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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, NEMA

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, Navigant 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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PRESENT VIA WEBINAR

ANDREA ALSTONE, LBNL

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 International

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, Advanced Lighting 

Technologies

ALEX VALENTI, LBNL

JUAN VELEZ, Westinghouse Lighting Corp

VAGELIS VOSSOS, LBNL

LINDA WILSON, NYS OAG
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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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1 P-R-O-C-E-E-D-I-N-G-S

2 9:00 a.m.

3 MR. BROOKMAN: Good morning, 

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

5 Department of Energy's public meeting on 

6 conservation standards preliminary analysis for 

7 general service fluorescent lamps and 

8 incandescent reflector lamps. 

9 Today is Tuesday, April 9th, 2013, 

10 here in the Forestall Building at the 

11 Department of Energy in Washington, D.C. 

12 My name is Doug Brookman from Public 

13 Solutions. Glad to have you here with us this 

14 morning. We'll start with welcoming remarks 

15 from Lucy deButts.

16 MS. deBUTTS: Good morning, 

17 everyone. Thank you for coming. Good to see 

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

19 members of the industry here.

20 We will be presenting the 

21 preliminary analysis for GSFLs and IRLs today 

22 and without further ado we can begin.
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1 MR. BROOKMAN: Thank you. Let's 

2 start with introductions as we typically do. 

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

4 organizational affiliation.

5 MR. HAKKARAINEN: Pekka Hakkarainen 

6 with Lutron Electronics.

7 MR. K. COOK: Keith Cook with 

8 Philips.

9 MR. GREEN: John Green with Eaton 

10 Cooper Lighting.

11 MR. BOESENBERG: Alex Boesenberg, 

12 NEMA.

13 MS. CALLAHAN: Susan Callahan, Osram 

14 Sylvania.

15 MR. HOWLEY: Joe Howley, GE 

16 Lighting.

17 MR. STEPHENS: Charlie Stephens, 

18 Northwest Energy Efficiency Alliance.

19 MR. ROSENSTOCK: Steve Rosenstock, 

20 Edison Electric Institute.

21 MR. STAS: Eric Stas, DOE General 

22 Counsel Office.
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1 Dr. GERKE: Brian Gerke, Lawrence 

2 Berkeley National Lab.

3 MS. KIENLE: Maureen Kienle, 

4 Navigant Consulting. 

5 MS. HUSAIN: Aisha Husain, Navigant 

6 Consulting.

7 MS. PIERCE: Julie Pierce, Navigant 

8 Consulting.

9 MR. BROOKMAN: Please introduce 

10 yourself.

11 DR. GARBESI: Karina Garbesi, 

12 Lawrence Berkeley National Lab.

13 MR. BROOKMAN: Thanks to all of you 

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

15 start on the day. 

16 All of you received a packet of 

17 information as you came in this morning and an 

18 agenda, a packet of PowerPoint slides and a 

19 Federal Register notice. 

20 Let me do very briefly a general 

21 review. Immediately following this agenda 

22 review there is the opportunity for anyone that 
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1 wishes to do so to make brief summary remarks 

2 about issues that matter to you for this 

3 meeting today. 

4 Following that we'll have overview 

5 and statute and context review. Then 

6 technology -- market and technology assessment 

7 and screening analysis and following that 

8 engineering analysis. We'll take a break mid9 morning-ish, 10:30, 10:45 or so. 

10 Following the mid-morning break, 

11 product price determination and then energy use 

12 analysis and life-cycle cost analysis. We'll 

13 take lunch around about noon today or whenever 

14 we get to noon-ish. 

15 Then following straight from there 

16 shipments analysis, national impacts analysis, 

17 preliminary manufacture impact analysis, NOPR 

18 analyses plural, and then closing remarks at 

19 the end of the day, another opportunity for 

20 anybody that wants to to raise additional 

21 issues. 

22 Make sure your issues are covered 
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1 during the course of this meeting today. 

2 Okay. So that's the plan. 

3 Questions or comments about any or all of that, 

4 Keith?

5 MR. K. COOK: Keith Cook from 

6 Philips. Question -- is there anybody on the 

7 line that --

8 MR. BROOKMAN: We have five -- how 

9 many? Twelve individuals on the line.

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

11 MR. BROOKMAN: Do you want to -- can 

12 you read off their names, Jack?

13 Why don't you hand Jack that 

14 lavalier mic? That's a good question.

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

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

17 James Cyre, Jennifer Amann, Linda Wilson, 

18 Michael Myer, Rachel Dickenson, Robert Lingard, 

19 Steve Stockdale and Tom Harding.

20 MR. BROOKMAN: Okay. Thank you. 

21 Many of you have participated in these meetings 

22 previously. I'd ask if you would please speak 
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1 one at a time. Please say your name for the 

2 record each time you speak. 

