.m.) 2



### M R. BROOKMAN: Once again, welcome 3


### to those joining us via the webinar. We're 4


### going to pick up where we left off. I'm not 5


### convinced that we got all the comments that 6


### were waiting for

-- either 13 or 14, so I want 7


### to take us back to that and maybe the brea k 8


### jarred some content loose. Pekka and Keith, 9


### whichever of you is first. 10


### MR. HAKKARAINEN: Pekka Hakkarainen, 11


### Lutron. I guess my conclusion, when I'm 12


### looking at slide 47 and addressing the , 13


### perhaps, issue, the thing is that the numbers 14



### shown in the tab le, to me, contradict the 15


### statement made on slide 45, which says that DOE 16


### is considering CSLs at which full

- wattage 17


### versions of the lamps are available to meet the 18


### standards. These standards are set so high 19


### that I am very concerned that full

- wattage 20


### lamps will be eliminated. And with that, 21


### significant energy savings are going to be 22

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### 134



### eliminated and not be the theoretical a couple 1


### of percent energy savings that we are looking 2


### at with lamp efficacy, which may or may not 3


### result in any actual energy savings in 4


### buildings. 5


### MR. BROOKMAN: Okay. Thank you. 6



### Keith? 7


### MR. K. COOK: Regarding issue 14, 8


### the compliance requirements, just want to 9



### reiterate the fact that we do need to make sure 10


### that the standards do reflect manufacturing 11


### tolerance, testing tolerances, and all those 12


### other things that have been reviewed before 13



### with the DOE. And I'd like to reference LSD 63 14


### from NEMA, which very clearly specifies what 15


### the requirements should be based upon all those 16



### tolerances I mentioned. 17


### MR. BROOKMAN: Okay. Thank yo u. 18


### MS. KIENLE: And just to clarify, 19


### I'm not sure if I mentioned this before, we 20


### might have breezed over this slide a little 21


### quickly, but the final CSLs that are presented 22

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### 135



### here are accounting for compliance 1


### requirements. 2


### MR. BROOKMAN: Did you have 3


### additional comments? No? Nothing additional. 4



### Mike first. 5


### MR. MCGARAGHAN: Mike McGaraghan, 6


### California Utilities. I just want to echo 7


### Pekka's comment that we see dimming as an 8


### extremely valuable asset in this market and DOE 9



### should take care not to eli minate products that 10


### dim. That's maybe something that we could have 11


### talked about in the scope section or the 12


### product class section, but if there are, you 13


### know, two sets of products, one set that can 14


### dim and one set that's much more efficient, 15


### then maybe t hat's grounds for covering them in 16


### separate product classes so that we can ensure 17


### you either comply by being very efficient or by 18


### having your dimmable product. 19



### MR. BROOKMAN: Steve Rosenstock? 20



### MR. ROSENSTOCK: Steve Rosenstock. 21


### And, again, that table on 47 makes it, again, 22

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### 136



### for four out of the five products, CSL 1 1


### represent what DOE considers max tech, correct, 2


### in these product categories? Maximum 3


### technology. That's

-- 4


### MS. KIENLE: Right. DOE is 5


### currently considering 1 CSL for all the product 6



### clas ses -- 7



### MR. ROSENSTOCK: And that is 8


### equivalent to the max, that would be equivalent 9



### to a max tech for all these, for these four 10


### products? 11


### MS. KIENLE: Right. So a max tech 12


### lamp, specifically, might perform higher than 13


### the CSL. But, again, since we'r e accounting 14


### for that full wattage requirement, the CSL is 15


### set here to account for the full wattage. And 16


### then, additionally, any max tech products would 17



### also fall at the same level. Is that more 18


### confusing? 19


### MR. ROSENSTOCK: I think, I think I 20



### hear what you're saying. But, again, the fact 21


### that there's no higher CSLs, basically, in 22

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### 137



### DOE's mind, this is the max that's out there 1


### for those products, based on the criteria about 2



### the full

- wattage lamp? 3


### MS. KIENLE: Right. 4


### MR. ROSENSTOCK: Thank you. 5



### MR. BROOKMAN: Alex? 6


### MR. BOESENBERG: Alex Boesenberg, 7


### NEMA. So returning to Dr. Hakkarainen's 8


### earlier comment, some of those numbers in CSL 1 9


### are higher than the max tech previously noted, 10



### so how did max tech get maxier if the tech 11


### hasn't changed? 12



### MS. KIENLE: So these CSLs are based 13


### on catalog initial lumen output divided by the 14



### ANSI

- rated wattage. So these are catalog 15


### values, so I just want to express that these 16


### are levels are based on commercially available 17


### products. 18


### MR. BOESENBERG: So was the p revious 19



### iterations max tech based on a different 20


### equation then? 21


### MS. KIENLE: No, I don't think so. 22

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### 138



### MR. BOESENBERG: Well, the number

-- 1


### MR. deLASKI: Some years have 2


### elapsed, Alex. 3



### MR. BOESENBERG: True, but there 4


### have been no major technical inno vations. I 5


### just don't understand how the numbers changed. 6


### MR. BROOKMAN: Lucy deButts? 7


### MS. deBUTTS: Well, I can't really 8


### speak to the catalog data that was available 9


### prior to 2009. If you have further data that 10


### could help us, we'd appreciate your i nput. 11



### MR. BROOKMAN: Joe? 12



### MR. HOWLEY: Our concern is that 13


### these are simply based on finding more 14


### aggressive marketing claims in catalogs, not 15


### finding any real change in technology. There's 16


### always some manufacturers that are willing to 17


### claim more, fa ster, higher, when, you know, it 18


### tends to be, perhaps, more of a marketing claim 19


### than a technology reality. And that may be 20


### what's going on here, and, if that's the case, 21


### we have concerns about going to the most 22

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### 139



### aggressive marketing claim, product claim, out 1


### there by any manufacturer because some of them 2



### do stretch in terms of claims. 3



### MR. BROOKMAN: Andrew? 4



### MR. deLASKI: Just to follow

- up. 5



### It's Andrew deLaski from ASAP. That would 6


### suggest that there's some enforcement action 7


### the Department should be taking if there are 8


### products out there that are being certified in 9


### the database that aren't, you know, that aren't 10


### compliant so

-- 11



### MR. BROOKMAN: Charlie? 12



### MR. STEPHENS: Yes. Charlie 13


### Stephens. I'd like to go back to Mike's 14



### earlier comment. I do n't think he was 15


### misreading the database. I mean, the column, 16


### it says efficacy. You know, you put the number 17


### in there. I mean, I think everybody who puts 18


### that number in there knows what that means, so, 19


### you know, somebody ought to, you know

-- yes, 20



### so do we. And I think, you know, I think until 21


### we all know that we're dealing with consistent 22

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### 140



### data here, it's darn hard to make any decisions 1


### about whether this looks right or not. I mean, 2


### I don't know about everybody else, but with all 3



### the different numbers being bandied about here, 4


### I'm just nothing but confused at this point. 5


### So maybe if we can clear this up, I could make 6


### some rational judgment as to whether this makes 7



### sense or not. 8



### MR. BROOKMAN: Lucy. 9


### MS. deBUTTS: Lucy deButts, DOE. So 10


### if we, as I understand this correctly, we're 11


### saying that there's some manufacturers that 12


### certify products that are not compliant and DOE 13


### should go after them because the data that 14


### we're presenting actually uses the 15


### certification data, as well. We can look into 16



### it. 17


### MR. STAS: Eric Stas. Maybe I'll 18


### ask this question. Is it that they're not 19


### meeting the minimum standards or they're 20


### overstating the maximum, so they would still 21


### comply with the minimum standards? Is that 22

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### 141



### what's happening? 1



### MR. BROOKMAN: Joe? 2



### MR. HOWLEY: It's hard to say. I 3


### think there's also a lot of confusion among 4


### manufacturers about what exactly to report and 5


### what column, but that could be part of it, as 6


### well. It could be that the lamps are in 7


### compliance, but some of the claims being made 8



### ar e aggressive. 9



### MR. BROOKMAN: You think there's 10


### confusion about which data to put in which 11



### columns? 12



### MR. HOWLEY: Yes. We have a series 13


### of questions into DOE right now about how to 14


### report, and there's a lot of confusion among 15


### manufacturers in industry about this. 16


### MR. BROOKMAN: Interesting. Go 17


### ahead, Keith. 18



### MR. K. COOK: Now I'm confused. I 19


### thought that this data was catalog data, but 20


### Lucy led me to believe that this is compliance 21


### reported data. 22

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### 142



### MS. deBUTTS: What I said is that we 1



### looked at t he catalog data. We also looked at 2


### the compliance data and adjusted for that, but 3


### there was not enough compliance data at the 4


### time when we were doing the analysis. Aisha, 5


### correct me if I'm wrong. So we will analyze it 6


### further. I'm not saying this is it . NOPR 7


### stage will create, you know, another round of 8


### analyses, but it's based on catalog first and 9


### then adjusted for the compliance data that we 10



### had at the time. 11



### MR. BROOKMAN: Eric Stas? 12


### MR. STAS: Okay. Eric Stas, DOE. 13



### So a follow

- up question for everybody. So in 14


### the 2009 lamps rule, was the level setting in 15


### the analysis done the same way? So did 16



### manufacturers make wilder claims in the 17


### intervening years, or was there more compliance 18


### data then to check against that that you didn't 19


### have any object ions at the 2009 time frame? 20



### MR. BROOKMAN: Keith? 21


### MR. K. COOK: More compliance data 22

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### 143



### now, considerably more. There's a much larger 1



### database. 2


### MR. BROOKMAN: Okay. Thank you, 3



### Keith. Andrew deLaski? 4


### MR. deLASKI: A question. So, Alex, 5



### you s uggested, you told us a couple of times 6


### that you have a request into the Department for 7


### clarification on these points, and I wonder if 8


### you could share that request. DOE probably 9


### will publish it, but, if you could share it, 10


### that would help us to understand the sort of 11


### questions you guys are grappling with. 12


### MR. BOESENBERG: I'll talk to my 13


### counsel. I don't see a reason why we can't, 14



### but I have to

-- 15


### MR. deLASKI: It will be public 16


### eventually. 17


### MR. BOESENBERG: It will be public 18


### eventually, right. 19



### MR. BROOKMAN: Lucy? 20



### MR. BOESENBERG: I'll connect with 21


### you offline. 22

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### 144



### MR. deLASKI: Okay. 1


### MS. deBUTTS: Lucy DeButts, DOE. So 2


### DOE is addressing comments that we received 3


### from NEMA, and we are working on a set of 4


### guidance. I cannot say when it's g oing to come 5


### out, but we're actively working on responding 6


### to those questions. So as soon as they're 7


### available, we're going to publish them on the 8


### guidance database, which is accessible through 9



### the DOE website. 10



### MR. deLASKI: It sounds like these 11



### issues are very much interconnected. The kind 12


### of guidance that you guys are seeking is 13


### interconnected with the concerns being raised 14


### right here. Okay. 15


### MR. BROOKMAN: Okay. 16


### MR. deLASKI: So if you could share 17


### that with us, it would help us to put in 18


### thought ful comments, frankly. 19



### MR. HOWLEY: I think this overall 20


### issue is a function of the fact that, you know, 21


### in the last rulemaking, we were going from a 22

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### 145



### relatively modest efficiency regulation of 75 1


### lumens per watt to something higher. In fact, 2



### for a lon g time we discussed 83 lumens per watt 3


### as being the next level, and we were actually 4


### somewhat surprised when it came out at the 89 5


### lumen per watt level when we were talking four

6


### foot lamps at that time. But there was, 7


### obviously, a policy change where they decided 8


### to go to a very high level, as opposed to 9



### moderate level. So most of the discussion was 10


### around going mid 83 and, of course, we knew we 11


### had products that easily met 83. So there 12



### wasn't a lot of discussion in this area about 13


### who's reporting what o r what levels are on or 14


### what's in people's catalogs. But now that we 15


### are talking about numbers at the very tippy

- top 16


### of the highest claim anybody would make, then 17



### all of this stuff becomes relevant where it 18


### wasn't relevant before, is all these real, can 19



### t hese lamps actually meet these levels, are 20


### these lumen per watt numbers actually 21



### achievable? 22

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### 146



### When we're talking about the 1


### absolute ceiling, these all come into play. 2


### And so I think the DOE needs to make sure they 3



### have actual test data from labs that sho w 4


### exactly what these products are capable of and 5


### not based on marketing claims when we're 6


### talking about the absolute maximum technology, 7


### or you can inadvertently end up in a situation 8



### like we have with the 130

- volt power lamps. We 9


### set a level so high that , although it appeared 10


### on paper that some people might make these, in 11


### reality, they're technically not achievable, 12


### and we don't want to inadvertently wipe out 13


### entire product classes here. 14



### MR. K. COOK: In that same vein that 15


### Keith got from Philips, the p roposed candidate 16


### standard levels is to appoint two of a decimal 17


### place. That is providing an artificial measure 18


### of accuracy that doesn't even exist. I think 19



### we can ’t measure it that accurately. 20


### MR. deLASKI: Maybe this can't be 21


### entered today, but are we seeing a discrepancy 22

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### 147



### between, is the Department seeing a discrepancy 1


### between the catalog datas for given models and 2


### what's in the database being certified to you? 3


### MS. KIENLE: So there's generally 4


### some variation, yes. I would say there's 5


### definitely variation between what's reported, 6


### which would be a tested value, and then what's 7


### presented in the catalogs. 8


### MR. BROOKMAN: Significant 9



### variation? 10



### MS. KIENLE: There's some variation. 11


### MR. K. COOK: You need to recognize 12


### the process that we have to go through in 13


### developing new products. And, you know, when 14


### we set up our catalog values, we start that 15


### very early in the process with only a handful 16


### of samples completed at that time. Now, the 17


### database is thousands of samples, essentially, 18



### later, and so it's much more representative of 19


### the manufacturing. But in the meantime, the 20


### catalog is already out there, and it's already 21


### based upon much smaller sample size. So 22

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### 148



### there's going to be a difference between those 1



### two. 2


### MR. deLASKI: Do you eventually s ync 3


### them up eventually? 4


### MR. K. COOK: Yes, eventually, there 5


### will be a true up, but, usually, we only 6


### refresh our catalog every two or three years. 7


### MR. deLASKI: Are you required to? 8


### I mean, are you allowed to market a level 9


### different than what you certified with DOE? 10


### MR. K. COOK: Yes, there is some, 11



### there is allowable difference there. 12


### MR. deLASKI: Okay. 13


### MR. K. COOK: And, typically, 14


### typically, well, there is some allowable 15


### difference. It's recognized that this is a 16


### problem. 17



### MR. deLAS KI: I remember it came up 18


### in the last rulemaking, too. We had this 19


### discrepancy between the catalog because DOE was 20


### working on catalog values, and you all said, 21


### well, hang on here, this has created some 22

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### 149



### problems. I remember we never quite got to the 1



### bott om of it, in my recollection. 2



### MR. BROOKMAN: Lucy? 3


### MS. deBUTTS: Lucy DeButts, DOE. I 4


### think this is question, this question can be 5


### addressed by recent FTC rulemaking where they 6


### have labeling requirements for lamps. I would 7



### refer to that for the answ er. 8



### MR. BROOKMAN: Charlie? 9


### MR. STEPHENS: Yes, Charlie 10


### Stephens. I would just remind everybody that 11


### the market out there, the designers are using 12


### catalog values, so it would be a little 13


### discouraging to find out that they weren't 14



### real. 15



### MR. BROOKMA N: Mike? 16


### MR. MCGARAGHAN: Mike McGaraghan, 17


### California Utilities. Keith, your comment 18


### about significant digits and accuracy of the 19



### measurement, I wanted to ask about

-- my 20


### understanding is that the test procedure is 21


### very specific on

-- I'm talking abou t 22

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### 150



### certification now

-- the test procedure is very 1


### specific on the sample size and the way you 2


### gather products for the sample. You measure 3


### all the products, you take the mean, and then 4


### you also calculate, you do a statistical test 5


### on the upper 99 percent c onfidence limit or 6


### something along those lines. So you have two 7


### values, and you just take the smaller. That 8


### might have any number of decimal points after 9


### it, so I guess I'm confused why one significant 10


### digit is considered too inappropriate or

-- 11



### MR. BO ESENBERG: This is Alex 12


### Boesenberg, NEMA. Mike, have you read NEMA LSD 13


### 63? I'll send you a copy happily. We argue 14


### these decimal point percentages are getting 15


### past the realm of repeated and reliable 16



### measurement. 17



### MR. MCGARAGHAN: So I'm not 18


### referring to the NEMA test procedure. I'm 19


### referring to the DOE test procedure. 20



### MR. BOESENBERG: We have submitted 21


### various comments to that effect, to the DOE 22

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### 151



### test procedure and to other rulemakings. 1


### MR. MCGARAGHAN: As long as that 2


### test procedure exists, that's what we're using, 3


### and it has, it has a procedure to come to a 4


### very specific number. 5



### MR. BROOKMAN: Steve Rosenstock? 6



### MR. ROSENSTOCK: Steve Rosenstock , 7



### EEI . I know that, like with, I'm familiar with 8


### other, like, heating and cooling equipment, 9



### like AH RI. I believe the tolerance that 10


### they're allowed in their test, in terms of, 11


### let's say it's an AFUE or anywhere between five 12


### and ten percent, depending on the product, just 13


### because of the testing equipment accuracy. So 14


### there is going to be

-- so the high er the 15


### number and if you try to make it a smaller 16


### range, it just might not be possible just to 17


### get the test equipment. So you have to have a 18


### certain tolerance in terms of, because you're 19


### testing a product with a piece of testing 20


### equipment, there is going to be some sort of 21


### error. That's always going to happen and, you 22

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### 152



### know, the higher the numbers, the more that 1



### becomes an issue. 2


### MR. BROOKMAN: Maureen, as you look 3


### at 15 or 14, is there anything specifically you 4


### wish to queue for them to respond to or have we 5



### covered it? 6



### MS. KIENLE: I think we've covered 7


### it at this point. 8


### MR. BROOKMAN: Okay. Let's keep 9


### going. 10


### MS. KIENLE: Okay. So once CSLs are 11


### established for the representative product 12


### classes, DOE develops scaling factors to apply 13



### those C SLs to the remaining product classes. 14


### This process involved comparison of lamps that 15


### differ only by the parameter under 16


### consideration for scaling. So in this case, it 17


### would be shape or CCT. 18


### To develop a scaling factor to 19


### account for shape, DOE compar ed commercially 20



### available two

- foot U

- shaped lamps with CCTs 21


### less than or equal to 4,500 K and the 22

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### 153



### equivalent four

- foot medi um bi

- pin version. By 1


### comparing catalog ratings, DOE found that an 2


### average efficacy reduction of two percent from 3



### the four

- foot medi um bi

- pin CSLs was 4


### appropriate for the two

- foot U

- shaped lamps. 5


### Similarly, to develop a scaling 6


### factor to account for CCT, DOE identified pairs 7


### of lamps in which the only difference was CCT. 8


### DOE compared lamps with a CCT of 4,100 K to 9


### lamps of a CCT of 5,000 K and also 6,500 K. 10



### DOE determined that a two

- percent reduction of 11



### the CSL as established for the less than or 12


### equal to 4,500 K representative product class 13


### was appropriate. In both cases, DOE also 14


### confirmed that the scaling factor did not 15



### result i n backsliding from the current 16



### standards. 17


### DOE requests comment on the 18


### methodology and the results of its scaling 19


### analysis for GSFLs. 20



### MR. BROOKMAN: Joe? 21


### MR. HOWLEY: Well, I believe your 22

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### 154



### two

- percent decrease for the high chromaticity 1


### lamps is probab ly accurate. I don't believe 2



### your two

- percent decrease for U lamps is 3


### accurate. The percentage decrease on those 4


### lamps, typically, more is in the four

- to six

5


### percent range when you are going from a four 6


### foot to a U lamp. 7


### Again, if you're going off c atalog 8


### data, there's other confounding factors 9


### happening here, but I believe if you looked at, 10


### perhaps, manufacturer to manufacturer, even 11



### with that there's issues with some of the 12


### catalog data that I've seen in the industry. 13


### But from a technology standpo int, again, I'll 14


### double check with our engineers, but I believe 15



### it's more in the four

- to six

- percent range, as 16


### opposed to, perhaps, what you've found in 17


### catalogs. 18


### MR. BROOKMAN: Okay. Other comments 19


### here? Scaling and

-- did you queue the 20


### engineering a nalysis? 21


### MS. KIENLE: Yes. So at this time, 22

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### 155



### also, we'd like to request any comments on the 1


### overall methodology and results of the GSFL 2


### engineering analysis. 3



### MR. BROOKMAN: No additional 4


### comments? Okay. 5


### MS. KIENLE: Okay. I'm going to 6



### hand this o ff to my colleague, Julie Pierce. 7


### MS. PIERCE: Hi. My name is Julie 8


### Pierce, and I am with Navigant. I will discuss 9


### the IRL engineering analysis. In general, DOE 10


### chooses representative product classes on which 11


### to focus its analytical effort. Of the ei ght 12


### IRL product classes, which are shown in this 13


### table, the standard spectrum, greater than 2.5 14


### inches, less than 125

- volt product class shown 15


### in darker green was chosen as representative 16


### based on its high market volume

. 17


### DOE requests comment on its choic e 18


### of the representative product class for IRLs. 19



### MR. BROOKMAN: No comments here? 20


### MS. PIERCE: All right. The 21


### baseline lamp is the most common, least 22

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### 156



### efficacious model on the market for each 1


### representative product class. For IRLs, DOE 2



### found two comm on low

- efficacy lamps for the 3


### representative product class and is considering 4


### both as baseline models. They are both 60

- watt 5



### PAR38s. 6


### The first is an improved halogen 7


### lamp, which means it is a halogen lamp with an 8


### improved reflector. It has a light ou tput of 9


### 1070 lumens, an efficacy of 17.8 lumens per 10


### watt, and a lifetime of 1,500 hours. 11


### The second is an HIR lamp. It has a 12


### light output of 1100 lumens, an efficacy of 13


### 18.3 lumens per watt, and a lifetime of 3,000 14



### hours. 15


### DOE requests comment on its 16


### selection of two baseline lamps with similar 17


### efficacies but distinct technologies and 18



### lifetimes. 19



### MR. BROOKMAN: Steve Rosenstock? 20



### MR. ROSENSTOCK: Steve Rosenstock , 21



### EEI . You said most common. Is that just in 22

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### 157



### terms of models or sales, just out of 1



### c uriosity, in your analysis? 2


### MS. PIERCE: It was based on catalog 3



### data. 4


### MR. ROSENSTOCK: On catalog data. 5



### So

-- Steve Rosenstock , EEI . I thank you for 6


### that. So did you do any analysis, are there 7


### any other lamps, I'll say 60

- watt lamps, that 8



### represen t, I'll say 50 percent of sales in the 9


### marketplace that might have different 10


### characteristics? I know you're looking at 11


### catalog, but what's happening in the 12


### marketplace if there's 2012 or 2013 data in 13


### terms of what's actually being sold that might 14



### be diffe rent from this baseline? I'm just kind 15


### of curious about what's happening in the 16


### marketplace in terms of a baseline. 17


### MS. PIERCE: Does anyone have 18



### comment on that? 19



### MR. ROSENSTOCK: You don't have

-- 20


### okay. 21



### MR. BROOKMAN: Andrew? 22

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### 158



### MR. deLASKI: This is one of our 1


### areas of highest concern in the P

- TSD. It's 2


### really unusual to see two baseline products, 3


### and, you know, we're still kind of wrestling 4


### with it, but my intuition is that it's the 5


### wrong path. I'm struck that

-- really, two 6


### things. One is that this is different than how 7


### DOE typically does a baseline. Typically, a 8


### baseline is the minimum product available. So, 9


### for example, if you're going to use the most 10


### common dishwasher available for the baseline, 11



### it would have been the last standard bec ause 12



### the most common dishwasher available was an 13


### ENERGY STAR compliant product. It was above 14


### the minimum. So using the most common product, 15


### as Steve points out, is a different question 16


### than what is the least efficient product 17



### available. 18



### MS. PIERCE: We found these two 19


### products to have similar efficacies and

-- 20


### MR. deLASKI: But what they don't 21



### have is similar lifetimes. 22

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### MS. PIERCE: Correct. But we felt 1



### that the consumer economics would be different 2



### for the two baselines because of the lifetime 3



### dif ference, so we assess both in the LCC 4


### analysis

-- 5


### MR. deLASKI: Right. So what's 6


### puzzling to me is that

-- I'm not a lighting 7


### engineer. The lighting engineers are on that 8


### side of the table or else they work with you 9


### guys, so you can answer that better than I can. 10


### So the question is, I mean, my understanding 11


### is that lifetime and efficacy are very much 12



### related when it comes to incandescent 13


### technology. These two things, they go in 14


### opposite directions so that, as a product, as 15


### you increase lifetime, you'r e reducing efficacy 16


### in an incandescent product, all other things 17


### equal. 18



### MR. BROOKMAN: Joe? 19


### MR. HOWLEY: Right, that's correct. 20


### Therefore, if a lighting engineer were to look 21


### at these two products, they would clearly point 22

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### out that the first one was a lesser technology 1


### because it was only able to achieve 1,500 hours 2


### of life, where the second one is a more 3


### advanced technology. What you found in 4


### marketing catalogs is, basically, products that 5


### are designed for the consumer market or they 6



### don't need the long lifetime, and they're 7


### looking for, perhaps, a less expensive opening 8


### price point. 9


### The second one is a product that 10



### would be sold more towards a commercial 11


### customer who is more concerned about long 12


### operating hours because they might use it in a 13



### store that burns them, you know, 16 hours a day 14


### and they don't want to be replacing lamps every 15


### other day. So they would gravitate more 16


### towards the higher

- technology lamp, trying to 17



### reduce maintenance costs and those kinds of 18


### things. 19


### So although they might h ave a 20


### similar efficacy, the first one truly would be 21


### the baseline lamp, as you described it, Andrew. 22

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### The second one would not be the baseline lamp. 1