3 There will be a complete transcript 

4 of this meeting made available. If you could 

5 be concise -- please share the air time. There 

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

7 anyone's time. 

8 Please keep the focus here. Put 

9 your cell phones on silent mode. Limit sidebar 

10 conversations. You've already gotten used to 

11 turning these microphones on and off, and 

12 webinar participants, we welcome you. 

13 The Department of Energy wants to 

14 make these meetings accessible to all via the 

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

16 listening and you can raise your hand using the 

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

18 be doing my best as we go along, queuing 

19 individuals by name. 

20 Sometimes the follow-on, the back 

21 and forth between different perspectives is 

22 very useful for the department. So I wish to 
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1 encourage that as well. 

2 Do you want to do a few preliminary 

3 slides or do you just -- Lucy deButts.

4 MS. deBUTTS: Hi again. I just want 

5 to tell everyone that webinar participants, 

6 just like Doug mentioned, can actually talk to 

7 us if they raise their hand. Their 

8 comments are going to be made part of the 

9 transcript so they will be available on the web 

10 as well.

11 Okay. Well, let's begin with the 

12 purpose of this public meeting. The purpose 

13 is, of course, is to present the preliminary 

14 analysis for GSFLs and IRL products. 

15 We invite participants to comment on 

16 our analysis. We do appreciate your feedback. 

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

18

19 We will discuss the next steps in 

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

21 written comments or you just want to express 

22 your opinion right now in our open forum you 
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1 are more than welcome. 

2 We encourage that. In order to 

3 facilitate the discussion we are going to be 

4 using the issue boxes so throughout the 

5 presentation you will see those boxes. They 

6 will not be numbered in order. 

7 They will be numbered by -- in 

8 according to the issues that are presented in 

9 the preliminary analysis so if you'd like to 

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

11 more than welcome as well. 

12 Technical support documents are 

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

14 the docket, and as I mentioned the deadline for 

15 written comments was extended. It's now May 

16 13th of 2013.

17 And this is a slide on how to submit 

18 written comments. Again, please if you're 

19 submitting written comments write the title of 

20 the rulemaking, include the docket number and 

21 RIN number into the comment.

22 Comments can be submitted in a 
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1 number of ways. One is, of course, in an 

2 email, and then Brenda Edwards, who everybody 

3 met coming in today, she can receive the 

4 comments that are sent via postal service or 

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

6 comments are due to the Department of Energy.

7 Okay. Opening remarks?

8 MR. BROOKMAN: Remarks here at the 

9 outset summarizing concerns, issues that you 

10 wish to bring to the fore. Alex?

11 MR. BOESENBERG: Alex Boesenberg 

12 from NEMA. First, I want to thank the 

13 department for granting the extension on the 

14 comment period that industry and the advocates 

15 together have requested. 

16 That gives us more time to process 

17 the large amount of information and provide a 

18 better response and we appreciate that. 

19 And as far as my opening remarks 

20 regarding the content which we'll be discussing 

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

22 stated them back on October 5th, 2011, the last 
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1 public meeting -- concerns over whether or not 

2 there really are any feasible energy savings 

3 left given that the previous rule was very 

4 close to max tech.

5 And as we get into those individual 

6 areas we will examine or will comment on some 

7 of the analysis that pushes up into max tech or 

8 even beyond and we look forward to hearing the 

9 answers to our questions there about how the 

10 analysis came to those findings. So we'll get 

11 to that.

12 But we are concerned that the minor 

13 percentages being pursued in this rule, unlike 

14 some others, are detracting resources, both the 

15 department and in industry, away from rules 

16 that have a larger amount of savings which we 

17 could be tackling faster, arguably, by focusing 

18 on them first.

19 But this rule’s underway so we're 

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

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

22 MR. BROOKMAN: Thank you. Steve? 
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1 No? Other comments here at the outset? Okay. 

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

3 MS. deBUTTS: All right. So the --

4 Doug already went through the agenda and the 

5 presentation overview so right now let's start 

6 with regulatory history.

7 And this slide represents the 

8 regulatory history for this rulemaking. As you 

9 can see, the EPCA, Energy Policy and 

10 Conservation Act of 1992, amended the Energy 

11 Policy Act of 1975 and established energy 

12 conservation standards for certain classes of 

13 GSFLs and IRLs.

14 It also authorized DOE to conduct 

15 two rulemaking cycles to determine whether 

16 these standards should be amended and also 

17 direct the DOE to adopt standards for the 

18 additional GSFLs as warranted.

19 So DOE completed the first cycle of 

20 review in July of 2009 and that rule amended 

21 the existing standards for GSFLs and IRLs and 

22 adopted standards for additional GSFL types. 
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1 The standards require compliance -- required 

2 compliance. It started in July of 2012. 