### MR. deLASKI: Right. Adding from an 2


### analytical point of view, from an analytical 3


### point of view, what yo u've just done is you've 4


### just went up the first step on the energy curve 5


### with that because you just went up the 6


### technology curve, as Joe described it, to the 7


### first improvement. You've taken that first 8


### improvement, and you put it into the baseline, 9



### and tha t's the most cost effective improvement 10



### that has now been, basically, averaged into the 11



### baseline. 12


### Now, the market, I think, is 13


### important. What Joe is describing, these 14


### market pieces is something that would come in 15


### somewhere else in the analysis, but not in the 16


### baseline. And to me, you know, your lifetime

- 17



### - so if you were to take that lamp, that 3,000

- 18


### hour lamp, hold all other things equal and 19


### reduced that lifetime, then it would have a 20


### higher efficacy. 21



### MR. BROOKMAN: Steve? 22

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### MR. ROSENSTOCK: Steve Rosenstock, 1


### EEI. Especially to follow

- up with Joe and 2


### Andrew, I guess then

-- and please forgive me. 3


### I didn't read that part of the technical 4


### support document. In the LCC, are you doing, 5


### I'll say separate tracks for, I'll say the 6



### residential consumer m arket with, I'll say 7



### baseline one and the commercial market for 8


### baseline two and then aggregating the results? 9


### MS. PIERCE: We don't aggregate the 10


### results. They're separate. There's a 1,500

- 11


### hour residential, separate from commercial, and 12


### then a 3,000

- h our residential separate from 13



### commercial. 14


### MR. ROSENSTOCK: Okay, thanks. 15


### MR. deLASKI: This is Andrew again. 16


### And the way you would typically deal with that 17


### is you would, you know, deal with how the 18


### shipments shake out in your shipments baseline. 19



### If 100

- percent of commercial shipments are 20


### already at this level, then you would reflect 21


### that in your shipments analysis and it would 22

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### flow through to the LCC and NIA, but you 1


### wouldn't capture that until you got those later 2


### analyses, as opposed to trying to bu ild it into 3


### the baseline, which seems to me to be a more 4


### typical approach to this problem. 5



### MR. BROOKMAN: Joe? No? Mike? 6


### MR. MCGARAGHAN: Mike McGaraghan, 7


### California Utilities. I just wanted to 8


### reiterate the same point that Joe and Andrew 9


### just made. That was a big concern for us 10


### coming here today was these two baselines, and 11


### we agree that the true baseline here is the 12


### less efficient product with the shorter 13



### lifetime. Fifteen hundred hours is more 14


### representative of the sort of minimum lifetime 15



### that consumers expect from these lamps, so we 16


### recommend using that as your baseline product. 17


### MR. BROOKMAN: Okay, thank you. 18



### Steve? 19



### MR. ROSENSTOCK: Steve Rosenstock , 20



### EEI . I guess a quick follow

- up. In your 21


### research, what percentage of the market for 22

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### th ese lamps is consumer and what percentage is 1



### commercial? 2



### MS. PIERCE: I know the answer to 3


### that, but I think it's confidential so

-- 4


### MR. ROSENSTOCK: I'm not trying to 5


### get anything proprietary, just a generic

-- 6



### MS. PIERCE: So I'll refrain from 7



### an swering. 8



### MR. BROOKMAN: Charlie? 9


### MR. STEPHENS: Charlie Stephens. To 10



### follow

- up on Steve's question, how do you 11



### determine what's residential and what's 12


### commercial? Do you do that by distribution 13


### channel, or do you do that by what socket it 14


### ends up in? 15


### MS. PIERCE: Well, we just consider 16


### both in the LCC analysis. 17



### MR. STEPHENS: Consider both what? 18



### MS. PIERCE: Commercial and 19



### residential. 20



### MR. STEPHENS: I understand that, 21


### but I guess I'm wondering, given the volumes 22

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### that currently go throug h distribution channels 1


### like Lowe's and Home Depot right now where you 2


### really don't know whether it was commercial or 3


### residential, the socket that it ended up in, I 4


### guess I'm wondering how you knew that. 5


### MS. PIERCE: That might be more of 6


### an NIA questio n, which we'll get to later. 7


### MR. STEPHENS: We can probably talk 8


### about that later, but I think when you start 9


### talking about lifetime and everything else, you 10


### know, I can buy that second lamp at Home Depot 11



### and I can do that for a commercial socket or a 12



### re sidential socket. 13



### MR. BROOKMAN: Alex? 14



### MR. BOESENBERG: This is Alex 15


### Boesenberg, NEMA. Perhaps Aisha knows, is that 16


### part of DOE's lighting market characterization? 17



### I don't recall. 18


### MS. HUSAIN: Specifically, the 60

- 19



### watt PAR38 distribution or

-- 20


### MR. BOESENBERG: Well, I think 21


### there's a socketing data set there, and we can, 22

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### perhaps we can arrive at some agreement as to 1


### what percentage of those tend to be the higher 2


### technology. 3


### MS. HUSAIN: Yes, they have splits 4



### on residential and commercial bas ed on socket, 5



### as well, so

-- 6



### MR. BOESENBERG: I think that's the 7



### answer then. 8


### MR. BROOKMAN: Are we ready to move 9



### on now? I think so. 10


### MS. PIERCE: Okay. DOE identified a 11


### more efficacious replacement lamp with a lower 12


### wattage and a lumen output wi thin ten percent 13


### of the baseline lamps. The replacement lamp 14



### for both baselines was a 55

- watt PAR38 improved 15


### HIR lamp, which means it is an HIR lamp with an 16


### improved reflector. It has a light output of 17


### 1,100 lumens, an efficacy of 20 lumens per 18



### watt, and a lifetime of 4,400 hours. 19



### For the more efficacious 20


### substitutes, DOE requests comment on the 21


### criteria used in selecting substitute lamps, as 22

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### well as the characteristics of the lamps 1



### selected. 2



### MR. BROOKMAN: Steve Rosenstock? 3



### MR. ROSENSTOCK: Steve n Rosenstock , 4



### EEI . I remember from the last rulemaking where 5


### the Justice Department was concerned about the 6


### higher standard levels because of that certain 7


### technologies for halogen infrareds were 8


### proprietary and that there were going to be 9


### competitive conc erns because only a couple of 10


### companies were making, I'll say the highest 11


### efficacy lamp in this product category. So 12


### with this particular technology, is this, 13


### again, the issue where this might be a 14


### proprietary technology that's only made by a 15


### very limited or even just only one manufacturer 16



### -- again, I'm not trying to cause any trouble 17


### with anyone across the table here

-- that is 18


### going to be limited in both, you know, also 19


### limited in availability and also the fact that 20


### it's, you know, the price could be, we ll, I'll 21


### just say extremely high, could have an 22

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### extremely high price point? 1


### MS. PIERCE: No, we did not find 2



### that to be an issue. 3


### MR. ROSENSTOCK: Okay, thank you. 4



### MR. BROOKMAN: Andrew? 5


### MR. deLASKI: So my concern with 6


### this table is that, you know, we're moving 7


### again, the table moves these two dependent 8


### variables, both lumens per watt and lifetime, 9


### so that the product that now is the more 10


### efficacious substitute is providing not just 11


### greater efficacy but also more light, more 12


### hours of lighting, greater utility. So we're 13


### ending up with a different product, which I 14


### think is being designed to meet some commercial 15


### consumer's desire for a long

- lived product. 16


### And if you were to take that same product and 17



### reduce its hours to be the same hours as the 18



### b aseline lamp, it would have a significantly 19


### higher efficacy, I think, from an engineering 20


### perspective. 21


### MS. PIERCE: We were using only 22

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### commercially available lamps in the analysis. 1


### MR. deLASKI: Right. I think that's 2


### probably, I think, in this case, t he standard, 3


### the hours here are a limiting factor on your 4


### efficacies that you're looking at. 5



### MR. BROOKMAN: Keith? 6


### MR. K. COOK: Could you explain what 7


### is meant by an improved reflector? 8


### MS. PIERCE: So it uses the higher 9


### efficiency reflector, su ch as silver. 10



### MR. K. COOK: But that is 11


### proprietary. 12


### MS. PIERCE: Would anyone like to 13



### comment on that? 14


### MR. HOWLEY: Well, I'd just like to 15



### comment that

-- Joe Howley

-- that DOE did find 16


### this to be an issue in the 2009 rulemaking. 17



### There's not bee n a lot of change in the world 18


### in the last three years, and I do think this 19


### factors in to your factor of impact on 20


### lessening the competition. I think this does 21


### probably have an impact there. I can't go any 22

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### further but to say that the world hasn't 1


### changed that much in three years when, as Steve 2


### pointed out, you did have that finding a few 3



### years ago. 4


### MR. BROOKMAN: Thank you. Mike? 5


### MR. MCGARAGHAN: Mike McGaraghan, 6



### California Utilities. I believe that the world 7


### has changed a little bit since 2009 be cause 8


### we're starting to see other silverized 9


### reflector products on the market. And we'd be 10


### happy to submit comments along those lines 11


### documenting them. The one that comes to mind 12


### is Halco is marketing a silverized PAR product. 13


### In terms of patents out t here, I 14


### believe GE has one, I think DSI has one, and I 15



### know there's one at Lawrence Livermore Lab. I 16



### think there are other manufacturers that now 17


### have silverized reflectors, as well. I don't 18


### know if there's any in the room here that have 19


### a product with a silverized reflector that can 20


### speak to that, but it doesn't seem like it's a 21


### niche product anymore. It seems like that's 22

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### 171



### widely available so we support the use of that 1


### as a design option. 2


### And I guess I'll keep going. While 3


### we're talking about more e fficacious 4


### substitutes, I am pretty concerned that there's 5


### only one CSL. There is huge potential in the 6


### IRL market for efficacy gains, and some of that 7


### is commercially available, some of it isn't. 8


### But starting with what's 9


### commercially available, DOE h as not come close 10


### to identifying it, and I wrote them all down 11


### here so I can go through. But, at least 12


### according to the certification database, 13


### Philips has a 70

- watt PAR38 at 22 lumens per 14


### watt. That's 13 percent better than the CSL 15


### value here. They hav e a 55 watt at 20.1 lumens 16


### per watt, 10 percent better than the CSL value. 17


### GE has a 23 lumens per watt product, 12 18


### percent better. I think Osram's best products 19


### are not in the certification database right 20


### now, at least I couldn't find them. 21



### And then there's a bunch of other 22

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### smaller manufacturers now that aren't 1


### represented here that have great products. The 2


### best one on the list was 25 percent better than 3



### CSL 1. 4


### There is huge potential for 5


### additional CSLs, two, three, four, among just 6



### the commerci ally available products. And that 7


### doesn't get into the products that are in 8


### development that have made huge strides in the 9


### last couple of years. I'm sure everyone has 10


### heard of the 2X lamp. You can buy them online. 11


### There's a website, 2X light now, or I' ll send 12


### the link, but they have A lamps, they have MR16 13


### lamps, the PAR lamps it says coming soon. 14



### But DOE needs to think outside the 15


### box a little bit because these capsules which 16


### achieve this high efficacy are not rare 17


### products at this point or unachie vable. 18


### They're not just prototypes. They're 19


### commercial products that can easily be dropped 20


### into other lamp form factors into reflector 21


### lamps. 22

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### And then they blow this number out 1


### of the water. We're talking 28, 30, 32. The 2


### lamp that we assembled in 2 009 was a 37 lumen 3


### per watt lamp. That's almost twice as 4



### efficient as this CSL. 5


### Now, there may be limitations, and 6


### that's part of the process. We need to look at 7


### the lamps and explore how much these lamps 8


### cost, can they be made, can they scale up 9


### produ ction? But that's not even addressed 10



### here. DOE needs to look at max tech and then 11


### identify what's cost effective and feasible. 12



### And we have a lot of data and would 13


### be happy to submit more information about this 14


### in our comments. But, at a glance, it jus t 15


### seems like we're aiming really short here. 16


### MR. BROOKMAN: Okay. Keith? 17


### MR. K. COOK: I guess I'm a little 18


### concerned that here we are inventing lamps. We 19


### don't know anything about whether or not 20


### they're commercially available. In fact, we 21



### know the y're not in some cases. We don't even 22

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### 174



### know if they're technically viable. We have 1


### demonstrated high as 37 lumens per watt, but, 2


### as far as we know, it only lasts 24 hours. So 3


### I think I've got a great concern over where 4



### we're headed on this discussion. 5



### MR. BROOKMAN: Andrew? 6



### MR. deLASKI: I wanted to follow on 7


### to Keith and Mike. So, Mike, my understanding 8


### is that, because we talked before this, that 9


### you found a number of products in the DOE 10



### certification database that are certified to 11


### DOE today and t hen also just online in catalogs 12



### that have efficacies above the CSL 1. So these 13


### are not just the model that we

-- 14



### MR. MCGARAGHAN: Correct. 15


### Currently, commercially available products

-- 16


### MR. deLASKI: So I was puzzled

-- so 17


### I guess our question to th e Department is it 18


### seems like, in your own database, that there's 19


### a bunch of lamps that are higher than CSL 1, 20


### not just one or two but a bunch that are quite, 21


### if you put the plot up, you would see the dots 22

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### 175



### and there's quite a distribution. It looks 1



### like t here should be two or three more CSLs 2



### above there. 3


### So I guess the question is how old 4


### is your data? Why is that? What happened? Is 5


### there any explanation, do you have any thought 6


### what the explanation would be why you wouldn't 7


### have captured those lamp s that are

-- 8


### MS. PIERCE: Sure, yes. Well, for 9


### one, we will reassess this in the NOPR 10


### analysis. Another consideration is that we try 11


### to keep the baseline , or the CSL lumens within 12


### ten percent of the baseline. So we base the 13


### CSLs on what technology op tions can be used to 14


### achieve them, so we adjusted them for 15


### compliance based on the range of technology 16


### options that could meet that. So if you have 17


### suggestions for alternative technology options 18


### that could meet those higher levels, we would 19



### take those. 20


### MR. deLASKI: So by that last point, 21


### do you mean that you may have ruled out some 22

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### 176



### lamps because you thought they were proprietary 1


### technologies? 2



### MS. PIERCE: No. We believed that 3


### they were all at the max tech technology option 4


### level. They were HIR lam ps with improved 5



### reflectors. 6



### MR. BROOKMAN: Joe? 7


### MR. HOWLEY: And if I could just 8


### make some comments. We would disagree with a 9


### lot of these comments being made here. We 10


### don't believe there's this pie

- in

- the

- sky 11


### mystical technology out there that's g oing to 12


### triple the efficiency of these lamps. They are 13



### darn close to max tech right now. We believe 14


### this represents a very high efficiency level. 15


### What you're proposing is about where max tech 16


### was last time that you looked at it. Although 17


### there may be a couple more players in the 18


### market, the technology itself hasn't changed in 19


### the last three or four years or what you can do 20


### with it. And, certainly, this improved HIR 21


### does represent the highest technology class of 22

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### 177



### what we have today that has to meet many 1


### different customer requirements, have many 2


### different utilities, and address a lot of 3


### different needs in the marketplace. 4


### And as you're moving up even to this 5


### level, you're starting to strain several of 6


### these utility product class needs based on 7



### technical feasibility, economic feasibility. 8


### As you go up higher, you're basically cutting 9


### out lots of different market utility leading to 10


### the fact that you might end up with one product 11



### that works for one customer and one 12


### application, and that's the only thing th at's 13


### economically or technically feasible. 14


### So it's a lot more complex than 15


### what's being portrayed here. And you are 16


### proposing a very high level which I would 17


### suggest, we would even suggest where you're at 18


### right now is fine. You don't need to go any 19


### hig her. This, though, does represent kind of 20



### your max tech of what's available today that 21



### could cover across all the different market 22

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### 178



### needs. 1


### MR. BROOKMAN: Mike, do you want to 2



### go next? 3


### MR. MCGARAGHAN: I'll let Alex go. 4


### MR. BROOKMAN: Okay. Alex? 5



### MR. BOESENBERG: This is Alex 6


### Boesenberg, NEMA. Reading the previous rule, I 7


### didn't look it up myself but I'm told it was 8


### page 34096 in the Federal Register, I'll 9


### paraphrase here and there. Per IRL DOE will be 10



### determined the maximum max tech would 11



### incor porate the highest efficiency reflector 12


### halogen or coating filament design. Combining 13


### all three of these technologies simultaneously 14



### results in the max tech. However, because the 15


### only technology pathway to this level is 16


### dependent on a proprietary technol ogy, DOE did 17



### not consider this level further in its 18


### analysis. The level set by the last rule was 19


### as high as we could get, certainly at that 20



### time. 21


### So whether there are any 22

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### 179



### technological innovations that have happened 1


### since then is a valid point of discus sion. But 2


### each one would have to be given the same level 3


### of rigor regarding whether it's a feasible 4


### pathway or not. 5



### MR. BROOKMAN: Mike? 6


### MR. MCGARAGHAN: Yes, thank you for 7


### those comments. And I didn't mean to imply 8


### that it's simple. I think there are some 9


### complex issues. My point is that it's DOE's 10


### responsibility to look into those lamps and 11


### identify whether they're feasible or not. This 12


### lamp right here I think was $7 or something 13


### online. It's an MR16, so it's not a covered 14


### lamp. It's a smalle r form factor. It's 37 15


### watt equals 50. It's essentially one of the 2X 16


### products I'm talking about. It's not pie

- in

17



### the

- sky, it's not mystical. It's a 18


### commercially available product. 19


### Of course, it's not apples to 20


### apples. MR16 lamps have different desi gn 21


### parameters, coatings on the lenses and they're 22

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### 180



### low voltage. They're also, being a smaller 1


### form factor is often considered a challenge for 2


### designing lamps. So, in that sense, some of 3


### that might even out, and you could expect to 4


### see real high efficacies and higher diameters, 5



### as well. 6


### The prototype lamp that we developed 7


### last time, it's possible that we forgot to list 8


### its rated hours in our comment letter, which 9


### was our mistake. And there were a couple of 10


### things like that about the lamp, and DOE's 11



### resp onse was California Utilities did not list 12


### the lifetime of that lamp so we can't consider 13



### it. 14


### We would ask you to reach out to us 15


### and ask us that sort of question because we'd 16


### be happy to provide it was a 1,500

- hour lamp, 17


### and these products are out there . They're not 18



### so far off. So this doesn't cover the 19


### potential of the market, by any means. And if 20


### DOE needs help gathering data, we're happy to 21


### help gather data. 22

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### 181



### MR. BROOKMAN: Andrew? 1



### MR. deLASKI: On Joe's comment about 2


### utility impacts, absolutel y, you know, we've 3


### got to look at the utility impacts of going to 4


### higher standard levels. It doesn't mean you 5


### don't look at the levels, though. To me, the 6


### issue here is DOE, in every rulemaking that 7


### I've been involved in, tries to cover the 8


### space, the ef ficiency space. And then as you 9


### get to higher levels, if you have utility 10


### impact, the whole utility impact analysis, that 11



### has to be done. So sometimes that leads to 12


### different choices about product classes, but 13


### you don't cut off the analysis. This is not a 14


### proposed level. It's just a level for 15


### analysis. The level that's even here is not a 16


### proposed level. It's just a level for 17


### analysis. And we think it's important that you 18


### cover the entire space of

-- certainly what's 19


### available in the market and, as Mi ke suggests, 20


### even things that could be available. Max tech, 21


### typically, is something that, again, it's max 22

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### tech. The limitation is not market 1