3 So for the rest of this presentation 

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

5 rule” and the standards for those rulemakings 

6 as “July 2012 standards.”

7 DOE initiated the second rulemaking 

8 cycle for evaluation of GSFLs and IRL standards 

9 in September of 2011 and we published the 

10 framework document. 

11 We presented the framework document 

12 on October 4th of 2011 and now the preliminary 

13 analysis that is the subject of this 

14 presentation is the next stage of the second 

15 review of GSFL and IRL standards.

16 This is the -- this slide represents 

17 the schedule for GSFL and IRL rulemaking and as 

18 I mentioned already the framework document 

19 public meeting for presentation was held in 

20 September of 2011. 

21 The notice for the preliminary 

22 analyses was published on February 28th of this 
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1 year. 

2 What we're projecting next is two 

3 major notices to be published -- the notice of 

4 proposed rulemaking, or NOPR, which we are 

5 anticipating in March of 2014, and the final 

6 rule, which we're anticipating in November of 

7 2014.

8 MR. BROOKMAN: Lucy?

9 MS. deBUTTS: So that's it?

10 MR. BROOKMAN: Yes. We have a 

11 question. I'm sorry.

12 MS. deBUTTS: Sorry. 

13 MR. BROOKMAN: Steve Rosenstock.

14 MR. ROSENSTOCK: Steve Rosenstock, 

15 EEI. More of a comment than a question. I 

16 appreciate the regulatory history but I think 

17 there is missing is the legislative history --

18 EPACT 2005 and EISA 2007 which set standards 

19 for fluorescent lamp ballast, certain 

20 incandescent reflector lamps and I believe 

21 certain fluorescent lamps were -- standards 

22 were set in those pieces of legislation. 
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1 Again, I'd have to double check. 

2 There's a couple thousand of pages of things 

3 going through my head right now. 

4 Also, the November -- I think it was 

5 November 2011 final rule on fluorescent lamp 

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

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

8 talking about the regulation but you just can't 

9 -- the legislative history was just as 

10 important in this case for these products. 

11 Thank you.

12 MR. BROOKMAN: I think this was 

13 meant to be a very short summary.

14 MS. deBUTTS: Right.

15 MR. BROOKMAN: Okay. Okay. Thank 

16 you. 

17 MS. deBUTTS: Thanks. Okay. And 

18 the last piece, basically the compliance for 

19 this rulemaking, the compliance date would be 

20 in November of 2017, which is three years from 

21 the publication of the final rule.

22 Now, while DOE is establishing 
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1 standards it has to consider seven factors 

2 which are presented on this slide and they also 

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

4 factor and we are going to present our analysis 

5 throughout this meeting.

6 All right. So now we can go into 

7 the scope of this rulemaking. So DOE defines a 

8 general service fluorescent lamp as any 

9 fluorescent lamp that can satisfy the majority 

10 of fluorescent lighting application. 

11 Currently, standards cover six 

12 fluorescent lamp types shown on this slide with 

13 certain wattage ranges. This include 4-foot 

14 medium bi-pin base, 2-foot U-shaped, 8-foot 

15 slimline, 8-foot high output and the 4-foot 

16 mini bi-pin standard output and high output 

17 lamps.

18 In addition to reviewing and 

19 amending standards for the six covered 

20 fluorescent lamp types, the rulemaking also 

21 considers expanding coverage to additional 

22 fluorescent lamp types and wattages. 
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1 To make this assessment, DOE 

2 determines whether a lamp that is a candidate 

3 for a standard meets the general technical 

4 description of fluorescent lamp and does not 

5 fall under any exceptions specified in DOE's 

6 definition of the general service fluorescent 

7 lamp.

8 Then DOE determines whether the 

9 standard for the candidate lamp would result in 

10 significant energy savings and, further, if the 

11 standards would be technologically feasible and 

12 economically justified.

13 In assessing whether to extend 

14 coverage for additional lamp types, DOE 

15 considered fluorescent shapes not covered such 

16 as circline lamps and also lengths that are not 

17 covered such as 5-foot and 6-foot lamps.

18 However, DOE was not able to 

19 identify any additional lamp types that have 

20 market share or energy consumption that could 

21 result in substantial energy savings from those 

22 standards.
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1 So DOE is not extending scope of 

2 coverage for additional lamp types. We, 

3 however, decided to consider exclusions of 

4 additional -- inclusions of additional wattages 

5 for fluorescent lamp types already covered. 

6 DOE determined that certain covered 

7 lamp types are being offered in low wattages. 

8 Specifically, the 8-foot slimline is now 

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

10 standard output is in 25 watts and T5 high 

11 output in 44 and 47 watts.

12 Because those low wattage lamps have 

13 the potential to gain market share, standards 

14 for these lamps may offer energy savings. 

15 Therefore, DOE is considering including these 

16 wattages under the scope of coverage.

17 The new wattage limit under 

18 consideration are shown in green in this table. 

19 We also -- DOE is also considering 

20 modification to clarify the definition of 

21 general service fluorescent lamp as well as 

22 definition that exempt lamps and definition 
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1 exempt -- of exempt lamps designed and marketed 

2 for certain non-general applications. 

3 These definitions include impact 

4 resistant fluorescent lamp, reflectorized and 

5 aperture lamp, fluorescent lamp design for use 

6 in reprographic equipment, lamps primarily 

7 designed to produce radiation in the 

8 ultraviolet region of the spectrum.

9 We're also considering to define the 

10 term designed and marketed in similar 

11 terminology as it applies to the -- all 

12 lighting products.

13 Okay. That's all for the scope for 

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

15 considering notification -- oh, I'm sorry. 

16 Now IRLs are -- IRLs under the scope 

17 of coverage for this rulemaking must meet DOE 

18 definition of incandescent reflector lamps 

19 which are specified in this box that you can 

20 see on this slide. 

21 Even though we don't set the upper 

22 limit of wattages, existing IRL standards are 
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1 set between 40 and 205 watts because anything 

2 greater than 205 watts are mainly specialty 

3 lamps that comprise a small portion of the 

4 market and probably would not result in 

5 significant energy savings. 

6 We confirmed in our analysis that 

7 this remains the same so therefore we are 

8 keeping the range of wattages for this 

9 rulemaking between 40 and 205. And that brings 

10 us to the comments on the scope of coverage. 

11 MR. BROOKMAN: I see two comment 

12 boxes there. They list the specific lamp types 

13 they wish -- the department wishes to receive 

14 comment on both for GSFLs and then GSFL 

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

16 Alex Boesenberg?

17 MR. BOESENBERG: Regarding issue 

18 one, I wanted to -- I guess less a comment and 

19 more of a question and more of a clarifying 

20 statement.

21 While we don't necessarily disagree 

22 with the addition of low wattage lamps, I do 
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1 want to point out that those often being energy 

2 savers are subject to some performance 

3 restrictions. 

4 As we noted in the 2011 public 

5 meeting, some of these have difficulty 

6 operating in low temperatures and we'll make a 

7 greater point later on regarding the difference 

8 between 32- and 28-watt lamps that the 32 

9 watts, which are -- I would characterize as 

10 endangered by the TSD -- are the ones that are 

11 dimmable, and dimming is a performance feature 

12 that is highly desired and in fact the DOE 

13 claims energy savings based on dimming systems 

14 later. 

15 So we'll give that in greater 

16 detail. And as far as -- I did want to make a 

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

18 keeping the same as the previous rule. It --

19 because of how recently the 2011 standard or 

20 the 2012 standard went into effect it's 

21 difficult know where the market is.

22 But I'm curious if Navigant or the 
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1 labs for the DOE and the analysis noted there's 

2 -- are there any 130-volt products yet still 

3 available because our fear was they were going 

4 to be eliminated as a result of conformance.

5 MS. deBUTTS: Aisha?

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

7 130 volts products that were compliant.

8 MR. BOESENBERG: All right. Thank 

9 you.

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

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

12 the record. Steve Rosenstock.

13 MR. ROSENSTOCK: Steve Rosenstock, 

14 EEI. I have to say just from personal 

15 experience when I go to the hardware store to 

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

17 very highly efficient halogen IRL that was 

18 rated 39 watts to replace I believe it was a 

19 60-watt I'll say older version non-IRL, non --

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

21 the marketplace because of the -- I'll say the 

22 July 2012 standard there could be some things 
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1 going on at that lower end of the range where -

2 - again, just because of personal observation I 

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

4 know if that would be covered or not.

5 MR. BROOKMAN: Okay. Pekka?

6 MR. HAKKARAINEN: Pekka Hakkarainen 

7 and Lutron. Following to what Alex said a few 

8 minutes ago on dimmable lamps, I would also 

9 like to point out for the record that the full 

10 wattage lamps in both the T8 and T5 categories 

11 are the only ones for which there are dimming 

12 standards in the industry. So if we get 

13 rid of the full wattage lamps that are argon14 filled we also get rid of dimming.

15 MR. BROOKMAN: Okay. Thank you.

16 MR. HAKKARAINEN: I have a second 

17 comment on this IRL scope. The -- I'm a little 

18 bit confused about the scope as it reads right 

19 now. 

20 We have an ongoing rulemaking, I 

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

22 where the final rule has not been published 
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1 yet. Is this rulemaking going to affect those 

2 lamps as well?