### availability on max tech. But at a minimum, 2


### you need to cover what's available in the 3



### market and then look at th e good questions that 4


### are being raised by industry that, you know, 5



### doesn't meet the needs of the market or the 6


### utility impacts. And then that's part of what 7


### DOE is compelled to do. 8


### MR. BROOKMAN: Julie, go to the next 9



### comment box. Have we covered that? 10



### MS. PIERCE: I think so. 11


### MR. BROOKMAN: I think so, as well. 12



### Let's move on. 13


### MS. PIERCE: Okay. So we've touched 14


### on this, but, after identifying more 15



### efficacious substitutes for each of the 16


### baseline lamps, DOE developed CSLs based on the 17



### consider ation of several factors, including the 18


### design options associated with the specific 19


### lamps being studied, for example the use of 20


### infrared coatings for IRLs; the ability of 21


### lamps across wattages to comply with the 22

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### 183



### standard level of a given product class , and 1



### the max tech level. 2


### DOE used an equation that is a 3


### function of wattage to determine the CSL. To 4


### determine the coefficient of the CSL equation, 5


### DOE reviewed catalog data of commercially 6


### available lamps and their associated catalog

7



### rated efficacies. To establish final minimum 8


### efficacy requirements for CSLs, DOE analyzed 9


### publically available compliance data and 10


### adjusted the CSLs when necessary. As shown in 11


### the table, CSL 1 is 6.2 times the wattage to 12


### the 0.27 power. 13


### DOE requests comment on the CSLs 14



### und er consideration for IRLs. 15


### MR. BROOKMAN: Including design 16


### options, ability of lamps across wattages to 17


### comply, and max tech level. Steve Rosenstock? 18



### MR. ROSENSTOCK: Steve Rosenstock, 19


### EEI. The value that you showed inside 55, 20


### that's not adjusted for the spectrum diameter 21


### voltage, those are other values, correct? Or 22

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### 184



### is that, you know

-- that's just for, I'll say 1


### the baseline, the baseline lamp, that's just 2


### for the two and a half, standard greater than 3



### two and a half

- inch, less than 125

- volt lamp

-- 4


### MS. PIERCE: Right. 5



### MR. ROSENSTOCK:

-- before the 6


### scaling? And the follow

- up is the current 7


### number, is it 5.9 is the coefficient? 8



### MS. PIERCE: That's correct. 9


### MR. ROSENSTOCK: And this would go 10


### up to 6.2? 11



### MS. PIERCE: That's correct. 12



### MR. ROS ENSTOCK: And, again, based 13


### on your analysis, again, this is basically

-- 14


### and, again, based on what you showed before, 15


### this would be your consideration before the 16


### other analysis, before other things would be 17


### possibly considered, I'll say CSL 1 is equal to 18



### a max tech based on your current analysis? 19



### MS. PIERCE: That's correct. 20


### MR. ROSENSTOCK: Thank you. 21


### MS. PIERCE: Okay. And

-- oh, 22

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### 185



### sorry. 1


### MR. deLASKI: I'm trying to 2



### understand how

-- you based your analysis on 3


### products that are available in the marketplace. 4



### MS. PIERCE: Yes. 5


### MR. deLASKI: That's how you figured 6


### your CSLs. So then how did the design options 7


### play into that? Because you ask about design 8


### options here. I mean, how do you then use the 9


### design options to

-- what role do they play in 10


### your analysis going forward since all you did 11


### is look at a product that's there so

-- 12


### MS. PIERCE: That's, for example, 13


### the two baselines had distinct technology 14


### options. There was the improved halogen and 15



### the HIR and then the CSL 1 is based on an 16


### improved HIR. So if there are other technology 17


### options that we should consider, we would 18


### welcome comment going forward. 19


### MR. deLASKI: To get you beyond the 20


### products that you're observing in the market? 21


### MS. PIERCE: Right. 22

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### 186



### MR. deLASKI: Okay. 1



### MS. P IERCE: Okay. And issue 14, 2



### DOE invites comment on whether additional 3


### adjustments to the CSLs are needed to account 4


### for compliance requirements. 5



### MR. BROOKMAN: Comments on 6


### compliance requirements? I see none. 7


### MS. PIERCE: All right. Once DOE

-- 8



### M R. BROOKMAN: We do have one. 9


### MS. PIERCE: Oh, sorry. 10


### MR. BROOKMAN: Keith, please. 11


### MR. K. COOK: Just maybe so you get 12


### a feel for how big this impact is, for our 13


### products right now, to move it to this 6.2 14


### coefficient would actually result in 59 per cent 15


### of our products being eliminated from the 16


### market. And on the consumer channel, as it 17


### turns out, 81 percent would be eliminated. 18


### It's a huge impact, absolutely huge. 19


### MR. BROOKMAN: And that's your 20



### company? 21


### MR. K. COOK: Yes, just Philips 22

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### 187



### alone. 1



### MR. BROOKMAN: Steve Rosenstock? 2



### MR. ROSENSTOCK: Steve Rosenstock, 3


### EEI. So those are products that are compliant 4


### with the 2012 standard, so, basically, if the 5


### manufacturers did a long

- term investment, if 6


### they hadn't made their money within six years , 7



### oh, well. 8


### MR. BROOKMAN: Andrew? Well, Keith, 9


### do you want to reply? 10


### MR. K. COOK: No, Steve is 11


### absolutely right. And that is what our major 12



### concern is is we did invest millions of dollars 13


### in this technology in order to meet EISA's 14


### requirements to have products that met the 15


### phase

- out of tungsten filament incandescent, 16


### and now, all of a sudden, it's being 17


### potentially obsoleted with this rulemaking. 18


### It's just unbelievable. 19


### MR. deLASKI: So just to follow on, 20


### I think those numbers are, it makes sen se to 21


### me. That's kind of what I would expect. If 22

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### 188



### anything, it's a little higher than I, I'm 1


### sorry, a little lower than I would have 2


### expected. I'm surprised to hear that 41 3


### percent of the products are already above the 4


### minimum standard, so that's impress ive. You 5


### know, and that's why there's a manufacturer 6


### impact analysis and that's where a big part of 7



### the decision

- making in any rulemaking, and 8


### rightly so. 9



### MR. BROOKMAN: Joe? 10



### MR. HOWLEY: And that's a concern 11


### industry has, just about the speed of t his 12


### standard in back of the previous standard. 13


### We're only talking five and a half years, as 14


### was pointed out earlier, and that is, you know, 15


### makes it very difficult for manufacturers to 16


### recover investments in new technologies, even 17


### pushing up to their p rop ose d levels, let alone 18


### anything further. It has a severe and negative 19


### manufacturer impact when you have these 20


### rulemakings so close together. 21


### MR. BROOKMAN: Okay, thank you. 22

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### 189



### MR. deLASKI: Let me just follow on 1


### to that because that was being discussed when I 2


### came in this morning. I apologize for being a 3


### little bit late this morning. But my 4


### understanding is that DOE has a statutory 5


### obligation to do this rulemaking right now, so 6


### my reading of the law is that this is a 7


### statutorily required rulemaking, s o it's not 8


### discretionary for DOE to do any other schedule 9


### than what they're doing right now. 10


### MR. K. COOK: That was my original 11


### question. I don't think there's any time frame 12


### that this one had to occur right now. 13



### MR. deLASKI: I'll look at the 14



### statu te, but that's not my understanding. I'll 15



### take a look. EPACT 92 is still the law of the 16



### land, and the law

-- we can -- the law said you 17


### had to do it within a certain period of time 18



### after the last final rule. The last final rule 19



### was issued in 2009. That clock was triggered. 20


### This rulemaking is due now, according to the 21


### statute that your companies and our allies 22

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### 190



### worked out in 1992. 1



### MR. BROOKMAN: I think that we 2


### covered that this morning. Final comments here 3


### before we move on? Okay. 4



### MS. PIERCE: Okay. Once DOE 5



### determined CSLs for the representative product 6


### classes, it scaled the results to non

7


### representative product classes. For IRLs, DOE 8



### used a 15

- percent decrease from standard 9


### spectrum to modified spectrum, a 15.5 percent 10


### decrease from large d iameter to small diameter, 11



### and a 15

- percent increase for 120

- volt to 130

- 12


### volt lamps. These are the same scaling factors 13


### that were used in the 2009 lamps rule. 14



### MR. BROOKMAN: Steve? 15



### MR. ROSENSTOCK: Steve Rosenstock, 16


### EEI. Just out of curiosity, what kind of range 17


### did you see? 18


### MS. PIERCE: I'm sorry. I don't 19


### understand the question. 20


### MR. ROSENSTOCK: Range of decrease. 21


### What was the range, just out of curiosity? 22

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### 191



### MS. PIERCE: I still don't 1



### understand. 2



### MR. ROSENSTOCK: This is a median 3



### value or a mean value. What you're trying to 4


### say is, for the most part, when you're scaling, 5


### basically, because most of the lamps that are 6


### not analyzed will have a 15

- percent decrease in 7


### the efficacy. I'm just kind of curious about 8


### what was the range of decrease in efficacy that 9


### you saw. I'd like to know about the variance. 10



### Was it 14 to 16? Was it 10 to 20? Was it 5 11


### to 20, you know, 5 to 25? What was the range 12


### of the decrease that you saw? 13


### MS. PIERCE: So I would encourage 14


### you to look in the TSD. Each of these scaling 15


### factors had a different way that it was 16


### analyzed, so some were using test results, et 17


### cetera. So I would encourage you to look 18



### there. 19


### MR. ROSENSTOCK: Thank you. 20



### MR. BROOKMAN: Joe? 21



### MR. HOWLEY: So the results, Steve 22

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### 192



### and others, we, industry, originally asked for 1


### more leeway on the modified spectrum. Fifteen 2


### percent was settled on. And I think you have a 3


### note somewhere in here. I'm wondering why 4


### there's almost no modified spectrum lamps in 5


### the market today because that was barely e nough 6


### of a decrease to have that technology continue. 7



### The PAR20s have the same issue. I 8


### think there's a comment about why don't we 9



### st ill have PAR20s that are compliant. Again, 10


### this percentage decrease is barely enough of a 11



### decrease to continue to make compliant PAR20 12


### lamps due to difficulties in trying to fit 13


### halogen IR tubes into small PAR20 envelopes, 14


### which we also discussed in the 2009 rulemaking. 15



### The 130

- volt lamps, and we discussed 16


### this again in 2009, actually are less efficient 17



### than 120

- volt la mps. So when you apply a 15

- 18


### percent increase on a less efficient 19


### technology, you really don't have to ask why 20


### these products don't exist at all today. They 21


### have been pretty much wiped out by the 2009 22

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### 193



### rulemaking because we believe they're being 1



### corrected in the wrong direction, making it 2


### impossible to hit these levels. 3


### So if you're to increase this yet 15 4


### percent on top of already an unachievable 5


### standard, I'm not sure how you justify energy 6


### savings, given that there is no products in the 7


### marketplace t oday. So now I'm not sure what it 8


### is. You're 15 percent on top of a level that 9


### can't be met, so I'm not sure how energy 10


### savings are justified. Now it's just we're off 11


### into outer space and we just keep going out 12


### there, although there's no products that a re 13


### going to be made that ever meet these levels. 14


### So it just seems, it doesn't seem right, from a 15


### technology review standpoint. We'd disagree 16


### strongly with the 15

- percent increase for the 17



### 130

- volt lamps on top of a level that's already 18



### unachievable. 19



### MR . BROOKMAN: Mike? 20


### MR. MCGARAGHAN: Mike McGaraghan, 21



### California Utilities. I wanted to comment on 22

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### 194



### the allowance given to small

- diameter 1


### directional lamps. My read of DOE's analysis 2


### was that you compared a bunch of existing lamps 3



### on the market, small

- d iameter lamps to larger 4


### diameter lamps, and established that there was 5



### a 12

- percent difference. 6



### MS. PIERCE: That's correct. 7


### MR. MCGARAGHAN: And then you made 8


### an assumption that double

- ended burners could 9


### not be fit into those smaller lamps, and so y ou 10



### modeled the losses from double

- ended burners or 11


### single

- ended burners and added that. So I 12


### didn't understand why you would add those two 13


### together. To me, the original analysis, 14


### comparing small

- diameter lamps to larger 15


### diameter lamps, gave you a number. It was 12 16


### percent. So maybe I'll stop there and let you 17



### answer that. 18



### MS. PIERCE: Yes. So that 19


### comparison was done using lamps before the 2012 20


### standards went into effect, so they may not 21


### have been using halogen technology. We found 22

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### 195



### limited small

- di ameter lamps on the market now. 1

2



### MR. MCGARAGHAN: That doesn't answer 3


### the question of why you would add the losses 4


### from a single

- ended burner, once you've already 5



### established that there's a 12

- percent 6


### difference between large and small. 7



### MS. PIERCE: B ecause that 12 percent 8


### was with lamps without burners. 9


### MR. MCGARAGHAN: Okay. Okay. 10


### Second point here is that there are small

11


### diameter lamps with double

- ended burners. This 12


### is a Philips product currently on the market. 13


### It's an MR lamp, so it's even s maller than a 14


### PAR20, and it has a double

- ended burner in it. 15


### It could mean that the filter is, I'm sorry, 16


### the lens is clear, so you can see it. I can 17


### pass it around. This isn't a PAR20 lamp with a 18



### double

- ended burner. This one is in pre

19


### production righ t now. A manufacturer sent it 20


### to someone in my company, and I brought it to 21


### show today, but it's a PAR20 with a double

- 22

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### 196



### ended burner. So I can leave this with DOE if 1


### you would like to look at it, but double

- ended 2



### burners can fit in small

- diameter lamps. 3



### MS. PIERCE: Yes, that would be 4


### great. Actually, part of this request for 5


### comment, and we would like to get feedback from 6


### manufacturers, as well, if possible, is if our 7


### assumption that double

- ended burners cannot fit 8



### into small

- diameter PAR lamps is corr ect. We 9


### can't use the MR16 because that's out of scope, 10



### but we were curious to see what feedback there 11


### was on that, so thank you. 12


### MR. BROOKMAN: Any additional 13



### comment here? Andrew? 14



### MR. deLASKI: A follow

- up. I 15


### understand the MR16 is out of scope, but the 16


### burner in that would fit into that lamp. 17



### MS. PIERCE: Can the manufacturers 18


### speak to that? 19



### MR. BROOKMAN: Joe? 20



### MR. HOWLEY: It's a 12

- volt 21


### filament, which are much, much shorter than 22

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### 197



### 120

- volt filaments. 1



### MR. MCGARAGHAN: The other one is 2


### line voltage, and, yes, DOE can

-- actually, I 3


### could leave both of them, and you can take them 4


### apart and play with them. Yes, that's

-- I'll 5



### leave it there. 6


### MR. BROOKMAN: Okay. Final comments 7


### here? Okay. 8


### MS. PIERCE: Okay. Another part of 9



### this r equest for comment was DOE was unable to 10


### identify the specific UL safety standard 11


### mentioned by NEMA that requires a minimum 12


### distance between the halogen capsule and the 13


### glass envelope. DOE requests additional 14


### information on this UL safety standard, 15



### includ ing the standard number and minimum 16


### required distance. 17



### MR. BOESENBERG: This is Alex 18


### Boesenberg, NEMA. I'm still looking for that. 19


### I may have spoken in correctly about it being 20


### an issue of the glass envelope, you know, sort 21



### of the front half or the face of it. And it 22

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### 198



### may be that the issue, as raised to me, has to 1


### do with socket heating or the luminaire 2


### heating. The classic example would be every 3


### lamp you have at home with a screw

- based socket 4


### has a sticker on it that says 60 watts max or 5


### something like that. That has to do with heat. 6


### I'm now going down that road to see what I can 7


### figure out. 8


### MS. PIERCE: Okay. Thank you. 9


### MR. BROOKMAN: Okay. 10


### MS. PIERCE: Okay. DOE also 11


### generally requests comments on the overall 12


### methodology and results of t he GSFL and IRL 13


### engineering analyses. 14



### MR. BROOKMAN: I think we've 15


### received some global comment on the overall 16


### methodology and results. Additional comments 17


### here? No additional comments. Okay. Let's 18


### press on with product price determination. 19



### MS. P IERCE: Okay. Now I will 20


### discuss the product price determination. DOE 21


### estimated end user lamp prices directly, rather 22

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### 199



### than developing manufacturer selling prices, 1



### because GSFLs and IRLs are difficult to break 2


### down to discrete components and reverse 3


### engin eer. In its research, DOE found a range 4


### of end user prices that were dependent on the 5



### distribution channel used. 6


### To represent this range, DOE 7


### developed three discounts using lamp blue book 8


### prices. The low end lamp user prices are based 9


### on purchases t hrough state procurement 10


### channels. The medium prices are representative 11


### of purchases through large distributors or DIY 12


### stores. And high prices are based on internet 13



### retailers. 14


### Data for this analysis was gathered 15


### after the July 2012 standards required 16



### c ompliance. DOE also estimated end user prices 17


### for fluorescent lamp ballasts using the pricing 18


### information developed in the 2011 ballast rule. 19

20


### DOE requests comment on the 21


### estimated end user prices for GSFLs and IRLs, 22

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### 200



### as well as the methodology used to develop 1



### them. 2



### MR. BROOKMAN: Andrew deLaski? 3



### MR. deLASKI: So it looks like 4


### they're not going to show you the prices that 5


### you came up with in your slide, but they're in 6


### the materials for the TSD. So we tried to, the 7


### high prices on IRLs surprised us on how high 8


### they were, $23 I think in one case f or CSL 1. 9


### So we tried to corroborate those just through 10


### some internet searches, and we couldn't. So 11


### those high prices strike us as being too high. 12


### It also strikes us that, you know

-- 13


### I'm curious, you kno w. So the DIY, just the 14


### Lowe's, Home Depot, et cetera, is your medium 15


### case, yet there are these internet sales that 16


### are the high case, so who the heck is buying 17


### off the internet because I could buy from 18


### Lowe's and Home Depot off the internet, too. 19


### If you want to do an internet search, that's 20


### what you're going to get first if you're a 21


### consumer. And if you're commercial, hopefully 22

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### 201



### you're smart enough not to pay more. 1


### So I'm wondering what's this high 2



### channel? 3


### MS. PIERCE: Can manufacturers speak 4



### to th at? 5



### MR. BROOKMAN: Joe? 6


### MR. HOWLEY: I mean, all I can say 7



### is that DOE and the internet is a vast and wide 8


### place. DOE obviously found these prices. It 9


### doesn't surprise us they found these prices. 10


### We know that these lamps are sold in a myriad 11



### of d ifferent channels, which, you know, exist 12


### out there. So it probably represents a high 13


### point on those lamps, but some retailers, even 14


### small stores or internet, have set their own 15


### price points and can set very high price points 16


### on these products. It's not surprising to us 17


### the price levels they had. 18



### MR. deLASKI: So how would DOE 19


### weight those prices in your analysis? Have you 20


### thought about that yet? 21



### MS. PIERCE: Yes. So we used the 22

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### 202



### medium lamp price, and then we did 1


### sensitivities in the LCC analysis using high 2


### and low prices. 3


### MR. deLASKI: Okay. I mean, I'm 4


### struck by that, you know. I think you'd be 5


### careful about both the high and the low because 6


### I can't get the low price. That's a state 7


### purchase contract. The consumer certainly 8


### can't get that. And if a consumer is choosing 9


### that high price point, the consumer is making 10


### that, that's their choice. If I want to buy 11


### the new Stephen King novel, I can walk down to 12


### my local retailer near my house and pay $33, 13


### you know, the list price on the book. I c ould 14


### buy it from Amazon for 50 percent of that or I 15


### can go to Barnes and Noble now, I guess I can't 16


### go to Borders anymore, and get it for 30 17


### percent off. So I have all kind of prices I 18


### can pay for the new Stephen King novel, but if 19


### I'm choosing to pay tha t list price it's 20


### because I want to support my local bookseller 21


### who's my friend or something. I'm getting a 22

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### different value out of that is my point. So 1


### I'm suspicious of this high price in your 2


### analysis. 3


### However, my point, I guess, is that 4



### I think ve ry few lamps are being sold at that 5


### price would be my supposition, whereas at that 6


### low price a lot of lamps are being sold at that 7


### because those are big contracts. So I'm not 8


### quite sure how that, ultimately, should be 9


### weighted, but I would think that you should 10


### weight both that medium and that low price in 11


### the analysis. 12



### MS. PIERCE: So we'll look at the 13



### results of the LCC sensitivities more in the 14



### NOPR stage. 15


### MR. BROOKMAN: Charlie Stephens? 16


### MR. STEPHENS: Charlie Stephens. 17



### Just to add on to what An drew said, I don't 18


### think it calls for sensitivity. I think it 19


### calls for an attempt to weight the prices and 20


### come up with some sort of rational weighting 21


### for that, as he pointed out. I know where I 22

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### 204



### live, the state contract is available for every 1



### governmen t entity or semi

- government entity to 2


### buy with. And so Andrew is right, there's a 3


### lot of lamps go through those channels, and I 4


### think it's important that you give appropriate 5


### weight to the pricing that is actually used in 6


### the marketplace. 7



### MR. BROOKMAN: Okay, thank you. Did 8


### we cover ballast prices? I don't think so. 9


### MS. PIERCE: No. So in issue 18, 10


### DOE requests comment on the estimated ballast 11


### prices developed using the 2011 ballast rule. 12


### DOE also requests comment on the assumption 13


### that ballast pri cing does not change between 14



### low and normal ballast factor ballasts. As 15


### will be discussed in a few slides, DOE 16


### evaluated the effects of lighting controls on 17



### life

- cycle costs for GSFLs by examining impacts 18


### of dimmers on GSFLs. Therefore, DOE also 19



### estimate d end user prices for dimming ballasts. 20


### DOE requests comment on its 21


### determination that prices of dimming ballasts 22

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### 205



### are, on average, 120

- percent higher than prices 1


### of fixed light output ballasts. 2



### MR. BROOKMAN: Comments on ballasts, 3


### ballast prices? Mic hael? 4


### MR. MCGARAGHAN: Just a question. 5


### Did the ballast prices change in your standards 6


### case scenario versus your base case scenario? 7


### MS. PIERCE: Maureen can speak to 8



### that. 9


### MS. KIENLE: It's the same price. 10



### MR. BROOKMAN: No comments from 11



### manufa cturers on ballast prices? Too close to 12



### home. 13


### MR. K. COOK: Well, technically, 14



### we're not allowed to. 15


### MR. BROOKMAN: Yes, right, right. 16



### Mike? 17


### MR. MCGARAGHAN: Mike McGaraghan. 18


### Another question. In the portion of the TSD 19



### that discusses life

- cycl e cost analysis, 20


### there's a line item called installation cost, 21


### which I think is a roll up of the product cost 22

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### and the labor to install. Is there a place in 1



### the TSD where we can see that breakout 2


### specifically for each scenario, what was the 3


### assumed product cost and what was the assumed 4



### installation cost? 5


### MS. PIERCE: Yes, Chapter 7 has the 6


### product costs and Chapter 8 has the 7



### installation costs. 8


### MR. MCGARAGHAN: Thank you. Those 9


### are by your LCC scenario, though. 10


### MS. PIERCE: They may not be listed 11



### o ut for each scenario, but from the surrounding 12


### information you should be able to determine it. 13



### MR. BROOKMAN: Additional comments 14


### here? I'm going to suggest we take lunch. 15


### It's now 12:20, and we're a little behind 16


### schedule, maybe as much as a half an hour or 17


### more. But we'll make that up as we go along. 18



### It's no w 12:20. Do any of you not know where 19


### you're going in this building at this point? I 20


### think most of you are

-- down to the ground 21


### floor, about 100 yards in that direction. 22

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### (Whereupon, the for egoing matter 1


### went off the record at 12:20 p.m. and went back 2


### on the record at 1:23 p.m.) 3

4

5

6

7

8

9

10

11

12

13

14

15

16



### A

- F

- T

- E

- R

- N

- O

- O

- N S

- E

- S

- S

- I

- O

- N 17


### (1:23 p.m.) 18


### MR. BROOKMAN: Let's start back up. 19


### I hope you had a nice lunch. We are going to 20


### pick up where we left off with Julie, and I 21


### believe that's energy use. 22

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### MS. PIERCE: Yes. So now we will 1