3 MS. deBUTTS: No. Unfortunately 

4 right now, due to the appropriations rider DOE 

5 is not allowed to work on any standards that --

6 implementation or enforcement of any 

7 incandescent technology, all those R, ER and BR 

8 lamps. So we are not including those. They 

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

10 now allowed to work on it.

11 MR. HAKKARAINEN: Okay. That wasn't 

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

13 Okay. Thank you.

14 MR. BROOKMAN: Okay. Thank you for 

15 the question and thank you for the good 

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

17 next.

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

19 understand a little bit on the regulatory 

20 implications of this thing because I'm trying 

21 to understand why we're going through this 

22 rulemaking now. 
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1 The two rulemaking cycles that were 

2 authorized under EPACT 1992 was there a time 

3 when they would expire? Do those have to be 

4 completed by a certain date?

5 MR. BROOKMAN: Eric Stas?

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

7 there were deadlines in the statute. As you 

8 can see, DOE missed those deadlines. But, you 

9 know, we're not -- we haven't -- that doesn't 

10 absolve us of our obligation to do those 

11 rulemakings.

12 So we completed the first one in 

13 2009 and trying to follow on a similar schedule 

14 for what there was and we keep this -- we've 

15 also kept the same lead times. So now we're 

16 progressing with round two of the rulemaking.

17 MR. K. COOK: Even though round one 

18 never was fully implemented?

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

20 2009 rule, 2012 implementation date -

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

22 -- but due to the OHA stay a lot of the 700 
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1 series is still in the marketplace and so we 

2 never saw the full effect then of the first 

3 round.

4 MR. STAS: Right. Well, I guess 

5 that should be in your comments, obviously.

6 MR. K. COOK: It will be.

7 MR. STAS: And it should factor in 

8 the analysis I would --

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

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

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

12 rulemakings, right?

13 MR. STAS: Well, except the EISA 

14 2007 added the six-year look back so now all of 

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

16 later than six years later. 

17 So we do an ongoing review of 

18 standards and test procedures now -- test 

19 procedures on the seven-year cycle. 

20 But the specific authority we're 

21 going with our specific mandates first so this 

22 is the (i)(4) rulemaking -- sixth issue, ‘95 
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1 (i)(4), so we're completing that. 

2 But Congress at this point probably 

3 doesn't need to keep putting in specific 

4 provisions like that because we're going to be 

5 on a six-year cycle unless they choose for some 

6 urgent reason to direct us to do something much 

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

8 rulemakings.

9 MR. K. COOK: Okay. Thanks.

10 MS. deBUTTS: And I just wanted to 

11 add that we heard Susan when she was 

12 representing NEMA in the HID rulemaking one 

13 week ago she wanted us to coordinate the 

14 schedules for this rulemaking with HID so, you 

15 know, we'll try to accommodate this.

16 MR. BROOKMAN: Thank you. Please 

17 say your name.

18 MR. MCGARAGHAN: Good morning. It's 

19 Mike McGaraghan with Energy Solutions. I'm 

20 here representing the California investor-owned 

21 utilities. 

22 That's Pacific Gas & Electric, 
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1 Southern California Edison, San Diego Gas & 

2 Electric and SoCal Gas. I apologize for coming 

3 in a couple minutes late there. 

4 But a couple of comments to start 

5 off here.

6 First, just on the timing, we think 

7 that this is an appropriate time line for this 

8 rulemaking and applaud DOE for pushing forward 

9 with the mandate to complete the second rule. 

10 We commented in the previous -- at 

11 the framework stage that DOE should wait until 

12 the first lamp rule was in effect before coming 

13 out with the P-TSD, and DOE did that. 

14 By the time that this rule takes 

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

16 your slide 2018. That's a full six years after 

17 the previous rule and we think an appropriate 

18 amount of time.

19 MS. deBUTTS: '17. The compliance 

20 date is 2017.

21 MR. MCGARAGHAN: Okay. It sure 

22 looked like 2018 on the slide so maybe was it 
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1 end of 2017?

2 MR. BROOKMAN: November 2017.

3 MS. deBUTTS: Right.

4 MR. BROOKMAN: Very close to 2018.

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

6 MR. MCGARAGHAN: Yes. Thank you for 

7 clarifying, and then a couple of scope items. 

8 First, on GSFL I have a question on cold 

9 temperature lamps and it's my understanding 

10 that in the last rule cold temperature lamps 

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

12 they were clearly defined. 

13 You mentioned in a slide a page or 

14 two earlier that you're considering a 

15 definition for the term designed and marketed 

16 so I assume that that definition might apply to 

17 something like cold temperature. 

18 I would recommend developing a 

19 technical recommendation for cold temperature 

20 lamps. 

21 The next comment I have is on 2-foot 

22 lamps. It looks like DOE did some assessment 
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1 of the market and decided that 2-foot lamps are 

2 not common. 