### discuss the energy use and life

- cycle cost 2


### analysis. The purpose of the energy use 3


### characterization is to estimate the energy 4


### consumption of baseline and higher efficacy 5


### lamps. The results of this analysis are used 6



### in the LCC , payback period , and NIA analyses. 7


### Energy use is calculated as input power times 8


### operating hours. 9



### Various DOE sources were used to 10


### derive the operating hours, including the 11


### Lighting Market Charact erization and EIA's 12


### CBECS, RECS, and MECS data sets. Using these 13



### sources allows DOE to account for variation in 14


### annual operating hours across census divisions 15


### and large states by building type and lighting 16


### application. 17


### This table shows average annual 18



### op erating hours for GSFLs and IRLs in each 19


### sector. IRLs were not analyzed in the 20


### industrial sector since they have such a small 21



### market share in that sector. 22

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### 209



### DOE welcomes comment on the end use 1


### operating profiles for the lamp types covered 2



### under this rulem aking. 3



### MR. BROOKMAN: Steve? 4



### MR. ROSENSTOCK: Steve Rosenstock. 5


### Going back to the slide in terms of residential 6


### operation, especially for IRLs, you show 761, 7



### which I've seen other studies that that's seen 8


### that way, but the key issue is, since there's 9


### so many fixtures in typical residential 10


### applications, is what kind of diversity factor 11


### are you assuming for those IRLs in the home? 12


### MS. PIERCE: I'm not sure what you 13


### mean by diversity. 14


### MR. ROSENSTOCK: Suppose there's ten 15



### fixtures for the IRLs in th e home. How many of 16


### them are you thinking that are operating that 17


### will have these operating hours in the 18


### analysis? 19



### MS. PIERCE: So these are the 20


### average operating hours. The LMC provides data 21


### for IRLs broken down by room and building type. 22

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### 210



### And then w e used the EIA data sets to take a 1


### weighted average, so this was a weighted 2


### average value. 3



### MR. BROOKMAN: Charlie? 4


### MR. STEPHENS: Charlie Stephens. 5


### I'll get you some data probably next month from 6


### our field survey. We monitored 2,200 fixtures 7



### in the residential sector for energy use, and 8


### we surveyed 1,400 houses for exactly what type 9


### of technology is in what fixture type in what 10


### room in those houses. And so, hopefully, you 11


### can have at least some data to verify what you 12


### have up here. 13



### MR. BROOKMAN: Can you give us a 14


### flavor, an early snapshot? Are these anywhere 15


### in the ballpark? 16


### MR. STEPHENS: I can't right now. 17


### We're getting the report published here 18


### probably the first week of next month. It will 19



### be available on our website. And the database 20


### will be available with the raw data in it, 21



### cleansed of addresses, that has all the 22

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### 211



### demographics and everything that go along with 1



### it. 2


### MR. BROOKMAN: Great, thank you. 3



### Other

-- yes, Joe? 4


### MR. HOWLEY: Just another question 5


### about the analysis. 6



### MR. BROOKMAN: Are you on? 7



### MR. HOWLEY: I'm on. 8


### MR. BROOKMAN: Oh, okay. 9



### MR. HOWLEY: I’ll g et a little 10


### closer. Do these hours include any kind of 11


### analysis for dimming effects, or are these 12


### operating hours assuming sort of a full on 13


### position? 14



### MS. PIER CE: So the LMC actually 15


### accounts for occupancy sensors, so it would 16


### just be the on/off, and then we treat dimming 17


### in a separate analysis. 18


### MR. HOWLEY: Okay. So that's 19


### factored on top of this analysis. So they're 20


### on, but you don't have what state they' re on. 21


### The state that they're on is, like, how dimmed 22

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### 212



### or not dimmed they are. That's looked at in a 1


### different analysis? 2



### MS. PIERCE: Yes. 3


### MR. HOWLEY: Okay. 4


### MR. STEPHENS: I should probably add 5


### we're doing the same thing in the commercial 6



### sector right now, and I don't know if I can get 7


### you any data by the fall but we'll try to get 8


### you updated data from the commercial sector as 9


### quickly as we can. 10


### MS. PIERCE: Okay. 11


### MR. BROOKMAN: This is an important 12



### bit of data here. It would be useful if 13



### som eone could comment about what they think 14


### about these numbers, if anybody is in a 15


### position to do so. Joe? 16


### MR. HOWLEY: They look reasonable. 17


### MR. BROOKMAN: Okay. That's a 18


### start. Okay. Yes? 19



### MR. ROSENSTOCK: Steve Rosenstock , 20



### EEI

. T he industrial nu mber is interesting to 21


### me because industrial in the process area, I 22

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### 213



### mean the GSFL in the process area versus the 1


### office area, it's going to be, I think it 2



### should be a little bit more bifurcated than 3



### that. 4



### MR. BROOKMAN: Good. 5



### MS. PIERCE: DOE assesse d impacts on 6



### life

- cycle costs and payback periods in 7


### sensitivity scenarios where GSFLs and IRLs are 8


### operated on dimming systems. To develop annual 9


### energy consumption for these dimming systems, 10


### DOE used the system input power ratings as a 11


### result of dimming and the annual operating 12



### hours. 13


### DOE made certain assumptions to 14


### determine the system input power ratings. For 15


### GSFLs, DOE assumed a 33

- percent lamp and 16


### ballast lumen reduction, on average. The 17


### associated system input power reduction was 18



### calculated ba sed on characteristics of the 19


### dimming ballasts analyzed. DOE assumed that 20


### dimming does not change lamp lifetime for 21



### GSFLs. 22

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### 214



### For IRLs, DOE assumed a 25

- percent 1


### lumen reduction, on average, which corresponds 2



### to a 20

- percent reduction in wattage and a 3



### lif etime multiplier of 3.94. For IRLs, in 4


### addition to calculating LCC savings for 5


### individually dimmed lamps, DOE also assessed an 6


### LCC scenario in which a certain percentage of 7


### the population used dimmers: 29 percent for the 8


### residential sector and 5 percent f or the 9


### commercial sector. Lighting controls are also 10


### analyzed as part of the NIA. 11


### DOE requests comment on the dimmed 12


### GSFL systems analyzed, in particular the lamp 13


### types included in the dimming scenarios and the 14


### assumption that light output and input p ower 15


### scale linearly for dimming systems. 16



### MR. BROOKMAN: Pekka? 17


### MR. HAKKARAINEN: Pekka Hakkarainen, 18



### Lutron. I don't have comments on the 19


### fluorescent lamps. I have a couple of comments 20


### on the IRLs. The lifetime multiplier that you 21


### reported, 3.94, I believe is based on the 22

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### 215



### standard incandescent formula that's published 1


### in the IES handbook, for example, for reduction 2


### to 20 percent of wattage, 20

- percent reduction 3


### in wattage. 4



### I was a co

- author on a paper some 5


### years ago that we presented at IES that I'm 6


### happy to supply with our written comments. We 7


### think that the multiplier is lower for halogen 8


### PAR lamps, somewhere between three and four but 9


### not as close to four as you are indicating 10



### here. 11


### And then as far as the percentage of 12



### IRLs in the residenti al sector being on 13


### dimmers, I'm curious what the source of your 14


### data, what your source is for this number, the 15


### 29 percent number is. I think the Lighting 16



### Market Characteri zation say 25 percent, so 17


### maybe you have something else. 18



### MS. PIERCE: It's from th e Lighting 19



### Market Characterization , and we also added 20


### light sensors because we assumed that they had 21


### the same impact as dimmers. So we welcome 22

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### 216



### comment on that. It was 25 percent for dimmers 1


### and 4 percent for light sensors. 2



### MR. BROOKMAN: Steve Rosenst ock? 3



### MR. ROSENSTOCK: Steve Rosenstock, 4


### EEI. You know, with the sensors, it's not a 5


### dimming sensor, it's an on/off sensor, right? 6


### That's the other four percent? 7


### MS. PIERCE: No, I'm sorry. It was 8


### light sensors where

-- 9


### MR. ROSENSTOCK: Daylight s ensors? 10



### MS. PIERCE: Yes, yes. 11


### MR. ROSENSTOCK: Daylight sensors. 12


### MS. PIERCE: So the occupancy 13


### sensors are accounted for in the energy use 14


### profile. 15


### MR. ROSENSTOCK: Okay. And Steve 16


### Rosenstock, EEI. I'm surprised that, for the 17


### commercial sector, that five percent. I'm just 18


### surprised it's that low. I just figured that, 19


### especially in the commercial sector, I thought 20


### it would be higher, just so many conference 21


### rooms. A lot of areas where they'd be tend to 22

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### 217



### be a lot of dimmer control, so that number 1


### looked, seemed a little low to me. Again, I 2


### didn't do any studies, just from some of my 3


### experiences. 4


### MR. HAKKARAINEN: I don't have any 5


### independent data, Steve. But this may be 6


### reasonably accurate. 7



### MR. BROOKMAN: Joe? 8


### MR. HOWLEY: I think, perha ps, that 9


### was based on what has occurred in the past. 10


### Perhaps, five percent of these systems are 11


### dimmed. But going forward in the future, and 12


### I'm not sure how far you took this into the 13


### future, we expect a lot more fluorescent 14


### systems to be controlled and dimmed. Some of 15


### the building energy codes are requiring it in 16


### more and more spaces. Therefore, I think you 17


### shouldn't leave the five percent steady state 18


### over the analysis period. It should be an 19


### increasing number as these codes come into 20


### play. 21



### MR. BR OOKMAN: Steve? 22

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### 218



### MR. ROSENSTOCK: Steve Rosenstock , 1



### EEI

. E specially the next edition of ASHRAE, 2



### 90.1

- 2013, there are more requirements for more 3


### lighting systems to have control systems. 4

5


### MS. PIERCE: Yes, just to reiterate what 6



### she said. That's accou nted for in the NIA. So 7


### these are specific to the LCC, which is a one

8


### time consumer impact. 9



### MR. BROOKMAN: Pekka? 10



### MR. HAKKARAINEN: Pekka Hakkarainen 11


### from Lutron. Did you also take into account 12



### Title 24 in California that comes into effect 13



### next Jan uary where virtually every lamp in 14


### commercial installations is going to have some 15



### level of level control? 16



### MS. PIERCE: If it's accounted for 17


### in the LMC, then I did. But I didn't use it 18


### independently. They

-- 19



### MR. BROOKMAN: Mike? 20



### MR. MCGARAGHAN: Mike McGaraghan, 21



### California Utilities. That would not be 22

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### 219



### accounted for the LMC because that was passed 1


### after that document was published. 2


### MS. PIERCE: Okay. We'll look into 3



### that. 4


### MR. MCGARAGHAN: And then a question 5


### here. I see 29 percent of halog en IRLs in the 6



### residential sector will be on a dimmer and 5 7


### percent in the commercial sector. Did you 8


### present those numbers for GSFLs already and I 9



### missed them? 10


### MS. PIERCE: No. So in the LCC, we 11


### didn't do a population

- based GSFL analysis 12



### because of t he different types of dimmers used. 13


### We were only able to do it for IRLs. 14



### MR. MCGARAGHAN: I see. 15



### MS. PIERCE: But the NIA addresses 16



### GSFLs more. 17


### MR. MCGARAGHAN: Okay. And did you 18


### explain where you got the five percent from? 19



### MS. PIERCE: The LMC. 20


### MR. MCGARAGHAN: It specifically 21


### called out commercial sector reflector lamps? 22

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### 220



### MS. PIERCE: Yes. 1



### MR. BROOKMAN: Pekka? 2


### MR. HAKKARAINEN: Pekka Hakkarainen, 3


### Lutron. I did actually have a fluorescent 4


### comment. I forgot about that earlier. Sorry. 5


### In issue 20, you say that the light output and 6


### input power scale linearly for dimming systems. 7


### Not quite. They have an offset at the low end 8


### that accounts for the required electrode 9


### heating in the lamps, and that's typically a 10


### few percent of the total m aximum rated power. 11


### And then it's, more or less, linear from there. 12


### Thereon, you can draw a straight line between 13


### those two points, but it's not from zero. 14


### MS. PIERCE: Okay, thank you. 15


### MR. BROOKMAN: Thank you. Helpful. 16



### Joe? 17



### MR. HOWLEY: Yes , just one more 18


### thought, as this discussion is going on. Is 19



### that

-- for the GSFL, if the lumen per watt 20


### level is set such that you'd have to go to a 21


### krypton

- based lamp, in other words a heavier 22

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### 221



### fill gas to hit those levels, you would have to 1



### then start to reduce your national impact 2


### savings because what you would do at that point 3


### is eliminate the ability to control and dim 4


### them. Although the dimmers and controls may be 5


### forced to be in these buildings, none of them 6


### would work very well. So you would actua lly 7


### have negative savings nationwide due to lack of 8


### dimming if the standards went so high on a 9


### lumen per watt standpoint that you had to use a 10


### krypton

- based lamp to meet that standard. So 11


### you're at a tipping point here where, if you go 12


### too far, you're goi ng to have a negative impact 13


### on national energy savings. 14



### MR. BROOKMAN: Mike? 15


### MR. MCGARAGHAN: Mike McGaraghan. 16


### I'm just curious if there are studies or anyone 17


### could help break down that issue a little bit 18


### more, in a little bit more detail what the 19


### impact of going to krypton as a fill gas has on 20


### dimming. You said they won't dim well. Has 21


### this been published or tested, or is this sort 22

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### 222



### of empirical? Can you expand on that? 1


### MR. HAKKARAINEN: Pekka Hakkarainen, 2


### Lutron. There is a lot of, certainly , 3


### manufacturer testing that has been done. I'm 4


### not aware of any NEMA publication on this 5


### topic, so probably nothing that has been 6


### published. Keith, do you know? 7


### MR. K. COOK: No, and the problem is 8



### the same one that ENERGY STAR ’s running into. 9



### There's no standards right now for dimming, so 10


### there would not be anything published because 11


### there's nothing to compare to. 12


### MR. BROOKMAN: Thank you, Keith. 13


### MR. HAKKARAINEN: So just to 14


### clarify, the standards do exist for argon

15


### filled lamps for dimming purpos es but not for 16


### lamps that have krypton in them. 17



### MR. BROOKMAN: So that was Pekka. 18



### Now to Joe. 19



### MR. HOWLEY: Just manufacturer 20


### experience, we know that these issues occur 21


### because we get customer complaints when people 22

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### 223



### attempt to do this and they don't work 1


### properly, and we suggest they go back to an 2



### argon - based lamp in those applications. There 3


### are some applications where they do work okay, 4


### but we get into more questionable dimming 5


### whenever we have to put krypton in them and we 6


### try to control or dim th em. 7


### So it's not a, there's not a bright 8


### line here. It's kind of an application

- by

9


### application issue that we're running into. 10


### MR. BROOKMAN: Please say your name. 11


### That's not on. There ought to be a button 12


### there. There you go. 13



### DR . GARBESI: Hi. So Karina Garbesi 14



### from LBL. Just for clarification for the 15


### analysis, you referred a couple of times to the 16


### krypton having problems with dimming. Are 17


### there any other technologies in these low

18


### wattage lamps that we know of that do not have 19



### those kinds of problems, or is krypton really 20


### the only option there? You know of nothing 21


### else. Thank you. 22

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### 224



### MR. BROOKMAN: So for the record, 1


### Joe says that's the only option they're using 2


### right now, and he knows of nothing else. Alex? 3



### MR. BOESENBERG: Alex Boesen berg, 4


### NEMA. So I want to paraphrase or summarize 5



### what I heard from the different manufacturers I 6


### have present in the room about krypton and its 7


### effects is what I've heard, and I'll allow them 8


### to contradict me, is the lamps in the market 9


### are optimized for their performance if you want 10


### them to dim. To add any krypton, you start to 11


### lose performance, and the reason they don't use 12


### it is because they don't, it's a feature or 13



### whatever. Does that make sense? Customers 14


### want it to dim, so that's why they don't pu t 15


### krypton in them. 16


### MR. BROOKMAN: Okay. Mike? 17


### MR. MCGARAGHAN: Sorry. To make 18


### sure I'm clear on this, the manufacturers at 19


### the table here are not aware of any way to make 20



### a low

- wattage lamp that dims well; is that a 21


### simple way to say that? 22

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### 225



### MR. BR OOKMAN: Keith? 1


### MR. K. COOK: It's not quite that 2


### clear. I mean, the problem is is there is 3


### sometimes compatibility issues. You can have

- 4



### - typically, there's three things that would be 5


### involved. It's ballasted is one thing. We 6



### have issues between c ompatibility of the dimmer 7


### and the lamp itself, and so with certain 8


### dimmers you may end up possibly working in a 9


### certain environment in a certain application. 10



### We've seen cases where we take that exact same 11


### setup and put it into a different building, and 12



### i t wouldn't work. We can't explain it. We 13


### don't understand. But that's reality. That's 14


### the way it works. So in the first application, 15


### it may work perfect. You couldn't find anything 16



### better. 17


### So we're still trying to understand 18


### it ourselves, and that' s the reason we're 19


### working on all sorts of new specifications, 20


### trying to get our arms around it. But it's 21



### still kind of more art than science. 22

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### MR. MCGARAGHAN: And does the 1


### problem get worse as you go down in wattage, 2


### typically? 3



### MR. K. COOK: Yes. 4


### MS. PIERCE: Okay. Thank you. Now 5



### I will discuss the life

- cycle cost and payback 6


### period analyses. The LCC and payback period 7


### analysis is used to assess the impacts on a 8


### consumer due to potential energy conservation 9


### standards. The analysis is conducte d from a 10


### consumer's perspective and shows the cost of 11


### owning and operating the lamp over its 12



### lifetime. 13


### As indicated in the diagram, the LCC 14


### considers two components. One is first cost, 15


### which is the product price and installation 16



### costs. The other is t he operating cost of the 17


### lamp, which is discounted to the present value. 18


### When the standard level lamp 19


### lifetime is different from the baseline lamp 20


### lifetime, DOE also calculates a residual value 21


### for the remaining useful life of the lamp at 22

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### 227



### the end of the analysis period and subtracts 1


### this from the total LCC value. From this, DOE 2



### calculates the total life

- cycle cost for each 3



### standard level considered. 4


### The results are expressed as LCC 5


### savings, which are the baseline LCC value minus 6



### the standard level LCC value. The simple 7


### payback period is also calculated and reported. 8


### Now I will discuss some of the key 9


### inputs to the LCC model, such as electricity 10


### prices, installation costs, ballast lifetimes, 11


### and discount rates. DOE calculated average 12


### electricity pric es using EIA 861 data. DOE 13


### then applied electricity price trends from AEO 14


### to project future electricity prices. DOE used 15


### the 2011 ballast rule, RS Means, and the U.S. 16



### Bureau of Labor Statistics to calculate 17



### installation costs. DOE calculated ballast 18



### lif etimes in hours, which translated to 19


### approximately 12 years for the commercial 20


### sector, 11 years in the industrial sector, and 21


### 15 years in the residential sector. 22

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### DOE uses a discount rate to 1