3 I don't know what your criteria are, 

4 if you came to the conclusion that they are 

5 specialty lamps, but in my experience they're 

6 all over the commercial sector. 

7 I've spent several years working as 

8 a commercial lighting auditor and they're in 

9 virtually every building you walk into now, at 

10 least in the California buildings that I've 

11 been working in. 

12 So very surprised to find that you 

13 didn't see larger shipments of 2-foot lamps and 

14 would encourage you to take a closer look at 

15 that lamp category.

16 MR. BROOKMAN: Is that U-shaped?

17 MR. MCGARAGHAN: No. Straight 2-

18 foot lamps.

19 MR. BROOKMAN: Okay. 

20 MR. MCGARAGHAN: Lastly, comment on 

21 IRL definitions and just to follow up on 

22 Steve's comment I don't think his observation 
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1 in the hardware store was unique. 

2 I think there are a lot of products 

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

4 coincidence. I think it's because the 

5 standards end at 40.

6 So I would recommend that DOE take a 

7 look at extending that wattage range.

8 MS. deBUTTS: Okay. Thank you.

9 MR. BROOKMAN: Okay. Steve 

10 Rosenstock?

11 MR. ROSENSTOCK: Steve Rosenstock. 

12 In terms of the 2-foot lamps, a lot of those 

13 are in the -- not the general service. Aren't 

14 they mostly a lot of the task lighting type and 

15 in the furniture type or are you saying in the 

16 general --

17 MR. MCGARAGHAN: Yes.

18 MR. ROSENSTOCK: -- saying in the 

19 general ceiling?

20 MR. MCGARAGHAN: There are a lot of 

21 two-by-two fixtures that were previously U-bins 

22 that are now retrofitted with 2-foot lamps. 
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1 Lobbies -

2 MR. ROSENSTOCK: Not the 2-foot U3 tubes?

4 MR. MCGARAGHAN: No.

5 MR. ROSENSTOCK: The skinny U-tubes, 

6 2-foot straight bi-pin? Interesting. And 

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

8 close to the efficacy of the other ones too. 

9 They were replacing the 60-watt 

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

11 went up by 30, 40 percent.

12 MR. MCGARAGHAN: I think there's a 

13 wide range of efficiency of those 39-watt 

14 products.

15 MR. BROOKMAN: And Mike, just 

16 curious -- your experience is it mostly in 

17 California?

18 MR. MCGARAGHAN: Yes.

19 MR. BROOKMAN: I'm wondering about 

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

21 But anyway, following on, did you have a 

22 comment, Joe?
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1 MR. HOWLEY: Yes. Joe Howley with 

2 GE, just to say that, you know, data was 

3 provided to Navigant when they did this 

4 analysis and it basically showed that the sales 

5 of 2-foot lamps are substantially less than the 

6 sales of 4-foot lamps. 

7 So from an overall economic impact, 

8 although they're -- you know, maybe the 

9 buildings that you happened to be in happened 

10 to have 2-foot lamps, as a national standard 2-

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

12 -- the volume of them is much less frequent 

13 than 4-foot lamps.

14 MR. MCGARAGHAN: Okay.

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

16 assessment on extending. Also, the -- you 

17 know, the rule -- the '92 rule -- started at 40 

18 watts. We think that's appropriate. 

19 We don't feel that there is any 

20 reason to go lower. Quite frankly, lamps that 

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

22 and that's the whole point of the rule is to --
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1 is to put in lamps that use less energy. 

2 But we also think it's -- a 40-watt 

3 is an appropriate lower limit for IRLs in this 

4 regulation.

5 MR. BROOKMAN: Andrew deLaski?

6 MR. deLASKI: Comments -- Andrew 

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

8 had provided data on the sales of -- for across 

9 the market including the portion that's 2-foot 

10 lamps? Maybe I misheard you.

11 MR. HOWLEY: We -- yeah. I don't 

12 know that NEMA provided data but there was 

13 manufacturers interviews where we discussed 

14 verbally proprietary data. 

15 MR. deLASKI: So was that data in 

16 the docket? Does anybody know?

17 MS. deBUTTS: Aisha?

18 MS. HUSAIN: So in assessing those -

19 - the 2-foot linear lamps' inclusion -- we did 

20 take into account manufacturer feedback which 

21 indicated that there wasn't a strong shift 

22 towards these lamps. 
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1 We also looked at the Lighting 

2 Market Characterization in the 2010 report, 

3 which also was showing that the less than 4-

4 foot category didn't have a great market share 

5 as well.

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

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

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

9 percent? Is it 10 percent?

10 MS. HUSAIN: Yeah, I think it was 

11 around like -

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

13 10 percent that's a lot of -- that's a lot of 

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

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

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

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

18 the order of even a few percent of commercial 

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

20 something that we should potentially be taking 

21 a look at. 