### calculate the present value of expenses over 2


### the analysis peri od. For the commercial sector 3


### DOE calculated a discount rate of 5 percent, 4


### for the industrial sector 5.6 percent, and 5


### residential 5.2 percent. 6



### MR. BROOKMAN: Steve Rosenstock? 7



### MR. ROSENSTOCK: Steve Rosenstock, 8



### EEI. I know we've had these discussions 9


### before. Maybe because lighting products are 10



### low

- cost products, but it always seems 11


### fascinating to me that I see some of these and 12



### that a residential customer would have a lower 13



### discount rate than an industrial customer. It 14


### just kind of blows my mind som etimes just 15


### because of, you know, with lighting products, 16


### again, people, residential customers can pay 17


### cash, but if they decide to use any form of 18


### credit, any form of credit card, the nominal 19


### interest rate is going to be, typically, 10 20


### percent plus. 21



### An d, you know, I see these numbers, 22

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### 229



### and, again, maybe that's a weighted average 1



### because of cash versus credit transactions. 2


### But I always find it interesting when I see 3


### things like that where a pretty well 4


### capitalized industrial company will have a 5


### higher di scount rate than a residential 6


### customer of varying incomes and different 7


### credit card interest rates. Thank you. 8


### MR. BROOKMAN: Okay, thank you. 9


### MS. PIERCE: Okay. DOE is also 10


### considering a new method for calculating the 11


### average sales tax in the NO PR. DOE currently 12


### weights the sales tax by population but is 13


### considering changing the weighting to be based 14


### on the prevalence of building types within each 15


### sector. This would create a different weighted 16


### average sales tax value for each sector due to 17



### the likelihood of different types of buildings 18


### to be in certain areas of the country. 19


### DOE requests comment on this 20


### potential change for the NOPR. 21



### MR. BROOKMAN: Comments on the life

- 22

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### 230



### cycle cost analysis? 1



### MR. ROSENSTOCK: Steven Rosenstock, 2



### EEI. You kn ow, in certain areas of the 3


### country, there's local sales tax, as well. 4


### Like New York City might have a local

-- do you 5


### have some of that information, as well, in case 6


### there's like local, I'll say city or county 7


### taxes that go on top of the state sales taxe s? 8


### MS. PIERCE: Right now, we just 9


### weight it by state. 10



### MR. ROSENSTOCK: The reason I'm 11


### asking that

-- Steve Rosenstock, EEI

-- is that 12


### if you're starting to do this and let's say 13


### you're weighting however many commercial 14


### buildings in New York City, t hey're going to 15


### pay the city tax, as well as the state tax, on 16


### some of these issues. And then there might be 17


### other areas, especially urban areas with 18


### commercial buildings, that have the same 19


### scenario. So I don't mind this process. I 20


### don't mind the thoug ht behind this. But if you 21


### don't have the data on those local conditions, 22

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### 231



### then you might be missing some of the data. 1


### MS. PIERCE: If you have data for 2


### that, please submit it as a comment. 3


### MR. BROOKMAN: Do you think the 4


### state rate provides some sor t of a weighted 5


### average that would incorporate the cities? 6


### MS. PIERCE: I would think so, but 7


### I'm not familiar with how they derive those. 8


### MR. BROOKMAN: That would be my 9


### guess. Charlie? 10


### MR. STEPHENS: Charlie Stephens. 11


### Yes, I'm pretty sure ther e's some data out 12


### there. It's by county, which would be, you 13


### know, pretty close to what you're looking for. 14


### The other thing is this is where we get back 15


### to your pricing for things in the life

- cycle 16


### cost. If you're going to do the typical Monte 17



### Carlo on this thing, I'd like to reiterate the 18


### comments that Andrew and I were emphasizing 19


### this morning about getting a proper weight on 20


### the different low, medium, and high prices that 21


### you found out there, the right market weight, 22

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### 232



### because that will impact this life

- cycle cost 1


### analysis substantially. And so we still 2


### strongly recommend that you weight these 3


### pricings that you use. And I assume you're 4


### using markups and other such things, or are 5



### you? 6


### MS. PIERCE: We don't actually use

- 7



### - 8



### MR. STEPHENS: You're not using 9


### markups this time because

-- yes. But this is 10


### a hazard. I think you really need to do, if 11


### you're not going to use the typical 12


### methodologies, I think you really need to be 13


### very careful about data about who's paying, 14



### what fraction of the market is paying what 15


### price here, because when you go to do this 16


### analysis it's going to make a huge difference 17



### in how the results come out. 18


### MS. PIERCE: Okay. We'll consider 19



### that. 20



### MR. BROOKMAN: Additional comments 21



### on life

- cycle cost? 22

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### 233



### MS. PIERCE: There are more slides 1



### if

-- 2



### MR. BROOKMAN: Yes. Mike? 3


### MR. MCGARAGHAN: Mike McGaraghan, 4



### California Utilities. You mentioned that when 5


### a replacement lamp has a different remaining or 6


### a different useful life, you calculate a 7



### residual value. Is that identif ied in the TSD 8


### somewhere in each particular scenario what that 9


### residual value is, or is it folded in to the 10


### LCC chapter in such a way where you can't break 11



### it out? 12


### MS. PIERCE: So the equation is in 13


### Chapter 8. And if you go into the actual LCC 14



### model in Excel, I think you can figure it out 15


### that way. 16


### MR. MCGARAGHAN: Okay. Then one 17


### other question was you mentioned the cost of or 18


### the replacement cycle for ballasts, and I asked 19



### earlier about the cost of the ballasts. And 20



### sort of the follow

- up question is does the lamp 21


### rule being proposed here ever have any impact 22

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### 234



### on the ballast cost or the ballast lifetime or 1


### the assumed replacement schedule for the 2


### ballast to the consumer in any way? 3


### MS. PIERCE: I'll let my colleagues 4



### answer that one. 5



### MS. MCDONA LD: This is Ali McDonald. 6


### I don't believe that any lamp standard ends up 7


### impacting the lifetime of a ballast selected. 8


### Do you have a specific scenario you're 9



### concerned about? 10



### MR. MCGARAGHAN: Just that I 11


### understand that you're plugging in ballast 12



### rep lacement and ballast cost to your LCC, but I 13


### just want to make sure that those assumptions 14



### are the same in the standards case as the base 15



### case. 16


### MS. MCDONALD: They are. 17


### MR. MCGARAGHAN: Okay, thank you. 18


### MS. PIERCE: Okay. DOE uses several 19


### lamp pur chasing events in the LCC model. The 20


### first event is lamp failure in which a lamp 21


### fails and must be replaced. The second event, 22

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### 235



### ballast failure, is only for GSFLs and includes 1



### situations where the failure of the installed 2


### ballast requires a new lamp and b allast 3


### purchase. The third event is new construction 4



### and renovation where new fixture installations 5


### occur and are not restrained to the previous 6


### configuration. 7


### In the residential GSFL analysis, 8


### since the lamp lifetime is longer than the 9



### ballast lifetime for that sector, DOE assumes 10


### in the lamp failure event that GSFL consumers 11


### preserve their lamps when replacing a ballast 12


### and utilize the same lamps on the new ballast. 13


### DOE requests comment on how likely consumers 14


### are to exhibit lamp preserving behavior. 15



### MR. BROOKMAN: Joe? 16


### MR. HOWLEY: I guess I'll make the 17


### comment, or Keith can. But what we've been 18


### told is, often, when a ballast fails, it 19


### operates in a way that tends to chew up the 20


### lamp, and the lamp is not in good condition, as 21



### the ballasts don't typically fail in a nice 22

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### 236



### way, because they're trying to start the lamp, 1


### they're trying to do various things with the 2


### lamp, and it results in a lot of starts and a 3


### lot of damage to the cathodes. 4


### Often, the other thing that we 5


### recognize is when a light goes out, for a 6


### homeowner, the most likely thing they assume is 7


### that the light bulb needs to be replaced. They 8


### never assume the ballast has gone. In fact, 9



### most consumers don't even understand what a 10



### ballast is or that it's in that fixture. So 11


### they will go out and buy a new lamp and attempt 12


### to replace that first. Then, finding the new 13


### lamp doesn't light either, they'll go further 14



### to

-- and, often, at that time, they simply 15


### just buy a new fixture. There could be a few 16


### enterprising consumers that attempt to buy a 17


### ballast and change their ballast. Especially, 18


### perhaps, if they're in the lighting industry, 19


### maybe they would know enough to do that, or 20


### they're an electrician they would know enough 21


### to do that. But in many cases, consumers will 22

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### 237



### simply just then go to buying a new fixture to 1


### use with the new lamps that they've already 2


### bought. 3


### So they almost never would encounter 4


### the situation that you're referring to where 5


### they would keep these old lamps and change the 6



### ballast. That's a situation that almost ne ver 7



### occurs. 8


### MS. PIERCE: Okay, thank you. 9


### MR. BROOKMAN: Thank you. Mike? 10


### MR. MCGARAGHAN: Mike McGaraghan. 11


### In that comment box it says that in the lamp 12



### failure event

-- 13



### MS. PIERCE: Yes. 14



### MR. MCGARAGHAN:

-- you would assume 15


### they would preser ve their lamps and replace the 16


### ballast. Is that supposed to read in the 17



### ballast failure event? 18


### MS. PIERCE: No, it's in the lamp 19


### failure event because, in that case, we were 20


### trying to determine what the LCC would be if 21


### the lamp were able to live for its entire 22

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### 238



### lifetime independently of the ballast. So in 1


### the ballast failure event, you would replace 2


### the lamp and ballast. In the lamp failure 3


### event, you would just replace the lamp. 4



### MS. MCDONALD: This is Ali McDonald. 5


### We actually did this two different ways to try 6


### to get a range of results. And, you know, one 7


### of the ways is assuming that the lamp lives for 8


### its entire lifetime, even though you may be 9


### replacing the ballast. And so we did it both 10


### ways, and we're just asking for comment on 11



### whether one of these ways is actually a likely 12



### scenario. 13



### MR. K. COOK: What I think is 14


### confusing everybody is, if you look at the 15


### bullets up there, event two, the sub

- bullet 16


### says the failure of the installed ballast 17


### triggers a lamp and ballast purchase. In other 18



### words , the lamp is also purchased. But then in 19



### the box down below, that's not the case. 20


### That's where the confusion is arising. 21



### MS. MCDONALD: Sure. So when the 22

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### 239



### ballast fails, there's a new lamp and ballast 1


### purchase. And when just the lamp fails, 2


### there's j ust a new lamp purchase. That lamp 3


### lives for its entire lifetime, and so we 4


### assume, in that case, that the consumer is just 5


### replacing the ballast because, in the 6


### residential sector, it lives for 37, the lamp 7


### lives for 37 years, and so the ballast has to 8



### b e replaced over that course in time. 9


### MS. PIERCE: Right. So it's a 10


### question of, in that first event, do we cut it 11


### off when the ballast fails or when the lamp 12



### fails? 13


### MR. BROOKMAN: People are still 14


### giving me confused looks here. Keith, start us 15



### off

. 16



### MR. K. COOK: Well, down there where 17


### it says replacing a ballast and utilize same 18


### lamps on the new ballast. In other words, 19


### you're carrying over the lamps. That's where 20



### we're confused. 21



### MS. deBUTTS: I understand. It 22

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### 240



### could have been phrased bette r, yes. But we 1


### described all the scenarios we're asking 2


### comment on, so, hopefully, you can comment on 3



### the scenarios. 4



### MR. BROOKMAN: Steve? 5



### MR. ROSENSTOCK: Steve Rosenstock, 6


### EEI. Just to make things even more fascinating 7


### and interesting , is just be cause of the new 8


### lamp and the ballast standards, you know, for a 9


### majority of residential customers, myself 10


### included, is that they still have the T12 lamps 11


### with the magnetic ballasts in their home, so it 12


### makes things even more, you know, they can't 13



### use the T8 lamps with existing ballasts 14


### anywhere. Basically, if a lamp goes out, they 15


### might be forced to do the new fixture anyway, 16


### so it gets

-- I'm not trying to add another 17


### complication. It's just, especially in the 18


### early years of your analysis, 10, 15 years, 19


### whatever, there's still going to be the T8 20



### older ballast conundrum where the consumer 21


### isn't going to be able to find the replacement. 22

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### 241



### So that might steer the consumers towards the 1


### fixture replacement case anyway, regardless of 2


### whether it's just the lamp or the ballast. 3



### MR. BROOKMAN: Charlie? 4


### MR. STEPHENS: Yes, Charlie 5


### Stephens. I'm hoping we're going to have some 6


### data on this when we get into it, but our 7


### sense, initially, is that people, if what they 8


### have is a T12 fixture and the ballast goes out , 9


### what I do is I special order a rapid start 10


### ballast and go to a T8, but most people are not 11


### going to re

- ballast. They're going to go buy a 12


### new fixture. But it's likely to be a newer 13


### ballast and probably a T8 lamp if what they're 14


### getting rid of is a T12. 15


### When that happens and I still have a 16



### T12 or two or three or four fixtures in the 17


### house, I just set aside the lamp for another 18


### fixture until that ballast goes out. And then 19


### I do the thing again, and, hopefully, I'll run 20


### out of ballasts and lamps at abou t the same 21


### time. But at least I'm angling for that. 22

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### 242



### But I think a lot of people are 1


### going to go get a new fixture, and they're 2


### going to be using a newer lamp if what they 3


### started with is a T12. In our survey, about 10 4


### percent of the lamps in the reside ntial sector 5


### were linear fluorescent types. I can't tell 6


### you until the new data comes out next month how 7


### many were T12 and how many were T8s, but I 8


### think there is that segment out there for which 9



### it matters. 10



### MR. BROOKMAN: Brian? 11



### DR . GERKE: This is Brian Gerke from 12


### LBNL. Just to respond to those two comments, 13


### the issue of T12s leaving the market is handled 14


### in the NIA. The LCC only considers the 15


### products that meet current standards for the 16



### life

- cycle cost analysis, so it folds in later. 17



### MR. BROOK MAN: Okay, good. Keith? 18


### MR. K. COOK: A question. What are 19


### you assuming for the frequency of renovation? 20


### MS. PIERCE: It's just a matter of 21


### when the lamp and

-- well, can I get back to 22

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### 243



### you on that? I'm sorry. 1



### DR . GERKE: Frequency of renovatio n, 2


### we followed the ballast rulemaking so a fixed 3


### percentage of the stock in each year. I 4


### believe it was three percent renovation, which 5


### was the same as the stock modeling in the 6


### ballast rulemaking. 7


### MS. PIERCE: There we go. It was an 8


### NIA question. 9


### MR. BROOKMAN: Thank you, Brian. 10


### Okay. Mike, one more? 11



### MR. MCGARAGHAN: Is renovation 12


### synonymous with lighting retrofit in your 13


### analysis? 14



### MS. PIERCE: Yes. 15



### MR. BROOKMAN: Alex? 16



### MR. BOESENBERG: And Alex 17


### Boesenberg, NEMA. So one more tier on that 18


### series of questions. Does that mean they'll 19


### switch probably to a different technology, like 20


### from T12, T8, T5, et cetera, or you're just 21


### triggering a purchase? 22

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### 244



### DR . GERKE: Certainly, if they have 1


### T12s, they would have to switch at this point. 2



### For T8s and T5s, I'll get into that switching 3


### when I actually present. 4


### MS. PIERCE: All right. This table 5


### shows the range of results for four

- foot medium 6



### bi

- pin lamps on instant start ballasts across 7


### all sectors and lamp replacement systems for 8



### each CSL. For this product class, there are no 9


### lamp replacements in the lamp failure event at 10


### CSL 1 because there are no energy

- saving lamps 11


### available at that level. This is indicated by 12



### NR in the table. 13


### LCC results show positive savings, 14


### except for some resul ts in the residential 15



### sector. For all GSFL results, the results are 16



### the same for the ballast failure and new 17



### construction and renovation events since we 18


### assumed no spacing adjustments in the latter 19


### event. This is because the replacement systems 20



### were chos en such that the lumen output was 21


### within ten percent of the baseline system, when 22

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### 245



### possible. 1



### MR. BROOKMAN: Steve? 2



### MR. ROSENSTOCK: Steve Rosenstock, 3


### EEI. I'm going to refer back to the slide back 4



### on 43 that showed the baseline levels with 5



### different C SLs. And a few thoughts are coming 6


### out at me, is that you're showing no results 7


### for CSL 1, but CSL 1 is a candidate, so I think 8


### you really need to show the LCC savings. 9


### That's part of the analysis. And, yes, 10


### basically, the baseline and CSL 1 lamp have t he 11


### same nominal wattage and the same rated 12


### wattage. If there's no savings, there's no 13


### savings. And to say that that's NR, that is 14


### going to be a scenario for these lamps, and it 15


### is a candidate under this preliminary analysis. 16


### The other question, the oth er 17


### thought I had was, under CSL 2, one of the 18


### lamps, again, has the same nominal wattage and 19


### same rated wattage going into that existing 20


### fixture. So, again, there's probably not going 21


### to be, I don't think there's going to be any 22

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### 246



### energy savings because you have the same 1



### ballast with that CSL 2 with 95.4 rated 2


### efficacy of 95.4 lumens per watt, but you're 3


### showing positive LCC savings. 4


### I guess I'm extremely concerned 5


### because, number one, it seems like you're 6


### ignoring the analysis of a lamp failure for CSL 7


### 1, which is going to be a scenario if it 8


### becomes the standard and, number two, showing 9


### very positive savings for one of the technology 10


### scenarios in CSL 2, which is not going to 11


### provide any energy savings. So can you explain 12



### that? 13



### MS. PIERCE: Sure. So to address 14


### the first comment, we do provide results for 15



### CSL 1 in events two and three. And we consider 16


### all events in the LCC analysis. 17


### MR. ROSENSTOCK: But why aren't you 18


### showing any results

-- Steve Rosenstock, EEI. 19


### What about event one, which will happen for 20


### these lamps? 21



### MS. PIERCE: Because there was no 22

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### 247



### energy - saving replacement for

-- 1



### MR. ROSENSTOCK: But if that becomes 2


### a standard, it's still going to be an economic 3



### cost to the consumer. 4



### MS. MCDONALD: This is Ali McDonald. 5



### Steve, that NR is an acknowledgment that there 6


### aren't positive savings at that level. You 7


### don't have any energy savings. 8



### MR. ROSENSTOCK: But there are costs 9



### to the consumers. 10


### MS. MCDONALD: Okay. 11


### MR. BOESENBERG: Right. But zero is 12



### a number, not NR. 13



### MR. ROSE NSTOCK: Or it could be 14


### negative. 15


### MS. MCDONALD: Right, it would be 16


### negative. 17



### MR. ROSENSTOCK: So this is Steve 18


### Rosenstock, EEI. That should be shown in here 19


### because it is going to happen because, 20


### otherwise, then it's not counted, otherwise it 21


### might not be counted with event two and three. 22

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### DR . GERKE: This is Brian Gerke from 1


### LBNL. Just to allay any further concerns, we 2


### do consider all these possibilities in the NIA. 3


### So in the LCC, there's no energy

- saving 4


### alternative, but in the NIA, at that choi ce 5


### point, you can, if you are a consumer, choose 6


### something that doesn't save you any money. 7



### It's allowed. 8


### MR. ROSENSTOCK: That could happen 9



### in this scenario. If that is the standard 10


### chosen by DOE, you'll save in event two and 11


### three but you won't save in event one, but both 12


### will happen in the marketplace. So to only 13


### show the positive savings for event two and 14


### three and then ignoring the negative savings in 15


### event one is not doing a complete analysis. 16


### MR. BROOKMAN: We got it. 17



### MR. ROSENSTOCK: Sorr y. Thank you. 18


### MS. PIERCE: Okay. This table shows 19


### the range of results for four

- foot medium bi

20


### pin lamps on programmed start ballasts across 21


### all sectors and lamp replacement systems for 22

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### each CSL. Consumers purchasing higher efficacy 1



### four

- foot medium bi

- pin lamps for use on 2


### programmed start ballasts would experience 3


### positive LCC savings only for reduced wattage 4


### lamps. 5



### MR. BROOKMAN: Steve? 6



### MR. ROSENSTOCK: Steve Rosenstock, 7


### EEI. Same comment. Thank you. 8


### MR. BROOKMAN: Okay, thank you. 9



### Mike ? 10


### MR. MCGARAGHAN: Mike McGaraghan, 11



### California Utilities. There are a number of 12


### scenarios that aren't shown on your slide here 13


### but that are in the TSD when you start looking 14


### at individual replacement scenarios where DOE 15


### has assumed, in the standards ca se, there's an 16


### increase in installed cost and, yet, the 17


### operating cost is identical. 18



### MS. PIERCE: Correct. 19


### MR. MCGARAGHAN: It appears that 20


### it's the same equipment being installed in the 21



### base case as the standards case. I don't see 22

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### how you could end up with a more expensive 1


### replacement scenario, but you're using the 2


### exact same equipment. It's calculated to the 3


### penny the same energy or the same operating 4



### cost. 5



### MS. MCDONALD: This is Ali McDonald. 6



### That's a factor of the ballast factors that 7



### are ava ilable in program start. For instant 8


### start, there are a wide variety of ballast 9



### factors, and so we selected a ballast factor to 10


### pair with the lamp that would reduce energy use 11


### and have energy savings. For the programmed 12


### start systems, there were a select ion of low 13


### ballast factor ballasts, and so we ran into 14


### some instances where they were, the 32

- watt 15


### more efficient lamps were paired with the same 16


### ballast factor and so they had the same energy 17



### use. 18


### So, for instant start systems, we 19


### were able to identify lamp and ballast systems 20



### for the 32

- watt lamps t hat saved energy by 21


### choosing a lower ballast factor ballast to pair 22

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### with the lamp. And for programmed start 1


### ballasts, those same low ballast factor options 2


### weren't available. And so what we're showing 3



### ther e is we're pairing more efficient 32

- watt 4


### lamps with the same ballast factor, so we have 5


### the same energy consumption. 6


### MR. MCGARAGHAN: Thank you. 7



### MR. BROOKMAN: Yes, Pekka? 8


### MR. HAKKARAINEN: Pekka Hakkarainen, 9


### Lutron. What are we looking at? Se venty

- two, 10


### yes. The bullet point at the top says positive 11



### life

- cycle cost savings only for reduced 12


### wattage lamp replacements, so now I'm 13


### concerned, does this analysis take into account 14


### the probable increased use of dimming systems 15


### in the future, especiall y in new construction 16



### and renovation? And that would have the effect 17


### of not allowing the use of reduced wattage 18


### lamps and, therefore, the life

- cycle cost 19


### savings, as shown, would likely be lower here 20


### but greater if you take into account the total 21



### energy u se. 22

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### MS. PIERCE: So this table does not 1


### show that, but that is done as a sensitivity in 2


### Appendix 8B. 3



### MR. HAKKARAINEN: 8B. 4



### MS. PIERCE: Yes. 5



### MS. MCDONALD: I also want to

-- 6


### this is Ali McDonald. I also want to point out 7


### that we're identifying p otential levels here 8


### and putting forward results for them, but we're 9


### not proposing anything yet. You know, we'll be 10


### weighing the results, the benefits versus the 11


### burdens at the NOPR stage before we would 12


### propose a level. 13


### MS. PIERCE: Okay. This table s hows 14


### the range of results for the remaining GSFLs 15


### across all sectors and lamp replacement systems 16


### for each CSL. Consumers purchasing higher 17


### efficacy T5 or eight

- foot slimline lamps would 18


### experience positive LCC savings. However, 19


### consumers purchasing eigh t

- foot high

- output 20


### lamps would experience negative LCC savings. 21



### MR. BROOKMAN: Mike? 22

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### MR. MCGARAGHAN: Mike McGaraghan. 1


### Just a question on the selection of ballast 2


### factors. It looks like you used mostly 0.88 3


### and 0.87 and occasionally dropped to 0.77. 4


### Those are very common ballast factors. 5



### I also notice a bunch of 0.83s. Are 6


### those common in the market? Is that why DOE 7



### chose 0.83? 8



### MS. KIENLE: Yes, those are 9


### commercially available ballasts that are 10


### available in the market place. And if you 11



### no tice, too, those are particularly common for 12



### the residential ballasts. 13


### MR. MCGARAGHAN: Okay. So one 14



### comment on that. There were a number of 15


### scenarios where DOE dropped to 0.83 where it 16


### could have dropped to 0.77 and still stayed 17


### within five percent o f initial lumens. So I 18


### would recommend, rather than increasing light 19


### to go with the 0.83, in any scenario where you 20


### can stay pretty close with a 0.77, that you do 21



### that. 22

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### I also wondered if DOE had 1



### considered

-- I guess this is all lamp for 2


### lamp, so ther e is no scenario where you assume 3


### a delamp and going to a high ballast factor, 4


### 1.0 or 1.15, adding reflectors or any other 5


### kind of optimized retrofit scenario. 6



### MR. BROOKMAN: Brian? 7



### DR . GERKE: We didn't end up 8


### considering that explicitly in the NIA , but we 9


### did try to get a sense of the average ballast 10


### factor out there right now to account for that 11



### sort of decision that is made. 12


### MR. MCGARAGHAN: Okay. I'm more 13


### interested in seeing it in the LCC because 14


### there would be scenarios where you could 15


### opti mize cost

- effectiveness that might not be 16


### displayed here. 17



### MR. BROOKMAN: Steve? 18



### MR. ROSENSTOCK: Steve Rosenstock, 19


### EEI. I guess the issue with that is then now 20


### you're presenting much more, you know, new 21


### materials. Like if you're presenting 22

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### reflect ors, that adds another layer to the 1


### analysis that, you know, it may or may not be

- 2



### - again, as you broaden the analysis, you get 3


### so many more scenarios that it's really

-- you 4


### lose what's happening necessarily, possibly, 5


### with what's actually happening wit h the lamp 6


### efficacy so that you add reflectors or you're 7


### thinking about delamping, that can change your 8


### analysis so much that you go from a three

- lamp 9



### ballast to a two

- lamp ballast, maybe with 10


### tandem wiring. I mean, you get, you can get, 11


### easily, hundreds of installation scenarios 12


### where you can easily lose what's probably going 13


### to happen, whether it's new construction or 14



### retrofit market in terms of what's the most 15


### likely scenario for this lamp after a standard 16


### is put into place. I mean, obviously, those 17



### op tions exist, but you throw those in and then 18


### you just get all sorts of things. Well, why 19


### did you do it in the baseline? Some of those 20


### things could be applicable in the baseline, 21


### too. Hey, we can put the reflector or tandem 22

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### wiring with the baseline lamps , too. That 1


### would lower the savings. 2



### MS. MCDONALD: This is Ali McDonald. 3


### We do know that that's a possibility we didn't 4


### consider in this analysis, but we'd welcome any 5


### information you have about how common that is 6


### and what the most typical delamping scenario is 7


### so that we could possibly consider it in the 8


### next phase. 9



### MR. BROOKMAN: Charlie? 10


### MR. STEPHENS: Yes, Charlie 11


### Stephens. We might have some data on that. It 12


### is a pretty common scenario. If you include 13


### lighting retrofit as renovation, then this is 14


### one manner that that particular kind of 15


### renovation is done, and it's done fairly often. 16


### So we might be able to get you some data on 17


### that if I scrounge around a little bit. 18


### MR. BROOKMAN: Okay, thank you. 19



### Yes, Joe? 20



### MR. HOWLEY: Joe, GE. I w ould 21


### counter that it was a very typical situation 22

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### when people are moving from T12 to T8 systems. 1



### As this forward

- looking analysis is T8 to T8, 2


### I think it would be much less likely that 3


### people are going to move in this direction. 4


### But I agree, in the past, it has been. I just 5


### don't think it's going to be that common going 6



### forward. 7



### MR. BROOKMAN: Final comments here? 8

9



### MS. PIERCE: This table shows the 10


### range of LCC savings results for IRLs across 11


### all sectors. Consumers with the 1,500

- hour 12


### improved halo gen baseline have positive LCC 13


### savings, but consumers with the 3,000

- hour 14


### baseline lamp have negative savings. 15


### DOE requests comment on the 16


### likelihood that fixture spacing is adjusted 17


### during new construction and renovation if 18


### systems considered for inst allation all have 19


### similar lumen outputs. 20



### MR. BROOKMAN: Steve? 21



### MR. ROSENSTOCK: Steve Rosenstock, 22

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### EEI. We talked about this before, and, again, 1


### it's really, I'm not a lighting designer but, 2


### again, it's a matter of if there is so many 3



### foot candles r equired for the space, they will 4


### put in as many fixtures to meet that and also 5


### meet the, I'll say the ASHRAE lighting power 6


### density requirements in 90.1. And in the 7


### scenarios that you addressed, all of the system 8


### lighting outputs have lower lumens output in 9


### the system. So, therefore, there will be a 10



### need for more fixtures to maintain the same 11



### foot candles. 12



### MR. BROOKMAN: Joe? 13



### MR. HOWLEY: Yes. What's most 14


### likely to happen under the scenario where 15


### you're getting lamps, perhaps, that are newly 16



### avail able that you weren't expecting, if their 17


### lumen output is different, it's very unlikely 18



### that users would re

- space their fixtures. If 19


### you look in this room, you see a standard two

20


### by

- four grid that would be nearly impossible to 21



### re - space to take advantage o f, you know, a one 22

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### 259



### or two

- lumen per watt difference in the lamps. 1


### What most likely would happen, if 2


### somebody wanted to take advantage, if they 3


### could, of any energy savings, they, perhaps, 4


### would consider a ballast change, the ballast 5



### factor. But more lik ely, the ballast would 6


### still be fine, so here we're still going down 7


### to they'll just replace one lamp for another. 8


### The lumen difference isn't that great, so they 9


### wouldn't really, I don't see any scenario where 10


### they'd consider re

- spacing an existing 11



### buildi ng, which is where the majority of the 12


### products are used. 13


### MS. PIERCE: Thank you. 14



### MR. BROOKMAN: Other comments here? 15

16


### MS. PIERCE: Okay. DOE requests 17


### comment on the methodology and results of the 18


### LCC analysis. 19



### MR. BROOKMAN: Quite a bit of 20


### comments on the methodology so far. Alex? 21


### MR. BOESENBERG: Alex Boesenberg, 22

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### NEMA. I would just add, and we'll put it in 1


### our written comments, to amplify on Mr. 2


### Howley's statement, I hope the DOE and the 3


### analysts will bear in mind that spacing, it's 4



### no t tied just to light fixture output, but 5


### we're talking about two

- by

- four ceiling grids 6


### and everything else. The idea that spacing 7


### will be adjusted

-- if you're going to adjust 8


### it, it's got to be at least two feet, and then 9


### you've got to look at whether or not you can 10


### still meet lighting levels due to the changes 11


### in the fixture's performance. The spacing is 12



### where it is. You've hit this balance. There's 13


### a symbiosis between the manufactured ceiling 14


### materials, modular wire strings, and the 15



### fixtures and thei r performance. So it's all 16


### got to change. 17


### MR. BROOKMAN: Okay. Keith? 18



### MR. K. COOK: Keith Cook from 19


### Philips. The other thing that you need to also 20


### recognize is, in a lot of scenarios, if you're 21


### going to try and adjust spacing, that means 22

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### you're g oing to have to change the hangers for 1


### the lights, which means you're getting into the 2


### ceiling itself and there's still an awful lot 3


### of buildings with asbestos. They do not want 4


### to go there. 5



### MR. BROOKMAN: Charlie? 6


### MR. STEPHENS: Charlie Stephens. We 7


### must live in another planet or another market 8


### or something where we are because most of this 9


### stuff occurs during tenant improvement, and the 10


### ceiling is the first thing to go, all of it. 11


### And the lighting system is redesigned. It's 12


### brought in because t he tenant changed, and the 13


### people who are in the space are no longer the 14


### same people. 15


### Also, all the office furniture get s 16


### changed out. And sometimes the space is 17


### gutted. All the walls are knocked down, open 18


### floor plan. Lots of things get changed when 19


### the lighting system changes. Most of these 20


### things occur in the office

- type occupancy where 21


### the bulk of this stuff goes and a renovation is 22

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### 262



### occurring as part of a much larger renovation. 1


### And not just the ceiling goes, everything 2


### goes, including the people , the fixtures that 3


### are on the floor, the places where you're 4


### measuring your foot candles. Everything 5


### changes. And so you're starting all over in a 6


### lot of cases, and so what you're looking at 7



### here is a brand new ballast and a brand new 8


### lamp that will las t X number of years when it 9


### comes to renovation. And I doubt there's very 10


### much changed unless, or saved, I should say, 11


### unless you're bringing in T8 lamps and you can 12


### still use the same T8 lamps in a new T8 fixture 13



### with a different ballast. 14



### But other tha n that, I don't see 15


### much preserved when it comes to renovation. 16


### It's pretty much everything. 17



### MR. BROOKMAN: Pekka? 18


### MR. HAKKARAINEN: Pekka Hakkarainen, 19


### Lutron. Charlie, in your scenario there, the 20


### end result is, as far as I can judge, is not 21


### going t o be any different whether you have an 22

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### 263



### 89

- lumen per watt lamp or a 90

- lumen per watt 1


### lamp. You're going to have the same number of 2


### lamps and the same load. 3


### MR. STEPHENS: Except that you may 4


### have daylighting that you didn't have and you 5


### may have dimming fixtures and you have a whole 6


### different control system. And you probably 7


### will have a different spacing of fixtures 8


### because there's a different number of people in 9


### a different office configuration living in the 10


### place. So there's going to be, everything i s 11


### going to be redesigned, so I guess what I'm 12


### saying is it's like new construction. 13


### MR. HAKKARAINEN: Absolutely. And 14


### all of those other things are the result of 15


### those other design and technical changes and 16


### have nothing to do with the lamp standard. 17


### MR. BROOKMAN: Steve? Okay. Keith? 18

19


### MR. K. COOK: The other thing that 20


### you've got to recognize, too, is, even if you 21


### do have daylighting, you still have to be able 22

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### to provide lighting when there is no daylight. 1


### MR. BROOKMAN: Okay, or very little. 2


### Have we finished this segment? 3


### MS. PIERCE: I think so. Thank you. 4


### MR. BROOKMAN: Then we're moving on. 5


### MS. PIERCE: All right. I'll pass 6


### it on to Brian Gerke for the shipments and NIA 7


### analysis. Thank you. 8



### DR . GERKE: Hi, I'm Brian Gerke fr om 9


### Lawrence Berkeley National Lab. I'll be 10


### telling you about the shipments and the 11


### National Impacts Analyses for this rulemaking. 12


### So in the shipments analysis, DOE 13


### estimates the shipments of GSFLs and IRLs that 14


### will occur during the 30

- year analysis per iod 15


### for this rulemaking, which runs from 2017 to 16



### 2046. The NIA then estimates the nationwide 17


### impact of the potential new standards over that 18


### period. 19


### In particular, we compute the 20


### national energy savings, or NES, potential 21


### standards achieved for product s shipped during 22

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### 265



### the analysis period. A positive NES, in this 1


### case, indicates a positive net savings of 2


### energy. We also compute the net present value, 3


### or NPV, of those savings, less any additional 4


### consumer expenditures that accompany the new 5



### standards. A positive NPV represents a net 6


### savings to U.S. consumers. 7



### To summarize the main results of the 8


### NIA, as shown here, the preliminary analysis 9


### for GSFLs projects that both of the candidate 10


### standard levels will lead to a positive total 11


### national energy savin gs in the range of several 12


### quads of energy savings over the 30

- year 13


### analysis period and a positive NPV in the range 14


### of several billion dollars of savings to 15



### consumers. 16


### For IRLs, the preliminary analysis 17


### indicates that any candidate standard will have 18



### pos itive energy savings but, depending on the 19


### discount rate assumed, may have a negative NPV, 20


### implying a net cost to consumers. 21



### MR. BROOKMAN: Steve? 22

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### 266



### MR. ROSENSTOCK: Steve Rosenstock, 1


### EEI. For the GSFLs, that also incorporates the 2


### assumption that the re is no lamp replacement 3



### for CSL 1? 4



### DR . GERKE: No, all options are 5



### available in the NIA. 6


### MR. ROSENSTOCK: But how could you 7


### do it if it already said that there was no 8



### calculation of it or no estimate of the

-- 9



### MS. MCDONALD: This is Ali McDonald

. 10


### The LCC was looking at energy

- saving 11


### replacements, and the NIA considers situations 12


### where consumers may not save energy. 13


### MR. ROSENSTOCK: Okay, thank you. 14



### DR . GERKE: So the shipments 15


### analysis and the NIA consider the following 16



### candidate standards cases because there is only 17


### one CSL for most of the product classes and two 18



### CSLs for the four

- foot medium bi

- pins. We have 19


### an all CSL 1 standard case where everything is 20



### held at a CSL 1 standard level and a max CSL 21


### standard in which everything is taken t o its 22

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### 267



### maximum CSL which, in this case, in practice, 1


### means that you take four

- foot medium bi

- pins to 2


### CSL 2 and hold everything else at CSL 1. 3


### Moving on to the details of the 4


### shipments analysis. It's made up of three 5


### interacting modules. The lighting dem and 6


### module estimates the total demand for lighting 7


### service to be filled by new shipments in each 8


### year of the analysis period, so the total 9


### lumens that you need in new lighting shipments. 10



### The consumer choice module estimates the 11



### market shares of the differ ent product classes 12


### and efficacy levels in each year of the 13


### analysis period. And the price learning module 14


### projects future prices of lamps and ballasts. 15


### It interacts very closely with the other two 16


### because the prices impact the consumer choice 17



### model, and the shipments impact the price 18



### trends. 19


### And I should point out, at this 20


### point, that in the price learning module, the 21


### price learning is not applied to the portion of 22

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### 268



### the GSFL price that comes from rare earth 1



### elements. And I'll talk a little bit more 2



### abo ut how we incorporated the rare earth 3



### elements later. 4


### MR. BROOKMAN: Charlie Stephens? 5


### MR. STEPHENS: Charlie Stephens. 6


### Did you, could you or did you or would you 7


### account for technology shifts in your shipments 8



### model for IRLs? 9



### DR . GERKE: How do yo u mean? 10


### MR. STEPHENS: Well, for instance, 11


### when the cost curve for LED, you know, for 12



### solid

- state lighting and for incandescent IRLs 13


### cross, does your shipment model account for 14


### that possibility? 15



### DR . GERKE: Right now

-- I'll get to 16



### LEDs in a minute. R ight now, they're included 17


### as sort of an external envelope based on other 18



### estimates of the LED because the LED is not 19


### part of the scope of this rulemaking, so we 20


### just used an external estimate of what the LED 21


### shipments will do. But they are allowed to eat 22

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### 269



### into the demand for IRLs and GSFLs. 1


### MR. STEPHENS: Okay. That's what I 2


### was curious about. Thank you. 3



### DR . GERKE: So this is a schematic 4


### diagram showing the elements of the shipments 5


### analysis. It takes inputs from the engineering 6


### analysis, the prod uct price determination, and 7


### the energy use characterization. There is some 8


### summarization of those inputs to make the 9


### modeling more tractable. The three modules I 10


### just discussed are then used in concert to 11


### project the shipments of products over the 2017 12


### to 2046 period. 13


### Getting to the answer to the last 14


### question, this shows the projection from a 15



### recent solid

- state lighting report from DOE of 16


### the lumen capacity that will be needed or that 17


### is expected to be fulfilled by LEDs. So the 18



### overall curve here sho ws the total projected 19


### lumen capacity that will be needed for 20


### applications that are currently fulfilled by 21


### GSFLs and IRLs based on projected growth in 22

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### commercial and residential floor space. 1


### And the blue region is the portion 2


### of that demand that's proj ected to be fulfilled 3


### by LEDs in each year of the modeling period. 4


### In this preliminary analysis, as I said, we 5


### treat that as an exogenous envelope on the 6


### total shipments of GSFLs and IRLs. 7


### We then considered the remaining 8


### demand, which is the two gree n wedges there, to 9


### determine the total new shipments that were 10


### necessary to fill demand for GSFLs and IRLs. 11


### MR. K. COOK: Why do you show a 12


### continuation of GSFLs and IRLs? Why wouldn't 13


### the LEDs eventually take over the entire 14



### market? 15



### DR . GERKE: The projection from the 16



### recent solid

- state lighting report is they get 17


### up to something like 70 to 80 percent of the 18


### market shares, so we use that as the envelope. 19


### I can't speak to the details of that. 20



### MR. K. COOK: You can't forecast 21


### without that part of it , do you think? 22

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### MR. BROOKMAN: That was Keith. 1



### DR . GERKE: Yes, so we had to fit a 2


### curve to that, a market adoption curve, but it 3


### does seem, from the trends that were in that 4


### forecast, that it's maxing at about 80 percent. 5


### We can certainly

-- 6



### MR. K . COOK: Without the 2030 in 7



### their forecast. 8



### DR . GERKE: Yes, it's true. It only 9



### goes out to 2030 in the forecast, as you 10


### mentioned. It is flattening out by that 11


### period, though, and so we fitted a logistic 12



### curve. 13



### MR. K. COOK: So it's not their 14



### assu mption, it's your assumption as to why it 15


### continues. And I guess I'm trying to 16



### understand that. 17



### DR . GERKE: Right. So we fitted a 18


### logistic curve to it, which is a standard curve 19


### for adoption of new technologies in the market. 20



### And the best fit that w e had to the best 21


### forecast that we had showed it flattening it 22

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### 272



### off at 80 percent. We don't really have, we're 1


### not in a position to do a better forecast than 2



### that. 3



### MR. BROOKMAN: Steve? 4



### MR. ROSENSTOCK: Steve Rosenstock, 5


### EEI. Again, I'm going to as k questions about 6


### the graph. I didn't look for the numbers in 7


### the technical support document. Again, I'm 8


### looking at this

-- so, basically, again, if I'm 9


### looking at this graph correctly, I'll take the 10


### two technologies separately, for IRLs, it 11


### basically, i f I'm reading this correctly, it 12


### appears that, I'll say by 2031 the LEDs have 13


### pretty much displaced the IRLs. Is that

-- 14



### DR . GERKE: The overwhelming 15


### majority. There's a little bit still hanging 16



### around in

-- 17



### MR. ROSENSTOCK: For both new and, 18



### that's new and existing construction, correct? 19


### New buildings and

-- 20



### DR . GERKE: Yes. 21



### MR. ROSENSTOCK:

-- existing? And 22

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### then for the, again, same question for the 1


### fluorescent lamps, and I'll say it by 2031. 2


### I'll say 15 years in the future after a 3



### standard or NOPR that the LEDs have replaced 4



### almost like two

- thirds of the fluorescent lamp 5


### fixtures in new and existing construction? 6



### DR . GERKE: It's a bit more than 70 7



### percent. 8



### MR. ROSENSTOCK: Seventy percent. 9



### DR . GERKE: So this is a fraction of 10


### the ship ments in each year. 11


### MR. ROSENSTOCK: Right. But the 12


### shipments go to new and existing buildings? 13



### DR . GERKE: Yes, right. But it's 14


### not necessarily, this is not necessarily a 15



### fraction of the total stock of fixtures that 16



### are installed. 17



### MR. ROSENSTOCK: Okay. 18



### DR . GERKE: Things get installed, 19


### and they stay around for a long time. This is 20


### the fraction of the shipments in each year. 21


### MR. ROSENSTOCK: So you're saying 22

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### 274



### that people will replace the GSFL shipments 1


### with the LED shipments? 2



### DR . GERKE: Yes. 3


### MR. ROSENSTOCK: Okay. For

-- 4



### DR . GERKE: That's the projection

-- 5



### MR. ROSENSTOCK:

-- both existing 6



### and

-- okay. Again, I'm just trying to, you 7


### know, because this graph is saying, you know, 8


### quite a few things. So in all the analyses, so 9


### in, I'll say the life

- cycle cost analysis and 10


### the National Impact Analysis and the NPVs, 11


### then, basically, the savings are basically zero 12


### for IRLs by 2031? 13



### DR . GERKE: It's not quote zero, but 14


### it's quite low. 15


### MR. ROSENSTOCK: The graph shows 16


### zero IRLs, if I'm reading it correctly. 17



### DR . GERKE: This graph? It's very 18


### small. It's very small compared to GSFLs, so 19


### you can't really see it. But there's still 20


### something there. It's not zero. 21


### MR. ROSENSTOCK: Okay. 22

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### DR . GERKE: Yes, that wedge doesn't 1



### go to zero

. 2



### MR. ROSENSTOCK: But do the other 3


### impacts assume that the standard will, any 4


### impact of the standard is reduced by, I'll say 5


### 90 percent by 2031? 6



### DR . GERKE: In the main analysis, 7


### that's true. I'll get into this in more detail 8



### later on. We do consi der a scenario in which 9


### there's no LED growth to see how that large 10


### that impact is. 11


### MR. ROSENSTOCK: Okay. And then, 12


### again, the same question for the fluorescent. 13


### You're assuming that, basically, whatever the 14


### standard is going to be, that 70 percent o f the 15


### savings are pretty much, I'll say disappear 16


### because the LED incursion by 2031. 17



### DR . GERKE: We believe that's the 18



### best estimate of future trends. 19


### MR. ROSENSTOCK: Okay. Again, I'm 20


### trying to get a sense for my comments. Thank 21


### you very much. 22

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### MR. BROOKMAN: Charlie Stephens? 1