22 So that would be our -- our point 
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1 would be we'd like to see the data.

2 MR. BROOKMAN: Aisha, can you 

3 comment further?

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

5 do have the LMC data here and I can circle 

6 back.

7 MR. BROOKMAN: We'll circle back 

8 too.

9 MR. deLASKI: That would be great. 

10 That would help us to assess sort of the --

11 what's going on here.

12 MS. HUSAIN: Sure.

13 MR. deLASKI: For those of us who 

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

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

16 like to see the data.

17 MS. HUSAIN: We would also welcome 

18 any other data that you can provide on this.

19 MR. deLASKI: Right. So the other 

20 question I have on the 40-watt question is is 

21 that a statutory limit or is that something the 

22 department has authority to go lower than 40 
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1 watts? Sort of an Eric question, I think.

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

3 statutory.

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

5 definition lately but unless it's in the 

6 definition and would throw something outside 

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

8 the past, if Congress set standards at a 

9 certain wattage level we've said when we do 

10 amendments we can expand that to some extent or 

11 go into some related types of lamps that they 

12 didn't particularly tackle in the statutory 

13 standard. 

14 So I don't think we're -- it's not 

15 in the definition where I can see.

16 MS. deBUTTS: No.

17 MR. STAS: So then we would have 

18 flexibility to tackle things.

19 MR. HOWLEY: Eric, if you look at 

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

21 slides ago -- it does have listed here directly 

22 -
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1 MR. BROOKMAN: What's the number? 

2 Joe, what's the number?

3 MR. HOWLEY: Slide 16.

4 MR. BROOKMAN: Thank you

5 MR. HOWLEY: Ten CFR 430.2 does have 

6 it in the -- has listed a statutory definition 

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

8 in the original 1992 law.

9 MR. BROOKMAN: Thank you for that.

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

11 to make me pull out my statute now.

12 MR. BROOKMAN: Aisha, were you going 

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

14 MS. HUSAIN: Yeah, I was just going 

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

16 T8s less than 4-foot of installed stock as well 

17 as the T12s and that's about one terawatt 

18 energy consumption for the T8s less than 4-foot 

19 as well as the T12s less than 4-foot. So those 

20 are the numbers they're reporting. 

21 But, again, if you have other data 

22 at the national level or any other data that 
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1 would be helpful. 

2 MR. deLASKI: So just to read --

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

4 got it right. So you said .2 percent -

5 MS. HUSAIN: Installed stock, yeah.

6 MR. deLASKI: -- of installed stock 

7 --

8 MS. HUSAIN: Yeah.

9 MR. deLASKI: -- is two feet or less 

10 than --

11 MS. HUSAIN: Is less than 4-foot.

12 MR. deLASKI: It's less than 4-foot.

13 MS. HUSAIN: Right.

14 MR. deLASKI: Okay.

15 MR. BROOKMAN: And then back to the 

16 statutory question, Eric.

17 MR. STAS: I may stand corrected 

18 here. Okay. So unless I'm missing -- so 

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

20 incandescent lamp.

21 It says any lamp commonly referred 

22 to as a reflector lamp which is not colored and 
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1 is blah, blah, blah. Rated voltage or voltage 

2 range lies at least partially within 115 and 

3 130 volts, a diameter which is exceeds 2.25 

4 inches and has a rated wattage that is 40 watts 

5 or higher.

6 MS. deBUTTS: So it's in the 

7 statute.

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

9 MS. deBUTTS: Right.

10 MR. STAS: So that does stand 

11 corrected. It wasn't just in DOE's regulations 

12 so it seems like a limit more bound.

13 MS. deBUTTS: Yeah. Okay.

14 MR. BROOKMAN: Thank you for that 

15 clarification. Charlie Stephens?

16 MR. STEPHENS: Charlie Stephens. I 

17 guess if it's in the statute I don't think 

18 anybody's going to be messing with it anytime 

19 soon but it's increasingly less useful as we 

20 shift technologies, and when you have a 

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

22 trying to deliver a certain number of lumens 
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1 and as we move toward fewer and fewer watts 

2 that eventually you're going to just hit those 

3 lumens and wattage is not a very good way to 

4 define what's covered. 

5 The whole point is to use fewer and 

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

7 going to be getting down into those lower 

8 wattages down into the 20-watt category to 

9 deliver the same number of lumens that a 60-

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

11 of the way we're headed.

12 But so for now you may not be able 

13 to mess with it but I'd -- you know, some of us 

14 have sort of seen this coming for a long time 

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

16 things like street lighting. But so at some 

17 point we may have to do something about this.

18 MS. deBUTTS: Now it's a legal 

19 question, Eric.