### MR. STEPHENS: Charlie. I just, 2


### mathematically, I would remind people that, at 3



### a seven - percent discount rate especially, 4


### anything after year 20 is nearly meaningless 5


### anyway. So it doesn't have much of a dollar 6


### impact on an y of the NPV. Nothing does at a 7



### seven - percent discount rate after year 20. 8


### MR. BROOKMAN: Okay, thank you. Did 9


### you wish to comment now? Okay. So yes, Mike? 10


### MR. MCGARAGHAN: Just real quickly, 11


### what is the name of this report that this came 12



### from and do you know if there's numbers behind 13


### it? Apart from this graph, can you see the 14



### detail? 15



### DR . GERKE: Yes, it's DOE's solid

16


### state lighting report. I'm not sure what the 17


### actual title of it was. It was, I think, the 18


### most recent SSL report or, perhaps, two years 19


### ago. Karina, do you know exactly which one? 20



### DR . GARBESI: It's cited in the TSD 21


### in Chapters 9 and 10, so you'll find it. It's 22

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### 277



### prominent. 1


### MR. MCGARAGHAN: Thank you. 2


### MR. BROOKMAN: Okay. 3



### DR . GERKE: So with the demand for 4



### GSFLs and IRLs determined in each year, we then 5


### used this consumer choice model to project the 6


### market shares of the different product classes 7


### and efficacy levels and apportion those 8


### shipments among the different options. 9


### We use an econometric logit model to 10



### com pute the probability that a consumer will 11


### select a particular product based on its price 12


### and its operating and maintenance costs. The 13


### O&M costs in this case include both the energy 14


### costs and, in the case of IRL, the cost of 15


### purchasing additional lamps for shorter

16


### lifetime products. 17


### In the case of relatively new 18


### technologies

-- so the logit model is shown on 19


### the right of, on your left. In the case of 20


### relatively new technologies, like T5s and the 21


### more advanced IRLs, we also incorporate a Bass 22

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### 278



### adoption cur ve which is a standard model for 1


### consumer adoption of new and unfamiliar 2


### technologies. This is just to ensure that 3


### these new technologies aren't forecast to reach 4


### higher market shares than is actually 5


### realistic, given typical consumer behavior in 6


### adopting new technologies. 7


### Oh, importantly, although it's not 8


### shown in this diagram, we also include some 9



### factors that limit the maximum market share 10


### that certain options can attain, such as low

11


### wattage lamps, which we understand have limited 12


### utility in certain applications. So there's 13


### what's called an acceptance factor that sort of 14


### puts a cap on the total market share that some 15


### of these technologies can achieve. 16


### There's also this price learning 17


### module. The plot shows the inflation

- adjusted 18


### price of GSFLs, hi storic GSFLs, historically, 19


### as a function of cumulative production. So 20


### cumulative shipments on the horizontal axis, 21


### value per unit on the vertical axis. This is 22

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### 279



### from the Census Bureau. 1


### In the shipments analysis, we fit a 2


### smooth power law curve to this data. That's 3


### called, by economists, either a learning curve 4


### or an experience curve. And we use that to 5


### project the future price declines that we 6


### expect to occur as shipments, cumulative 7


### shipment production continues to rise. As I 8


### mentioned earlier, that sets aside the question 9


### of the rare earth elements, which we consider 10



### later on. 11



### MR. BROOKMAN: Steve Rosenstock? 12



### MR. ROSENSTOCK: Steve Rosenstock, 13



### EEI. I've made comments in this area before. 14


### Are you assuming that GSFL, after its new 15


### standard, will be on the left side of the curve 16


### or the right side of that curve? 17



### DR . GERKE: It will continue to 18



### decline as

-- 19


### MR. ROSENSTOCK: No, your starting 20


### point, though. Are you assuming that it's the 21


### left side of the curve or the right side of the 22

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### 280



### curve f or your analysis? 1



### DR . GERKE: Your right. 2


### MR. ROSENSTOCK: The right side? 3



### DR . GERKE: Yes. 4


### MR. ROSENSTOCK: Okay. The reason I 5



### mention that is because I've seen other 6


### documents from DOE that, even with mature 7


### products, that the price declines kee p going on 8


### forever, that they never reach a minimum cost, 9


### which is totally not true, especially in the 10


### case of fluorescent lamps. 11


### And a thing I really worry about is, 12


### you know, your GSFL is a separate analysis. 13


### Why isn't it incorporated into the lack of a 14


### learning curve? In other words, the price is 15


### going up, even though GSFLs have been around 16


### for 70 years. I think that, I think there's a 17


### presumption that the cost of manufacturing and 18


### the cost to the consumer always go down. Well, 19


### that's just not t rue, especially for this 20


### product when the price has been going up, 21


### especially if a regulation forces rare earth 22

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### 281



### materials which dramatically increase the 1


### price. 2


### So, again, this is just, I think 3


### there's some issues here where there's always a 4


### presumptio n that cost will always go down, and 5


### that's just not true, especially in this case. 6


### MR. BROOKMAN: Okay. Joe? 7


### MR. HOWLEY: My comments are in a 8


### similar vein in that the rare earth analysis 9



### should not be set aside and done later. The 10



### rare earth ana lysis should be part and parcel 11


### and key to this because, as we're learning more 12


### about critical materials, when a material goes 13


### critical, in other words there's a supply and 14


### demand imbalance, it tends to stay critical for 15


### a long period of time, which means that we're 16


### not done with the rare earth issue, certainly 17


### not over this analysis period. And you should 18


### assume continued price spikes throughout this 19


### analysis period where the cost will potentially 20


### go higher and higher, not lower and lower. So 21



### this is exa ctly the wrong analysis. 22

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### 282



### MR. BROOKMAN: Thank you. Keith? 1


### MR. K. COOK: Yes, I was going to 2


### say the same thing. But the other factor is 3


### the fact that this also is assuming business as 4


### usual and, in reality, with the new 5


### technologies, like LEDs, comin g onboard, we're 6


### no longer focusing on price and cost reduction 7



### of these activities. Those resources are 8


### devoted now towards reducing the cost of LED 9


### products, and so it's no longer business as 10


### usual. So price declines will not be 11


### happening. 12



### MR. BROOK MAN: Okay, thanks. Joe? 13



### MR. HOWLEY: Yes. One other comment 14


### is that the projection is for the volumes of 15


### these products to go down as they're supplanted 16


### by LED technology, which means that we're not 17


### going into an increasing cumulative shipment 18



### pattern , we're actually going into a regressive 19


### pattern, which will also further increase 20


### prices as volumes go down and economies of 21


### scale are lost in this product line. 22

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### 283



### MR. BROOKMAN: Okay. Charlie? 1


### MR. STEPHENS: Charlie Stephens. I 2


### mean, personally, I'm not overly concerned 3


### about it since, as I see that curve, for GSFLs 4


### anyway, it's nearly flat as it is. I mean, 5


### it's so flat as to figure it will be horizontal 6


### by the time you hit 14 billion or so shipments. 7

8


### So I think your assumptions are not 9



### terribl y -- rare earth excepted. But, there, 10


### volatility, I think, is a word, but there's 11


### also disruptive things that can happen in that 12


### market where a manufacturing plant is uprooted 13



### and moved to where the rare earth materials are 14


### and the problem changes a littl e bit. It may 15


### not go away, but it changes. That's already 16



### been done for a number of manufacturers. 17


### So I think, based on what I see 18


### here, something nearly flat for GSFLs is 19


### appropriate, which is where you are at this 20


### point as you project out. So I'm co mfortable 21



### with that for now. 22

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### 284



### MR. BROOKMAN: Keith and then to 1



### Karina. 2


### MR. K. COOK: Yes, we'd like to 3


### recommend maybe that DOE talk to Dr. Alexander 4


### King at the Critical Materials Institute at the 5


### Ames Laboratory, Ames, Iowa. He's got all 6



### sorts of ex cellent data that shows what happens 7


### with these critical materials historically, if 8


### you want to use historical information. And 9


### that even if you see prices coming down, don't 10


### trust it. It's not going to stay that way. 11


### MR. BROOKMAN: Thank you. Karina ? 12



### DR . GARBESI: I just wanted to say

- 13



### - it's Karina Garbesi from LBL

-- that the 14


### model does account for volume changes in 15


### shipments as it goes forward. So it doesn't 16


### just track forward as a trend on time. It 17


### actually accounts for greatly reduced shipme nts 18


### volume. So if it's flat there, it gets a lot 19


### flatter as a result of LED penetration in the 20



### market. 21



### DR . GERKE: Yes, that's true. I 22

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### 285



### also just want to clarify that this is only 1


### applied to the portion of the price that does 2



### not come from rare earth elements, and those 3


### are treated as a separate component of the 4


### price to account for exactly what you're 5


### talking about. 6


### If anyone has any data apart from 7


### what was just mentioned in support of some of 8


### the comments you just made, we'd be very happy 9



### to look at it. 10


### MR. BROOKMAN: Okay. 11



### DR . GERKE: Okay. Moving on to how 12


### the model actually works for shipments. In the 13


### product turnover portion of the shipments 14


### model, we consider various possibilities for 15


### product substitution. Essentially, we allow 16



### consum ers to switch between product classes and 17


### lamp options at appropriate decision points in 18



### the model. 19


### For the IRLs, the consumers may 20


### choose any of the available lamp options each 21


### time they replace a lamp because it's just 22

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### 286



### screwing it into the same fixture they already 1


### have. For GSFLs, consumers may only choose to 2


### switch to a new product class or subclass when 3


### they're doing a renovation or in the case of 4


### new construction, which isn't really switching, 5


### I suppose, but then the decision is triggered 6


### since pro duct switching actually requires 7


### replacing the entire lamp and ballast system in 8



### that case. 9



### We also assumed that the choice is 10


### constrained by the particular lighting 11


### application. So, for example, if you have a 12



### four

- foot medium bi

- pin T8 system, you're n ot 13


### going to go to a T5 high

- output system and so 14


### on. It's application

- specific. 15


### The allowed product substitution, as 16


### shown here, include T12s as starting points 17


### because many people have them in the stock 18


### today. But you can't switch to T12s, you can 19



### onl y switch from T12s in the model. 20


### So we have two questions, two issues 21



### for comment here. DOE believes that the 22

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### 287



### overall fluorescent lamp market will 1


### increasingly shift away from T12 products and 2


### toward other products. We request comment on 3



### the future ava ilability of standards

- compliant 4


### T12 lamps to be used for replacement. In this 5


### analysis, we assumed that there were such lamps 6


### available, as long as there were ballasts 7


### available to be lamped by them. 8


### For IRLs, also, we noticed limited 9


### product offerings for modified spectrum lamps 10


### and small lamps and lamps with voltages greater 11


### than 130. Some of these have been covered, but 12


### this is the request for comment on all those. 13



### MR. BROOKMAN: Joe? 14



### MR. HOWLEY: Yes, Joe from GE 15


### Lighting. We, as you mentioned , we did comment 16


### before that the reason there's limited, there 17


### are limited offerings for modified spectrum due 18


### to the difficulty in meeting the current 19


### levels. There's also limited offerings in 20


### PAR20 again and the difficulty in meeting those 21



### levels. And there are literally no products 22

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### 288



### that we're aware of that are 130

- volt lamps 1


### anymore, given the near impossibility of 2


### meeting those standards and still creating a 3


### practical lamp. We would suggest that no 4


### changes at all would be needed to any of those 5


### produ ct classes, as they've either nearly wiped 6


### out or wiped out the technology as we know it 7


### today. 8



### Your comment about T5s in the 9


### residential market is correct. They're of very 10


### limited use in the products we're talking 11



### about, the four

- foot T5 lamps or the nearly 12



### four

- foot T5 lamps, and unlikely to be a large 13


### use of these products in homes in the future. 14


### MR. BROOKMAN: Okay, thank you. 15



### Charlie? 16


### MR. STEPHENS: Charlie Stephens. 17


### I'd support your issue 28 assumption, as well. 18



### From what we can tell, LED s will probably take 19



### over a lot of that market before the T5s ever 20


### really get very far. 21



### MR. BROOKMAN: Residential or 22

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### 289



### commercial? Commercial sector only, it says. 1


### MR. STEPHENS: Commercial only, yes. 2


### MR. BROOKMAN: Okay, got you. Other 3



### comments on these two issue boxes? Okay. 4



### DR . GERKE: So this is a schematic 5


### diagram showing the operation of the turnover 6


### portion of the shipments model and the consumer 7



### choice model. So this shows the turnover model 8



### for IRLs and for fluorescent ballasts, and then 9


### we consider installing fluorescent lamps on 10


### those fluorescent ballasts in the next step 11



### that I'll discuss in a moment. 12


### So in each year in the model, for 13


### each of the product options we consider , some 14



### fraction of the installed stock fails or is 15



### removed fo r renovation. This amount of 16


### lighting demand is input to the consumer choice 17


### model, along with lighting demand for new 18


### construction and lighting demand from failures 19



### and renovations within the available substitute 20


### product options. The module then apporti ons 21


### this demand among the available product options 22

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### 290



### that are substitutes for the incoming products. 1



### In the case of fluorescent ballasts, we do 2


### assume that failed ballasts are replaced in 3


### kind with the ballasts of the same type and 4


### only allow product switc hing in the case of 5



### renovation. 6



### MR. BROOKMAN: Steve Rosenstock? 7



### MR. ROSENSTOCK: Steve Rosenstock, 8


### EEI. I appreciate this diagram, and I think it 9


### does a nice job. But I think, in terms of the 10


### ballast turnover, I don't know if there's a way 11



### to do it in the model but I think you might 12



### want to break out the commercial from the 13


### residential, especially for the next X years, 14


### I'll say the next 10 or 15 years, because of 15


### existing residential fixtures. I think it's 16


### probably a better assumption to assume tha t a 17



### failed ballast in a residential home will be 18


### replaced with a different ballast type, I'll 19


### just say magnetic to electronic as the best way 20


### to say it, for X years after the standard takes 21


### effect because that's what's going to happen, 22

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### 291



### that's the choice th at consumers are going to 1


### have to make just because of existing 2


### technologies. 3



### DR . GERKE: Thanks. Just to clarify, 4


### we do consider those separately, and we'll 5


### definitely take that into account. 6


### So once we have figured out how many 7


### shipments we have, in the next year, with the 8


### consumer choice model, that's when some 9


### fraction of that demand is siphoned off and 10


### apportioned to LEDs, and that's how our 11


### exogenous LED envelope is implemented in the 12


### model. The remaining demand after that 13



### determines the number o f new shipments for the 14


### product options under consideration. In 15


### particular, this allows us to determine the 16


### fraction of consumers who are going to switch 17


### from one product class to another product class 18



### in the base case and in the standards cases of 19



### the mo del, say from T8s to T5s, naturally, for 20


### purely economic conditions. 21


### So that determines the shipments of 22

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### 292



### IRLs and the shipments of fluorescent ballasts. 1


### To determine the shipments of fluorescent 2


### lamps, we developed a relamping probability 3



### distribution s hown here that gives you the 4



### likelihood that a ballast will need to have a 5


### new lamp installed as a function of the 6


### ballast's age. We assume that all the new 7


### ballasts are installed with new lamps in this 8


### case, so the relamping probability is equal to 9



### one a t age zero. And then the rest of the 10


### distribution is determined by the typical lamp 11


### lifetime in hours and by the usage patterns in 12


### the population, which translates into a typical 13


### lamp lifetime in years, so there's some 14


### fluctuation here with the peaks corr esponding 15


### to the sort of typical lamp lifetime in years. 16


### Then to determine the ages of the 17


### shipments of the GSFLs, we tracked the ages of 18


### the ballasts in the stock and we applied this 19


### probability distribution to determine the 20



### number of ballasts that need to have new lamps 21


### installed in each year of the model. 22

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### 293



### MR. BROOKMAN: Steve? 1



### MR. ROSENSTOCK: Steve Rosenstock, 2


### EEI. So just looking at some of these, I'm 3


### just surprised that they look relatively flat, 4


### especially after year 15. I thought there 5



### wo uld be kind of a general decline in all of 6


### those just because of the, you know

-- again, I 7


### don't know what the distribution curve is, but 8


### for some of these technologies it kind of looks 9


### like the probability is about the same in year 10


### 17 as year 35

-- 11



### DR

. GERKE: This is the probability 12


### assuming

-- this is the conditional probability 13


### assuming that the ballast survives that long. 14


### So you'd multiply this by the probability that 15


### the ballast fails over that period, so if the 16


### ballast lived forever it would get r elamped, 17


### and it smooths out over time because you're 18


### just repeating the same curve over and over 19


### again. 20



### MR. BROOKMAN: Joe? 21


### MR. HOWLEY: Just to mention, this 22

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### 294



### is a typical spot relamping curve for lighting 1


### systems. They all look like this. 2



### MR. BROOKMAN: Okay. Thanks, Joe. 3


### Okay. 4



### DR . GERKE: Okay. Once we've 5


### determined the shipments of GSFLs, we then 6


### input that back into the consumer choice model 7


### to allocate them among the different candidate 8


### standard levels or the technology options 9



### deter mined in the upstream analyses. And so 10


### you can see in this table, for example, a 11


### slight shift in market shares between the first 12


### year of the analysis period in 2017 and the end 13


### of the analysis period in 2046, for the base 14


### case. That represents the fractio n of consumers 15


### who would make that switch for purely economic 16


### reasons over that period in the absence of a 17



### standard. 18



### These charts show the results of the 19


### shipments model, the shipments analysis for the 20



### base case and the two candidate standards 21



### cases. Yo u can see that, for most product 22

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### 295



### classes, the shipments are declining, and this 1



### is because of the incursion of LEDs into the 2


### market, except for the T5 standard output, 3


### which continue to grow as some consumers shift 4


### away from T8s toward T5s for people who 5



### c ontinue to have fluorescent lighting. 6



### MR. BROOKMAN: Pekka? 7


### MR. HAKKARAINEN: So looking at 8


### these graphs, based on the data that you're 9


### showing here, the only rule that would possibly 10


### make sense is the T5 standard output. All the 11


### other ones the propo sed rulemaking has no 12


### effect, including the IRL, which accelerates 13


### only slightly if we go to CSL 1. I see no 14


### point in this whole exercise. 15


### MR. BROOKMAN: Thank you. 16



### DR . GERKE: I also want to point out 17


### in this case that, for the IRL shipments, 18



### there' s a sharp decline in shipments in the 19


### early years of the rule. That's simply 20


### because, as has been mentioned earlier, the CSL 21


### 1 lamp has a much longer lifetime than the 22

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### 296



### baseline lamps, and so there's a sudden drop in 1


### shipments as the turnover slows dramati cally. 2



### MR. BROOKMAN: Steve Rosenstock? 3



### MR. ROSENSTOCK: Steve Rosenstock, 4


### EEI. For the eight

- foot lamps in the bottom 5


### left quadrant there, you're assuming that

-- is 6



### that the LED effect as well, that that's 7


### eliminating those products from the 8


### marketp lace? 9



### DR . GERKE: At the moment, yes, I 10


### would consider the LED envelope to impact all 11


### the different product classes equally. If 12


### people have indications of how that should be 13


### divided up differently, we'd be happy to see 14



### them. 15



### MR. ROSENSTOCK: Steve Rosenstock, 16


### EEI. Again, I appreciate that. It just, you 17


### know, I'm just thinking about, I guess, all the 18


### existing buildings, especially where I've seen 19


### high output. I've seen a lot of those in, 20


### like, warehouses and high bay areas, and, 21


### again, please forg ive me

-- if the LEDs have 22

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### 297



### the same, I'll say light punch to serve those 1


### high bay areas, if they are, great. But I'm 2


### not necessarily familiar with them. 3



### DR . GERKE: If anyone has any data 4


### on that, I'd be happy to see it. Right now, we 5



### assume that it's equal across all product 6


### categories because we don't have better data 7


### than that. We'd be happy to see it. 8



### MR. BROOKMAN: Joe? 9


### MR. HOWLEY: Joe Howley with GE. I 10


### don't have a comment on that, in particular, 11


### Steve, but, in looking at these curves, th ough, 12


### I notice you do project quads of energy 13


### savings, but it appears that most of your 14


### energy savings for this rule going forward are 15



### based on the fact that all of the shipments of 16


### these products are declining. Therefore, 17



### there's fewer of them. Therefor e, they use 18


### less energy. Therefore, there's quad savings. 19


### But it doesn't appear, as Pekka mentioned, 20


### that there's much difference between doing a 21


### rulemaking and not doing a rulemaking because 22

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### 298



### if you did not do a rulemaking or did not move 1


### it forward you' d have, essentially, the same 2


### energy savings as the LEDs replace many of 3


### these technologies. 4


### So are you going to show or are you 5


### showing the difference in savings between just 6


### letting the market do what it's going to do 7


### anyway and passing a rule, as op posed to saying 8


### the rule is going to produce all these savings? 9



### DR . GERKE: The LED incursion is the 10



### same in the base case and the standards case in 11


### this analysis, so all the savings is relative 12


### to that baseline of LEDs coming into the 13



### market. 14



### MR. H OWLEY: Okay. So the other 15


### thing that I would ask as you're doing this 16


### analysis is that: assume a case where with CSL 17


### 2 on fluorescent, there's no control or dimming 18


### savings possible because the standard has gone 19


### so far as to not allow lamps to be dimmed. CSL 20


### 1, though, you may increase the savings in that 21


### scenario because of all the building codes, 22

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### 299



### requiring more and more dimming and controls to 1



### be used. 2


### It just seems your outcome, as I 3


### looked at the numbers in the beginning of this 4


### section, they see m to have a completely 5


### different analysis outcome than I would expect. 6


### I would expect that you'd probably get more 7


### savings from CSL 1 and then a negative savings 8


### for CSL 2 as you're eliminating the ability to 9


### control and dim these products going forward. 10


### You should at least do analysis assuming that 11


### you can't control or dim these products at this 12


### level and see what it does to your energy 13


### savings analysis. 14



### DR . GERKE: Thank you very much for 15


### that comment. That's very helpful. 16



### MR. BROOKMAN: Keith? 17



### MR. K. COOK: To address Steve's 18


### very insightful question, yes, I don't know of 19


### any products today that are for high bay 20


### applications with LEDs. But I see no reason 21


### why they can't be, and the reason I'm saying 22

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### 300



### that is if I look at outdoor lighting it's a t 1


### the same height as the indoor applications. 2


### And so maybe we're not there yet, but there's 3


### no reason why, technically, it can't be done. 4


### MR. BROOKMAN: Okay, thank you. 5


### Yes, Mike? 6


### MR. MCGARAGHAN: Mike McGaraghan, 7


### California Utilities. So Joe just asked about 8


### the national savings or I think he was asking 9


### about these graphs specifically, which show, in 10


### the standards case, fewer shipments of covered 11


### products. And your response was that your 12


### analysis currently doesn't, so I guess I want 13



### clarification for what you mean. The national 14


### savings values that you're going to show us in 15


### a moment, is that what you mean are not based 16



### on these slides? 17



### DR . GERKE: They are based

-- so, in 18


### many cases, the standards case overlays the 19


### base case here, but this sho ws the base case on 20



### all of the standards cases. You can see it 21


### most easily on the T5 standard output where 22

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### 301



### there's a blue curve, which is the base case, 1


### and then the red and the green curve are the 2



### standards cases. For the four

- foot medium bi

3


### pin, you ca n just barely see the blue curve up 4


### at the top and the red and the green curves are 5



### about the same. But all of these cases assume 6


### that LEDs come into the market, and the savings 7



### is the difference between the standards case 8



### and the base case. The base cas e is already 9


### accounting for all the LED incursion, and 10



### there's not more of it in the standards case in 11


### this particular model. 12


### MR. MCGARAGHAN: Okay. So I think 13


### the easiest one to see is the bottom right 14


### because you've got just two colors, and they're 15



### g oing down, and you see CSL 1 around 2020 16


### starts to plummet in the standards case, where 17


### it stays high in the base case, stays higher. 18



### DR . GERKE: Right. In this case, 19


### that effect occurs because the IRL CSL 1 option 20


### has a very long lifetime relative to t he 21


### baseline options. And so when you set the 22

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### 302



### standard, the turnover slows really 1


### dramatically by a factor of two or three. And 2


### so you get a sudden plummeting in shipments 3



### because of that. But the overall decline in 4


### IRLs, that envelope there is the LED e nvelope. 5


### MR. MCGARAGHAN: Thank you. 6



### DR . GERKE: All right. So that 7


### completes the discussion of the shipments 8


### analysis. I'll move on to the, maybe I'll move 9



### on to the NIA. We seem to be frozen. There we 10


### go. So the NIA computes the national energ y 11


### savings and the net present value of the rule. 12


### It starts with inputs from the shipments 13


### analysis and from the LCC and calculates the 14


### NES and the NPV for all the products shipped 15


### during the analysis period. This includes the 16


### energy savings realized for products shipped at 17


### the end of the analysis period. And because 18


### some of those products are residential GSFLs, 19


### we actually have to go out to about 2080 to 20


### capture all of those savings. But that's just 21


### the energy savings. We just considered the 22

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### 303



### energy sav ings from things shipped in 2046. 1


### There are some really long

- lived fluorescents 2


### in the residential sector, right? 3


### So the national energy savings is 4


### calculated using the following equation. We 5


### take the difference between the annual energy 6


### consumption in the base case and the annual 7


### energy consumption in the standards case, and 8


### we then multiply that by a factor to account 9


### for the rebound effect, that is people using 10


### more of the lighting service in the presence of 11


### more efficient products, and also a full fuel 12


### cycle multiplier that accounts for the energy 13


### savings that are realized from energy resources 14


### that don't need to be extracted from the ground 15


### and transported to the power plant and burned. 16


### The net present value is the 17


### difference between the present value of savings 18


### achieved under the standard minus the present 19


### value of the added cost the standard imposes. 20


### And as a standard in these analyses, we compute 21



### those NPVs with a three

- percent discount rate 22

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### 304



### and a seven

- percent discount rate, and I'll 1



### present results for both. 2


### So here's the national impact 3


### analysis results for the IRLs in our reference 4


### case. And when I say reference case, I mean 5



### our sort of best estimate case. I'll discuss a 6


### little bit later some analyses of the impact of 7



### some of the assum ptions that we made in this 8


### analysis. 9


### Because the shipments of IRLs are 10


### declining due to the LEDs, most of the energy 11


### savings occurs in the early years of the 12


### analysis period, but it is positive. The NPV, 13


### however, is significantly negative in the earl y 14


### years and then rises over time. This is 15


### because consumers pay high up

- front costs for 16


### more efficient products, which then repay over 17



### time. 18


### In the particular case of IRLs, the 19


### savings in the future don't necessarily offset 20


### the added expenditures, depen ding on the 21


### discount rate we assume. At three percent, 22

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### 305



### it's barely positive. At seven percent, it's 1


### significantly negative. And before we get to 2


### comments, I also want to point out that on the 3


### printed version there's a typo on this slide. 4



### The NPV at thr ee percent is $0.04 billion, 5


### which is correct here, rather than $0.4 6



### billion. 7



### MR. BROOKMAN: Steve? 8



### MR. ROSENSTOCK: Steve Rosenstock, 9


### EEI. You're showing the NPV over a 60

- year 10


### period, and I know with other appliances it's 11


### basically been two lifetim es. Let's say a 12


### residential air conditioner, it's been 30 13


### years. IRLs, since they have a life of about 14


### 1,500 hours and two lifetimes would be 3,000 15


### hours, how are you doing a 60

- year analysis 16


### period for the net present value? 17



### DR . GERKE: As you can se e, it's 18


### basically flat. We should have probably cut 19


### this off. But as I said, we're going out to 20


### 2080 in all of our analyses to capture the 21


### energy savings from GSFLs shipped at the end of 22

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### 306



### the analysis period, which was 2046. 1



### MR. ROSENSTOCK: But I was t alking 2



### about IRLs. 3



### DR . GERKE: That's right. And as 4


### you can see, it's flat after 2046 because all 5


### the IRLs go out of the market. So this is the 6


### cumulative NPV, so it maxes out at that level. 7


### MR. ROSENSTOCK: I know, but you're 8


### talking about, I'll say , you know, possibly 30 9


### or, depending on commercial versus residential, 10


### you know, 10 or 20 product lifetimes. 11



### DR . GERKE: Yes, the standard 12


### analysis period for these is 30 years. 13


### MR. ROSENSTOCK: All right. The 14


### second thing I had a question about, in your 15


### source energy savings, when I looked in the 16


### TSD, the numbers were significantly different 17


### from the source energy estimates that were used 18


### last year for other residential products. 19


### Could you explain why the change from last 20


### year's analysis of dishwas hers and furnace fans 21


### compared to IRLs in GSFLs? 22

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### 307



### DR . GERKE: This is for the full 1


### fuel cycle

-- 2



### MR. ROSENSTOCK: Yes. 3



### DR . GERKE:

-- analysis? 4



### MR. ROSENSTOCK: On the electric 5


### side, yes. There was significant change. 6



### DR . GERKE: I don't have t hose 7


### numbers to hand. Karina, do you have any 8


### notions on that? All right. We'll look into 9


### it for the next phase. 10



### MR. ROSENSTOCK: Steve Rosenstock, 11



### EEI. I don't see what

-- the only thing that 12


### changed between last year and this year is 13



### record number of solar and wind installations. 14


### If anything, those numbers would go down. 15


### MR. STEPHENS: Charlie Stephens. I 16


### asked about this last year, and I think what 17


### was missing was natural gas. There was a whole 18


### segment of natural gas. They had not looked at 19


### shale gas at all. They had not finished the 20


### analysis for shale gas. And once the shale gas 21


### numbers were put in, I think it changed things 22

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### 308



### somewhat. 1



### MR. ROSENSTOCK: Steve Rosenstock, 2


### EEI. I appreciate that but, again, it didn't 3



### look like the natural gas numbers changed. It 4


### looked like the electric numbers changed. But 5


### in some of the analysis, the natural gas 6


### numbers did not change. So it can't change for 7



### one and not the other. 8


### MR. STEPHENS: Well, I think it did 9


### change on the natural gas side, w hich, since 25 10


### percent or so of the power is natural gas, it 11


### would change that, too. 12


### MR. BROOKMAN: Moving on. Pekka? 13


### MR. HAKKARAINEN: Pekka Hakkarainen, 14


### Lutron. What the graphs here are showing is 15


### that the effect of going to CSL 1 would be 16


### simply t o kill a product class quickly, 17


### resulting in energy savings that are less than 18


### 0.01 percent of national energy use. This is 19


### not going to be measurable anywhere, except on 20


### this particular graph that we're looking at 21


### here. If you think I'm annoyed, you're right. 22

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### 309

1



### DR . GERKE: All right. Thank you. 2


### This is a partial display of the results for 3


### GSFLs, which are more extensive and are covered 4


### in detail in the TSD. Again, the energy 5


### savings here is front

- loaded because LEDs are 6


### eating into the market, so mo st of the savings 7


### is realized in the early part of the analysis 8


### period. Again, the cumulative NPV starts out 9


### negative, as people purchase more expensive 10


### products up front, and then grows into positive 11


### territory as those savings pay back over time. 12

13



### In this preliminary analysis, we 14



### found that the max CSL standards case achieves 15


### higher NES and higher NPV than the CSL 1 16


### standards case, regardless of the assumed 17



### discount rate. And both standards cases 18


### achieve positive NES and positive NPV. 19



### MR. BROOKMAN: I'm going to ask you 20


### to pause right there. I think we should take a 21


### short break, just ten minutes, so people can 22

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### 310



### use the facilities. We still have a number of 1


### slides to get through, not that long but I'm 2


### guessing it's at least another half an hour. 3



### Th at would press several individuals; one or 4


### two have left the room already. Let's take a 5



### ten

- minute break, which means we'll resume at 6


### ten after three. Good progress here. See you 7



### back here in ten minutes. 8


### (Whereupon, the above

- entitled 9



### matter went o ff the record at 2:58 p.m. and 10


### resumed at 3:09 p.m.) 11


### MR. BROOKMAN: Let's start back up. 12


### Okay. We're going to take it back to Brian. 13


### He's going to pick up where he left off. 14



### DR . GERKE: Okay. As many of the 15


### assembled have noted, our analysis rests on a 16


### number of assumptions that do have some degree 17


### of uncertainty. In particular, changing our 18


### assumptions about available technologies, about 19


### the penetration of lighting controls in the 20


### market, and the penetration of LEDs in the 21


### market, and about the pr ices of rare earth 22

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### 311



### elements will have a significant effect or 1


### could have a significant effect on the results. 2


### To gauge that impact, we performed a 3


### number of alternative analyses that varied our 4


### reference case assumptions as shown here: 5



### alternative techno logies, different assumptions 6


### about lighting controls penetration, different 7


### assumptions about LED market incursion, and 8


### different assumptions about where the price of 9



### rare earth oxides will be in the future. 10


### One means by which manufacturers 11


### could comply with the new IRL standards would 12


### be by simply shortening the lifetime of the 13


### baseline lamps that are currently commonplace, 14


### thus boosting their efficacy without reducing 15


### their energy consumption at all. If this were 16


### to occur, as shown in this model, you can see 17


### that the shipments no longer drop off because 18


### now you have these short lifetime lamps. In 19


### fact, the shipments are slightly higher in the 20


### standards case than they are in the base case. 21


### And in this case, it erases most of the energy 22

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### 312



### savings and mak es the NPV of the rule 1


### significantly negative, regardless of assumed 2



### discount rate. 3



### Our reference case analysis assumes 4


### growth in lighting controls that is consistent 5


### with commercial building codes as they build 6


### into the market, so the new ASHRAE 90.1 wi ll be 7


### complied with over time as buildings are 8


### refurbished and renovated. And so the growth 9


### of lighting controls follows the trend of that. 10



### If we instead assume that the 11


### penetration of lighting controls remains fixed 12


### at its current level, just to get a sense of 13


### the total impact, then the impact of a new GSFL 14


### standard is increased by a few tens of 15


### percentage points for both the NES and the NPV. 16


### At the moment, we don't assume growth in the 17


### IRL controls in our reference case, so there's 18


### no impact on the IR L rule. 19


### One point to note here is that the 20


### impact of lighting controls coming into the 21


### market due to building codes depends on the 22

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### 313



### compliance rate with the state building codes 1


### that are out there. In this analysis, we 2



### assumed a 75

- percent compliance rat e. If it 3


### were to be higher or lower, then the impact of 4


### the controls on the rulemaking would obviously 5



### be different. So DOE seeks comment and 6


### relevant data on compliance rates with current 7


### state building code requirements, and we also 8



### seek comment on the validity and 9


### appropriateness of our assumption that the 10


### penetration of controls in the residential 11



### sector remains fixed at the current levels. 12



### MR. BROOKMAN: Charlie? 13


### MR. STEPHENS: Charlie Stephens. 14


### Yes, I think your assumptions are not terribly 15



### o ff the mark. We do code compliance studies. 16


### We just finished a residential one in 17


### Washington State. It was very high, but I 18


### don't think we see very much change in 19


### residential controls. They're all pretty much 20


### located in a predictable set of rooms, so I 21


### wouldn't see any reason to change that. 22

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### And I don't think there's any point 1


### in adding 100 percent compliance rate in 2


### commercial buildings, code compliance, 3


### especially in lighting. I think when there is 4


### not compliance in commercial buildings, a lot 5



### of it seems to reside in the lighting area, 6


### lighting power densities. 7


### So I think, though it's interesting, 8



### the non

- compliance would suggest that, you 9


### know, potentially, there's higher savings if 10


### the actual power consumption of the base case 11


### is higher tha n you assume it is, which it often 12



### is when there's non

- compliance. But I don't 13


### think 75 percent is too far off the mark

-- 14


### MR. BROOKMAN: Charlie, is your 15


### experience, is it confined to the Northwest or 16



### -- 17


### MR. STEPHENS: It is, as far as I 18



### know. We ac tually do studies. My organization 19



### is the one who does the studies in the four 20


### states, and we just finished one in Washington 21



### and one in Montana. 22

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### MR. BROOKMAN: Okay. Joe? 1


### MR. HOWLEY: So I also agree that 2


### your assumptions probably are fairly

-- t hey're 3


### reasonable assumptions. However, what you 4



### should factor in is the fact that it's not so 5


### much the compliance with the building codes, 6


### it's just the building code requirements are 7


### increasing for the use of controls with 8


### lighting and that should be fa ctored in. 9


### So it's not just that people are 10


### complying with the current controls, but you 11


### should assume a situation where you're going 12


### from something, you're starting with, I guess, 13


### five percent on commercial and you should have 14



### some model where that is increasing every year 15


### in the commercial sector as the requirements in 16


### these codes themselves keep increasing and the 17


### use keeps increasing. 18



### DR . GERKE: Just to clarify, the 19



### five

- percent number is the number of commercial 20


### IRLs on dimmers, which is not the same as the 21


### amount of commercial lighting on controls, 22

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### generally. And right now most of the buildings 1


### in the country are under some kind of building 2


### code that requires some amount of lighting 3


### control, and so we just assume that those are 4


### complied with as

-- 5



### MR. HOWLEY: Yes, but most of those 6


### are on/off controls, and what I'm talking about 7


### are the new concepts where they're going to 8


### require sort of demand response systems or 9


### daylight response systems or even individual 10


### user control systems where they ca n decrease 11


### the lighting power use on an individual basis 12


### or based on some other response. That is 13


### increasing, and that is going to reduce the 14


### number of, the amount of power used by these 15


### fluorescent systems, as well. That should be 16



### factored into the anal ysis. 17



### MR. BROOKMAN: Let's hear from 18



### Karina. 19



### DR . GARBESI: Thanks. Karina 20



### Garbesi from LBNL. We'd love some additional 21



### data on that. What we did

-- you're absolutely 22

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### 317



### correct that the current codes require almost 1


### universal coverage of on/off, but t here's 2


### alternative ways that you can meet it with more 3


### advanced controls, as well. And we also expect 4


### that there will be sort of this layering of 5


### more advanced controls as one goes along, but 6


### we don't have a way of predicting that well. 7



### What the assum ption has been in the 8


### model is that we would save about 30 percent 9



### over no controls, and that's based on a meta 10


### study of savings that have been achieved to 11


### date in the field. But we realize that savings 12


### can go considerably higher if you start 13


### layering and you do it well. But right now we 14


### don't have data to be able to change that. 15


### But, still, I think by 2046 you 16



### would have two

- thirds of the commercial 17


### building area, essentially, covered by 18



### controls. 19



### MR. BROOKMAN: Charlie? 20



### MR. STEPHENS: I would agree with 21


### that end point. But what we're seeing right 22

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### now, as many as a third of the commercial 1


### building control systems don't work. They're 2


### there, but they don't work because they don't 3


### communicate with anything. There's 4


### miscommunication, and you can' t program them, 5


### and they don't actually function the way they 6


### were designed, including our own space, I might 7


### add. We finally gave up on trying to make it 8



### work, and we've done workarounds, and we're not 9


### getting all the savings we thought we were 10


### going to get. 11



### But that's not uncommon, but we're 12


### also forecasting that fixture

- level controls 13


### may change that, starting pretty much right 14


### about now. And so I wouldn't disagree with the 15


### trend, but for the reason that it will be 16


### simpler, not more complicated, no t more 17


### layered, but actually down at the level of the 18



### fixture. 19


### MR. BROOKMAN: Karina, go ahead. 20



### DR . GARBESI: Karina Garbesi again 21


### from LBNL. To clarify, the 30 percent number 22

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### that we used was based on cases where the 1


### savings were actually measured i n the field. 2


### We did find that there was a significant over

3


### prediction of what the savings would be if you 4


### used the theoretical studies alone, so we 5


### attempted to account for it. 6



### MR. BROOKMAN: Steve? 7



### MR. ROSENSTOCK: Steve Rosenstock, 8



### EEI. I do reca ll that, under the stimulus 9


### program, that one of the incentives was that 10


### for all state governments to basically, all 11



### state governments

-- a lot of state governors 12


### signed a document that said that they were 13


### going to go for 90 percent compliance in 14


### building codes by the year 2017, so there was 15


### money spent and they are kind of under the gun 16


### to report to the federal government. Again, 17


### the actual results may vary, but, again, that 18


### is out there, in terms of that. 19


### I guess the other thing I was going 20



### to say was, you know, there's building codes 21


### and then there's green building codes. And in 22

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### many jurisdictions, even ASHRAE 90.1 isn't the 1


### minimum code. It's actually, it's LEED or the 2



### IGCC or ASHRAE 189.1 for certain commercial 3


### buildings, especially if they're abo ve, I'll 4


### say 50,000 square feet in certain jurisdictions 5



### -- did I say something? Is everything okay? 6


### Okay. That they have to meet the green code, 7



### which has even more incentives for more 8


### controls on lighting within the building. 9


### Thank you. 10



### MR. BROOKM AN: Thank you. Karina, 11


### go ahead. 12



### DR . GARBESI: Sorry. Karina Garbesi 13


### again from LBNL. So another point of 14


### clarification. The model includes, on the top 15


### of what is going to be obtained solely from the 16



### state

- required code implementation over time, 17



### as you get new buildings and retrofits, it also 18


### includes an amount above that, which is 19


### currently not explained by the codes, and that 20



### is carried forward. 21


### MR. BROOKMAN: Okay. Joe? 22

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### MR. HOWLEY: You know, it's just a 1


### final comment wrapping all these co mments up. 2


### If you're assuming 5 percent commercial use of 3


### controls today are, you know, get you up to 30

- 4


### percent savings, what we would suggest in the 5


### analysis going forward is that 5 percent 6


### getting 30 percent savings is going to increase 7


### slowly over the next 20 or 30 years for all of 8


### these reasons. So maybe six or seven percent 9


### next year. So it's going to keep increasing by 10


### some estimated percentage over the analysis 11


### period. 12



### DR . GERKE: Thank you. That is what 13


### our analysis does, although it starts at a 14


### higher level. The five percent again is the 15



### fraction of IRLs that are on dimmers. 16


### MR. BROOKMAN: Okay. So let's press 17



### on. 18



### DR . GERKE: Okay. Obviously, the 19


### incursion of LEDs, as we have noted, has a 20


### large impact on our analysis. So we perform ed 21


### an alternative analysis in which there was no 22

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### 322



### further LED incursion into the market just to 1


### gauge the size of that impact. And, obviously, 2


### the impact of that is quite substantial. It 3


### significantly increases the NES for each of the 4


### potential standards cases simply because 5


### there's substantially more lamps out there in 6


### the market that are subject to the standard. 7


### It also significantly increases the NPV of the 8


### GSFL standard, but it actually leads to a more 9


### negative NPV for the IRL standard. 10



### MR. BROOKMAN : Steve? 11



### MR. ROSENSTOCK: Steve Rosenstock, 12


### EEI. So does this no LED also include the, 13


### I'll say the current competition from, I'll say 14


### HID reflector lamps that are used and also 15


### maybe some compact fluorescents? Again, I'm 16


### just

-- there's no LEDs, wh ich I understand are 17


### the newest technology, but what about the other 18


### competing technologies? 19



### DR . GERKE: That's not currently in 20


### the analysis. 21


### MR. ROSENSTOCK: Okay, thank you. 22

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### 323



### DR . GERKE: All right. And, 1


### finally, rare earth element prices. As w e're 2


### all aware, recent years have seen significant 3


### volatility in the price of rare earth elements. 4


### This chart shows a price index that we 5


### developed for the rare earth oxides that are 6


### used in the GSFL. It's weighed by their 7


### presence in those phosphors. F ollowing a price 8


### spike in 2011, rare earth prices have retreated 9



### somewhat but have not returned to their 10


### previous levels. 11


### We used the most recent prices in 12


### this chart to develop our reference case 13


### analysis. There's no reliable way to forecast 14



### future vol atility in the market for rare 15


### earths; but, to capture the range of possible 16


### impacts represented historically, we also ran 17


### the model assuming that rare earth prices 18


### remained at their peak levels from 2011 over 19


### the entire analysis period or that they 20



### return ed to their lower levels over the 21


### analysis period. 22

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### 324



### In both cases, because we assumed 1


### that people continue to light their space, the 2


### impact on the NES and NPV of potential new GSFL 3


### standard is small, on the order of a few 4


### percent, in this analysis. 5



### An d we'll move on to the comment 6


### box. DOE requests comments on the specific 7


### impacts of an increase in rare earth phosphor 8


### prices due to the decreased supply or an impact 9


### on the price due to the rulemaking. 10



### MR. BROOKMAN: Joe? 11



### MR. HOWLEY: So I think it' s very 12


### unlikely we're ever going to see the low REO 13


### again. That level which existed prior was due 14


### to a lot of factors that don't exist anymore, 15


### and we expect this to remain at a higher level 16


### and also to continue to spike from time to 17


### time. Again, if you analyze some of the other 18


### types of critical materials that have gone 19


### critical, you'll see the pattern that is going 20



### to start to exist for rare earth materials. So 21


### it's going to be closer to the high rare earth 22

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### 325



### scenario, which I note for the maximum CSL 1



### pr oduces a negative NPV in all scenarios. 2



### DR . GERKE: That's a negative change in 3



### the NPV from the reference case. 4


### MR. HOWLEY: Oh, is that what that 5



### is? 6



### DR . GERKE: Yes. 7


### MR. HOWLEY: Okay. Thank you for

- 8



### - 9



### MR. BROOKMAN: Steve? 10



### MR. ROSENS TOCK: Steve Rosenstock, 11


### EEI. So if I'm reading this chart right, you 12


### know, everything else is kind of locked except 13



### for the rare earth materials. If it's a low 14


### price, the NPV goes down from the reference 15


### case, but if it's a high price the NPV goes up, 16



### e ven though the prices are higher? That's what 17


### this table says. 18



### DR . GERKE: In the CSL 1 case but

-- 19



### MR. ROSENSTOCK: CSL 1. 20



### DR . GERKE:

-- not in the max CSL 21



### case. 22

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### 326



### MR. ROSENSTOCK: What? 1



### DR . GERKE: In one of the cases but 2



### not in the other. 3



### M R. ROSENSTOCK: Okay. I'm just

-- 4



### DR . GERKE: And the reason for that 5


### is likely because fewer people in the CSL 1 6


### case end up shifting to, naturally shifting to 7


### CSL 2 on their own because the prices are 8


### higher. 9


### MR. ROSENSTOCK: But there's only 10



### one CSL for IRLs, isn't there? Oh, the GSFL. 11


### I'm sorry. Sorry, GSFL. But there's only, 12


### only for the one lamp there's a second CSL. 13


### Okay. It just seemed counterintuitive to me. 14


### Okay, thank you. 15



### MR. BROOKMAN: Additional comments 16


### on rare earth phosphor availability in these 17


### scenarios? We're moving on. 18



### DR . GERKE: DOE did a few additional 19


### alternative analyses to assess uncertainties 20


### arising from uncertainty in the future price of 21


### electricity due to different assumptions about 22

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### 327



### economic growth in the a nnual energy outlook 1


### and also different assumptions about the 2



### rebound rate. 3


### As shown here, these are generally 4


### small compared to the impact of LEDs and 5


### controls on the rulemaking on the order of a 6


### few percent in most cases, except for the case 7



### of a 15

- p ercent rebound rate, which has a 15

- 8


### percent factor. 9


### And at this stage, I'd like to open 10


### it up for general comments on the assumptions 11


### and methodology used in the shipments and NIA 12



### model. 13


### MR. BROOKMAN: Any additional 14



### comments here? We've been cove ring it as we've 15


### been going. Steve? 16



### MR. ROSENSTOCK: Steve Rosenstock, 17


### EEI. Why would the rebound rate only affect 18


### the NES? Because if they're using the product 19


### more that would cut into the economic savings, 20


### as well, right? 21



### MR. BROOKMAN: Karina? 22

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### 328



### DR . GARBESI: Karina Garbesi from 1


### LBNL. This is an approach that's been taken in 2


### some prior rulemakings as well. The feeling is 3


### is that the economic savings that are derived 4


### from energy efficiency savings are used 5


### productively somewhere else to get co nsumer 6


### utility, and so there's a tradeoff there and 7


### there's no change in net consumer utility as a 8


### result but there is a change in the energy 9


### savings. 10



### MR. ROSENSTOCK: Steve Rosenstock, 11


### EEI. Thank you. But I'm just saying, for this 12


### particular analysis , if you're assuming more 13


### usage of the lighting product, if you're, 14


### again, trying to bound the analysis to say, 15


### okay, you're doing the economic analysis 16


### without the extra utility. Then if a product 17


### is being used 15 percent, that reduces your 18


### energy saving s by 15 percent and that reduces 19


### your cost savings by 15 percent. 20



### DR . GERKE: Right. The assumption 21


### is that the additional utility that consumers 22

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### 329



### achieve from that remains within the analysis, 1



### so there's no net offset. That's been standard 2



### in recent ru lemakings. 3



### DR . GARBESI: You can also see it in 4


### the TSD. If you look, it will direct you to 5


### the prior rulemaking that discussed that at 6


### more length. 7


### MR. ROSENSTOCK: Okay. Steve 8


### Rosenstock, EEI. So, again, I'm still, I think 9


### it still might be us eful to see economically 10


### what the change in NPV is from a rebound effect 11


### because I know it's not used for the analysis 12


### or the end result but, again, if people are 13


### incorporating that type of analysis, I know 14


### that, you know, especially some utilities might 15



### t ry to, if there is a rebound effect, that will 16


### have an impact on their analysis of future DSM 17



### programs. 18



### DR . GARBESI: Karina Garbesi again 19


### from LBNL. Actually, in this rulemaking we 20


### were unable to find any evidence of a current 21


### rebound on lighting. The data that were 22

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### 330



### originally cited went back to before 1992. 1


### There is a, you can find a discussion of this 2


### in one of the appendixes, either in Chapter 9 3



### or 10. And so we went to find current data 4


### that would get us as close to being able to 5


### quantify a rebou nd currently, and we could find 6



### no evidence thereof. 7



### MR. ROSENSTOCK: Steve Rosenstock, 8


### EEI. Again, I appreciate that, but, again, I 9


### think maybe, just from an analytical point of 10


### view, you know, if some people want or need to 11


### incorporate the financial or energy impact of a 12


### rebound effect and if they are required to do 13


### some sort of net present value analysis, it 14


### might be useful for some parties. Again

-- 15


### MR. BROOKMAN: We're moving on. 16



### DR . GERKE: Thanks for the comment. 17


### MR. BROOKMAN: Preliminary MIA. 18



### DR . GERKE: So Aisha Husain will be 19


### taking over for me now. 20



### MS. HUSAIN: Hi. This is Aisha 21


### Husain from Navigant. So these are the last 22

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### 331



### few slides. We will now discuss the 1


### methodology for the manufacturer impact 2


### analysis and some preliminary r esults that were 3


### provided from this analysis, and we will also 4


### go over upcoming NOPR analyses. 5


### The purpose of the manufacturer 6


### impact analysis, or MIA, is to identify impacts 7


### of amended energy conservation standards on 8



### manufacturers. The MIA is conducte d in three 9


### phases. In the first phase, an industry 10


### profile is developed that identifies key issues 11


### for the industry. An initial industry profile 12


### was presented in this preliminary analysis TSD. 13

14


### In the second phase, DOE develops an 15


### industry cash flow m odel called the government 16


### regulatory impact model, or GRIM, to forecast 17


### industry cash flows. In this phase, DOE also 18


### develops an interview guide for manufacturers 19


### to facilitate discussions during manufacturer 20


### interviews. In the third phase, the 21



### manufact urer interviews are conducted. 22

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### 332



### Information from the interviews and 1


### the GRIM are used to conduct a quantitative 2


### assessment of impacts due to standards. 3



### Manufacturer interviews are also used to make a 4


### qualitative assessment of impacts due to 5



### standards, including impacts on competition, 6


### manufacturing capacity, direct employment, and 7


### regulatory burden. Results from the second and 8


### third phase will be presented in the NOPR 9



### notice and TSD. 10


### In this preliminary analysis, 11


### manufacturers identified six key is sues in 12



### relation to GSFL and IRL standards. GSFL 13


### manufacturers noted the availability of rare 14


### earth phosphors as a key issue. Because a 15


### majority of rare earth phosphor mines are in 16


### China, which imposes a quota on their export, a 17



### manufacturer outside of C hina may be left at a 18


### disadvantage. 19


### Another key issue identified was 20


### that amended GSFL and IRL standards may be 21


### developed without knowing the full impact of 22

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### 333



### the July 2012 standards on sales, shipments, 1


### and consumer preferences. Manufacturers also 2



### noted that regulation of additional products 3


### may add to the existing burden of testing GSFL 4


### and IRLs for standards compliance. 5


### Shift to other technologies was also 6



### cited as an issue. Manufacturers stated that a 7


### potential increase in GSFL and IRL prices due 8



### to amended standards could further drive 9


### consumers to alternative technologies, such as 10



### LEDs. There are also concerns that amended 11



### GSFL and IRL standards could cause 12


### manufacturers to shift R&D resources away from 13


### more efficient lighting technologies. 14



### Anot her key issue was the potential 15


### impact on the residential sector. Amended IRL 16


### standards may cause residential consumers to 17


### purchase cheaper, less efficient IRLs with 18


### shorter lifetimes. For GSFLs, in order to 19


### comply with amended standards, residential 20



### con sumers may have to switch out entire GSFL 21


### systems for minimal energy savings. 22

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### 334



### So we have a few comment boxes here. 1


### In the NOPR stage, DOE plans to assess impacts 2


### on manufacturer subgroups. These are groups 3


### that have cost structures that differ largely 4


### from the industry average or are bound by a 5


### different regulatory framework than normally 6


### found in the industry. DOE requests comments 7


### on subgroups to analyze, as well as 8



### characteristics it should examine for this 9


### analysis. 10



### MR. BROOKMAN: No comments he re? 11


### Okay. 12


### MS. HUSAIN: Okay. So leading into 13


### that, one of the subgroups DOE looks at are 14



### small business manufacturers. If DOE finds 15


### that small business manufacturers are impacted 16


### by this rulemaking, it will conduct a 17


### regulatory flexibility analysis to identify 18


### ways to reduce negative impacts. 19



### MR. BROOKMAN: Alex? 20


### MR. BOESENBERG: Alex Boesenberg, 21


### NEMA. Regarding small business impacts, how 22

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### 335



### closely or does the DOE work with the Small 1


### Business Administration on this point? 2



### MS. deBUTTS: I d on't think we 3


### actually coordinate with them at this point, 4



### correct? 5


### MS. HUSAIN: We're not coordinating 6


### with them at this point, but I think maybe

-- 7


### MR. STAS: Eric Stas, DOE. I mean, 8


### in a typical rulemaking, if we make a 9



### certification that there w on't be a substantial 10


### impact on small businesses, we'll send a 11


### certification analysis to SBA for review. And 12


### SBA, presumably, is following DOE's 13


### rulemakings, and they're free to comment like 14


### any other party. And we also, you know, when 15


### we do the Regulato ry Flexibility Act analysis, 16



### we'll look to the SBA's classifications under 17


### the codes to get the numbers, and they populate 18



### it with the financial information and all. 19



### MR. BROOKMAN: Steve? 20



### MR. ROSENSTOCK: Steve Rosenstock, 21


### EEI. I'm going to go back to the 2009/2012 22

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### rule where the Department of Justice said that 1



### there would be anti

- competitive impacts of the 2


### IRL standard that was put in place, and I'm 3


### just, I'm kind of curious, when DOE received 4


### that information from the Department of 5


### Justice, what di d DOE do with that information? 6


### When the Department of Justice specifically 7


### stated and it was put in the final rule that 8


### the standard was going to be anti

- competitive 9


### and raise prices, what was DOE's response and 10



### what action did DOE take to address the 11



### De partment of Justice's issues? 12


### MR. STAS: Okay. Eric Stas, DOE. I 13


### mean, I don't recall the specifics of it at 14


### this time, but I know, in the final rule, DOE 15



### addressed the DOJ's comments. And it's in the 16


### preamble of the final rule, and so DOE 17



### addressed the comments and was able to move 18


### forward with the final rule that was published. 19



### MR. ROSENSTOCK: Well, Steve 20


### Rosenstock. Yes, I think kind of the 21


### addressing was to say DOE did not, basically, 22

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### well, I don't want to put words in anyone's 1


### mouth, but it's like, well, that DOE did not 2


### agree with the analysis of the Department of 3



### Justice it seemed like. It seemed to me to be 4



### a brush

- off of what Department of Justice was 5


### saying, and it concerned me a lot, especially 6


### because it seemed, you know, when the 7



### Depa rtment of Justice says something is anti

8


### competitive and the standard is in place, it's 9



### not ease to alleviate those concerns with 10


### impacts on both manufacturers and consumers. I 11


### think that was a very

-- it raised a lot of 12



### concerns. 13



### MR. BROOKMAN: Charlie ? 14


### MR. STEPHENS: Charlie Stephens. On 15


### the other hand, my experience from doing 16


### shopping regularly on this and in our own work 17



### in the manufacturers and distributors that we 18


### get to work with, which is quite a few, we have 19


### a lot more choices of who we get to work with 20


### these days on most of these products. There 21


### actually has been, I think, an increase in the 22

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### number of brand names that are available in our 1


### marketplace, and we get to work with more 2


### companies that five to ten years ago weren't 3



### even in the mar ket, at least not in our market. 4


### So I'm not sure whose predictions actually 5



### were borne out here. 6



### MR. BROOKMAN: Look at these comment 7


### boxes. Let's get additional comments on 8


### Regulatory Flexibility Act and manufacturer 9


### impact analysis. No additional comments at 10


### this time? Yes, Alex? 11


### MR. BOESENBERG: Alex Boesenberg, 12


### NEMA. On issue 33 regarding manufacturer 13


### impact, I'm still trying to understand GRIM and 14


### how it works. But I'm curious if you could 15


### explain how GRIM or how the analysis you're 16


### doing, regardless of the tool, affects the 17


### cumulative burden and adjust the rule, as 18



### necessary. 19


### We've commented in numerous previous 20


### rulemakings as to the cumulative effects of you 21


### make lamps, you make ballasts, and now you're 22

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### conforming to a ballast rule th at hits you with 1


### a 37 1/2 percent industry net present value 2


### over 20 to 30 years and then to do the same 3


### thing to the lamp side. How does the tool, how 4


### do the analyses factor in the limitations of 5


### just how many loans you can take out or how 6


### many, how much internal company resource you 7


### can funnel from one thing to the next? 8


### On a consumer note, to put it on a 9


### personal thing, if I want to take out a loan 10


### and buy a car, I can probably get one. If I 11


### want to take out a loan and buy a motorcycle, I 12


### might be able to get one. If I want to take 13


### out another loan for something, home 14


### improvement, I might not be able to get it. So 15


### at what point, how does the analysis factor in 16


### that companies can only adjust to so many rules 17


### that are, theoretically, now all being p aid 18


### back at once in some sort of messy thing? 19



### MR. BROOKMAN: Keith? 20


### MR. K. COOK: Maybe another way to 21


### put what Alex is saying is at what point do 22

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### the, does the impact on manufacturers become 1



### over - burdensome? What is the criteria that 2



### determines that we've gone too far? How is 3



### that established? 4



### MR. BOESENBERG: And the statement

- 5



### - Alex Boesenberg

-- to say that because, as 6


### I've been tracking rules for two and a half 7


### years, I haven't seen anything indicate when I 8



### read the final rule but because i t would have 9


### been overly burdensome, we dropped it at CSL, 10



### for instance. 11



### MR. BROOKMAN: Please. 12


### MR. H. COOK: Hi. This is Hayden 13


### Cook from Navigant. The GRIM itself does not 14


### look at the cumulative regulatory impact. The 15


### cumulative regulatory impac t is a separate 16


### analysis, and it does look at either three

- or 17



### four

- year periods before the rule and after the 18


### rule goes into effect, and it looks at the 19


### conversion costs from previous rules. And then 20


### that information is given to DOE and is one of 21



### the cri teria for selecting a standard, similar 22

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### to

-- we already talked about small business, 1


### so the small business Regulatory Flexibility 2


### Act is a separate analysis that's conducted, 3


### and that information is then given to DOE, and 4


### that's one of the weights that is used to, 5


### ultimately, determine the final rule that gets 6



### set. So there's no number threshold or 7


### something like that. 8



### MR. BROOKMAN: Additional comments

- 9



### - thank you

-- on these three items: 10


### manufacturer subgroup, Regulatory Flexibility, 11



### and manufacture r impact analysis? Okay. So 12


### then on to NOPR analyses. 13


### MS. HUSAIN: All right. Now we will 14


### briefly discuss the NOPR stage of this 15


### rulemaking. The following chart outlines the 16


### analyses that will take place during this 17


### stage. DOE will begin by revis ing analyses 18


### conducted at the preliminary stage, as 19


### appropriate, based on comments received. DOE 20


### will then conduct additional set of analyses 21


### that will further inform the rulemaking. 22

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### These additional analyses include 1


### the LCC subgroup analysis which co nducts an LCC 2


### assessment for specific consumer subgroups. 3


### Phases two and three of the MIA which were just 4


### discussed previously will be conducted in the 5


### NOPR stage. The employment impacts analysis 6



### looks at the indirect effects of national 7


### employment, whic h are impacts on net jobs as 8


### results of changes in expenditures and incomes 9


### due to amended standards. This employment 10


### impact analysis is different from the 11


### employment analysis conducted in the MIA which 12


### looks at direct employment impacts. 13


### The utility impact analysis looks at 14


### impact on generation capacity of utilities. The 15


### emissions analysis focuses on impact on impact 16


### on airborne pollutant emissions. Monetization 17


### of emission reduction benefits analysis 18


### estimates the monetary benefits from emission 19



### red uctions, and the regulatory impact analysis 20


### identifies potential non

- regulatory 21



### alternatives to standards. 22

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### DOE would welcome comments on these 1


### planned analyses for the NOPR stage. For the 2


### emissions analysis, DOE will assess the impact 3



### on emissions of c arbon dioxide, sulfur dioxide, 4


### nitrogen oxides, and mercury, and monetize the 5



### emission reductions due to amended standards. 6


### DOE welcomes comments on the methodology for 7


### this analysis. 8



### MR. BROOKMAN: Yes, Steve? 9



### MR. ROSENSTOCK: Steve Rosenstock, 10



### EE I. A few thoughts on this, and I'll go by 11


### emission. For sulfur dioxide, as I recall the 12


### TSD, there was a value in there based on a 2001 13


### study of, like, I'll say $2,000 per ton, or I 14


### forget what the exact amount was. But it was 15


### based on a study that's 12 years old that's 16


### been, basically, adjusted for inflation. And 17


### to me, that number is totally way overstated 18



### because of the fact that, because of the 19


### federal Clean Air Act, the emissions of sulfur 20


### dioxide, since about 2001 , they've gone down 21


### about 60 perce nt for SO2, since 1990 about 80 22

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### percent. If you look at the AEO projections, 1


### it's going to go down another 40 percent by the 2


### year 2015. So I don't see how those values can 3


### be so high when the amount of emissions keep 4


### going down and down and down. So I'm pretty 5



### concerned about that. 6


### I also note that, with certain 7


### emissions, that wherever there is a federal or 8


### regional cap, like the eastern 28 states, DOE 9


### has correctly said that efficiency standards 10


### will not affect, there will be no physical 11



### reduction in emissions based on appliance 12


### efficiency standard because they're capped 13


### upstream and they are regulated. Well, that's 14


### about to happen with mercury, under the mercury 15



### and air toxic standard rule that was finalized 16


### by EPA just a couple of months ago. 17



### An d in terms of carbon dioxide, 18


### there's no national standard, but there are 19


### regional standards. There's a regional 20


### standard in New England, and there's now the 21


### California standard. CO2 emissions are capped 22

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### in those states. 1


### So I'm wondering: will DOE tr eat CO2 2


### standards the way they've treated other 3


### standards in terms of that they will not show 4


### any emissions reductions and, therefore, no 5


### dollar savings because they're already capped 6


### in those regions. And I have a couple of other 7



### comments. 8



### MR. BROOKMA N: Yes. Steve, I'm sure 9


### the Department will welcome your comments on 10



### this. 11



### MR. ROSENSTOCK: I know, but I'd 12


### like some feedback from the Department now. 13



### MR. BROOKMAN: Lucy? 14



### MS. deBUTTS: We'll take a look at 15



### the data. 16


### MR. ROSENSTOCK: Okay, th ank you. 17


### And the other thing I was going to say, in 18


### terms of CO2 emissions, and I've said this 19


### other times before, in New England and 20


### California they already have dollar values. In 21


### New England it's about $2.00 per ton, which is 22

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### down from $3.00 a ton a fe w years ago. In 1


### California, the most recent auction, I believe, 2


### was $13.00 a ton and the first one was $10.00 a 3


### ton. These values are significantly below what 4


### DOE is using, and those dollars are going to be 5


### put into the electric rates already. So in a 6



### w ay, when DOE uses these numbers in its final 7


### analysis, I know they do it in the LCC but I 8


### know they do it in the final analysis for the 9


### final rule, you're double

- counting the CO2 10


### dollar savings for those regions. And I would 11


### hope that adjustment would be made because when 12


### you double

- count, you're overinflating what the 13


### estimated, I'll say, monetized savings are 14


### going to be for those, for that emission. 15


### The last thing I also want to say is 16


### that, in many states, there are renewable 17


### portfolio standards. There's record amounts of 18



### zero - emissions electricity being produced 19


### throughout the United States. So, again, in 20


### fact, CO2 emissions from the electric sector 21


### are below 1996 levels, even though production 22

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### has increased 16 percent. Thank you. 1



### MR. BROOKMA N: Thank you. Comments 2


### on regulatory impact analysis? Okay. And also 3


### you want to queue up LCC subgroups and trial 4


### standards? Yes, Keith? 5


### MR. K. COOK: Yes, I'm sorry. On 6


### the regulatory impact analysis, it's very 7


### similar to our previous comment, an d that is 8


### every year we go through this exercise of these 9


### rulemakings and every year we provide all sorts 10


### of data explaining what the regulatory impact 11


### analysis is doing for us, but we don't see 12


### anything coming out of it. Again, the same 13


### question I had be fore is what is going to be 14


### the determining factor saying enough is enough? 15


### What is that criteria that says

-- otherwise, 16


### you know, why bother? If there isn't something 17


### that triggers action, then why do you even ask 18


### the questions? 19


### MR. BROOKMAN: Okay . Yes, Alex? 20



### MR. BOESENBERG: This is Alex 21


### Boesenberg, NEMA. Since Keith clarified my 22

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### last big long statement, and his is short so 1


### I'll make a short clarification, will the DOE 2


### provide greater transparency into that decision 3


### cycle so that we can bette r understand how the 4


### decision is weighed? And I have a follow

- on. 5


### MS. deBUTTS: I'm not sure what you 6


### mean by greater transparency. 7


### MR. BOESENBERG: As was explained 8


### there, that regulatory burden is factored in 9


### with all the other choices and, there fore, a 10


### CSL is chosen. And it, logically, would help 11


### folks understand why, hey, it could have been 12


### worse if you can see that somehow something was 13



### knocked down in certain areas. 14



### MS. MCDONALD: This is Ali McDonald. 15


### In the NOPR notice, there's a sectio n called a 16


### walkdown which, essentially, starts with the 17


### highest possible standard, looks at all the 18


### results for those levels, like all the 19


### benefits, any burdens identified, and it comes 20



### to a conclusion as to whether the benefits 21


### outweigh the burdens. And if they don't, then 22

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### 349



### they evaluate the next lowest level and they, 1


### essentially, walk down until they find a level 2


### at which the benefits do outweigh the burdens. 3



### And there's a discussion in the notice about 4



### that. 5


### MR. BOESENBERG: All right. Thank 6


### you f or that. This is Alex Boesenberg again. 7


### Thank you for that clarification. We do have a 8


### perception that, once it hits the NOPR, it's 9


### pretty much a done deal, at which point it's 10


### hard to affect the change. 11


### MS. deBUTTS: Not necessarily 12


### because, as you know, there were rules, I'm not 13


### sure, you know, if we had any lighting standard 14


### rules, but we come up with supplementary 15


### notices. So if there are changes, significant 16


### changes that need to be addressed, the 17


### Department has the discretion of providing that 18


### or publishing that notice. 19


### MR. BOESENBERG: Okay. And if I can 20


### ask my follow

- on. That same explanation said, 21


### so we get this in and then you choose the CSL, 22

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### 350



### and so it could be a lower CSL due to 1



### cumulative burden and other effects. We have a 2



### lot of stu ff here where there's only one CSL, 3


### and so the option is zero or one, and the 4


### practice is to not say zero. 5


### MR. STAS: Eric Stas, DOE. I mean, 6


### typically, there are, you know, more CSLs. And 7


### usually there's some level where there's energy 8


### savings and e conomic justification to adopt a 9


### standard. But in the past, DOE, on some 10


### occasions, has adopted a no

- standard standard 11


### because that's all that was justified. 12


### MR. BOESENBERG: Could I get a list 13


### of those? I haven't experienced one myself. 14



### MS. deBUTTS : We can come back to 15


### you on that one. We'll look into it. 16


### MR. BOESENBERG: I'd appreciate it. 17



### MR. BROOKMAN: Go ahead, Steve. 18



### MR. ROSENSTOCK: Steve Rosenstock. 19


### Yes, the only product I'm aware of is microwave 20


### ovens, at least off the top of my hea d. But 21


### that was for the full standard. Now they're 22

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### about to do a standard on just the standby 1


### energy use of microwave ovens, so even that's

- 2



### - I have to caveat that statement. 3


### MR. BROOKMAN: Okay. Do you want to 4



### cue these last two? 5



### MS. HUSAIN: S ure. So DOE, as I 6


### mentioned, will assess the LCC impacts from 7


### standards on specific consumer subgroups that 8


### might be adversely impacted by amended 9


### standards. DOE is planning to assess low

10



### income consumers defined as residential 11



### consumers with incomes at or below the poverty 12


### line, per the U.S. Census Bureau. It's also 13


### planning to assess institutions of religious 14


### worship and institutions serving low

- income 15



### consumers. DOE welcomes comments on the LCC 16


### subgroups it's considering and any additional 17



### ones it sh ould consider. 18


### MR. BROOKMAN: Cue up trial standards 19



### also. 20


### MS. HUSAIN: For the NOPR, DOE is 21


### considering developing trial standard levels, 22

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### or TSLs, from the CSLs using minimum LCC, 1


### maximum NPV, and max tech efficiency as 2


### criteria. From these TSLs, DOE will select one 3


### proposed standard, and DOE requests comments on 4


### the criteria it is considering that should be 5


### used to develop TSLs. 6



### MR. BROOKMAN: Final comments on 7



### these two issues? Steve? 8



### MR. ROSENSTOCK: Steve Rosenstock, 9



### EEI. On the LCC sub groups, I mean, I think 10


### that looks fine. My only question was, since 11


### you're using RECS data, I can't remember, I'd 12



### have to take a look if the RECS data

-- there 13


### are areas of RECS that show differences, energy 14


### consumption or energy usage or energy 15


### expendit ures, by income. I can't remember if 16


### they have a specific breakout at the poverty 17


### level. I don't recall if they do. 18



### So I think

-- in concept, I like 19


### your idea. I'm just thinking, with the current 20


### RECS data, the way it's structured right now, I 21



### don't know if they break it out that way. So 22

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### 353



### that might make it a little trickier for you in 1


### terms of some of your analysis. 2



### MR. BROOKMAN: Comments on trial 3



### standard levels? No comments here. As we 4


### promised you first thing this morning, now 5



### there's an o pportunity for anybody that wishes 6


### to to make a concluding remark, a final 7


### statement, issues that haven't been covered 8


### sufficiently as we move towards closure. 9


### Nothing additional at this time, it seems. 10


### Then I'll turn it back to Lucy and, 11



### as I do, I'll thank you personally for a very 12


### productive meeting. There's an evaluation form 13


### that's at the bottom of your packet of 14



### information. Please take a minute and fill it 15


### out, and back to Lucy deButts. 16


### MS. deBUTTS: I just wanted to say 17


### thank you for everyo ne who contributed today. 18


### Again, we are welcoming all written remarks. 19


### We're going to be waiting for those, as 20


### promised, by May the 13th. And if you have any 21


### data, as I said, we would appreciate if the 22

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### 354



### Department could take a look at it. 1



### Other than tha t, I think we had a 2


### very productive discussion today. That's why 3


### we ran a little over. So thanks again. 4


### (Whereupon, the meeting was 5


### concluded at 3:52 p.m.) 6