20 MR. BROOKMAN: Keith?

21 MR. K. COOK: Keith Cook from 

22 Philips. I'm a little concerned that we're 
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1 losing sight of the original intent of EPACT 

2 here. The original intent was to get rid of 

3 less efficient lights, period. 

4 It was not to cover every fricking 

5 product that's made. If it's already efficient 

6 it was not supposed to be covered. I think 

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

8 you know, process.

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

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

11 second issue -- no, pardon me. GSFL is issue 

12 two -- GSFL definition. So comments on that as 

13 well. 

14 We haven't got -- we have one 

15 comment on IRLs. Comments on the definition 

16 before we move on? No comments? Joe?

17 MR. HOWLEY: The proposed changes 

18 look acceptable to industry.

19 MR. BROOKMAN: Okay. Are you 

20 speaking on behalf of NEMA there?

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

22 had a discussion on this, yes.
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1 MR. BROOKMAN: Thank you. Okay. 

2 We're moving on.

3 MR. MCGARAGHAN: Doug?

4 MR. BROOKMAN: Oh, yes. Mike?

5 MR. MCGARAGHAN: Hi. Mike 

6 McGaraghan. I had one other question on how 

7 you intend to structure the rulemaking, 

8 following up on Charlie's point that lumens are 

9 a better metric to identify lamp performance 

10 than watts.

11 Even if the scope remains based on 

12 wattage will DOE consider a lumen-based 

13 standard rather than a wattage-based standard? 

14 Or is that something we can talk about later?

15 MS. HUSAIN: This is for IRLs. 

16 MR. BROOKMAN: This is Aisha 

17 speaking.

18 MS. HUSAIN: This is Aisha. Sorry. 

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

20 we aren't -- in this preliminary analysis we 

21 haven't considered changing the metric. 

22 We did look at -- I know in the 
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1 framework we had discussed possibly using an 

2 application-efficacy-based metric and just 

3 based on manufacturer feedback and talking with 

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

5 on in developing such a metric and such a 

6 metric would require probably encompassing all 

7 types of directional lamps.

8 So the scope of it seemed to be 

9 bigger than what we have here and would 

10 require, you know, the inclusion of looking at 

11 LEDs as well and other directional lamps. So 

12 at this time for this analysis we didn't 

13 consider it.

14 MR. MCGARAGHAN: Okay. Thank you. 

15 My question was slightly different. Whether we 

16 look at lumens per watt or beam lumens per watt 

17 or some other application efficacy, the 

18 question is about whether the standards are 

19 tied to your wattage as a product or whether 

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

21 calculate the standard.

22 And we would recommend following up 
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1 on Charlie's comment just that we move in the 

2 direction of lumen-based standards because 

3 lumens are really what's useful to a consumer 

4 and watts is not a useful metric anymore. You 

5 end up with packages that say 55 equals 70 and 

6 that just doesn't make any sense. 

7 So in general as much as possible 

8 the DOE can help shift that discourse to be 

9 lumen-based instead of wattage-based and the 

10 standards are one way to help do that.

11 MS. HUSAIN: So it is the -- we are 

12 using the power law equation that relates 

13 lumens and wattage. 

14 But we would welcome any comments on 

15 that when we get into the engineering analysis 

16 if you have other ideas.

17 MR. BROOKMAN: Thank you, Aisha. 

18 Pekka?

19 MR. HAKKARAINEN: Pekka Hakkarainen, 

20 Lutron. Mike, I'm not understanding where you 

21 are getting at. What problem are you trying to 

22 solve with that? 
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1 MR. MCGARAGHAN: So just there's a 

2 focus on wattage and what you might see is for 

3 a specific product type manufacturers 

4 accustomed to designing to a wattage because 

5 that's what consumers are used to. 

6 So you might design to 50 watts 

7 regardless of your -- the efficiency of your 

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

9 products giving more or less light.

10 MR. HAKKARAINEN: But the efficiency 

11 standards would not allow you to design to just 

12 any lumen output. 

13 So are you -- is this a way to 

14 extend the coverage of what products are 

15 covered or is this to help consumers understand 

16 what's going on?

17 MR. MCGARAGHAN: It's just to help 

18 ensure that as we improve efficiency we're 

19 reducing wattage rather than increasing light.

20 MR. BROOKMAN: Steve Rosenstock?

21 MR. ROSENSTOCK: Steve Rosenstock, 

22 EEI. I know for the last I don't know how many 
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1 years any time a consumer looks at a compact 

2 fluorescent bulb in the store the box is going 

3 to say something like 26 watts equals 100 watts 

4 just so the consumer knows that if they have an 

5 incandescent baseline at home if they replace 

6 it with the 26-watt, the light output should be 

7 equivalent or even possibly even higher, 

8 depending on the manufacturer and the 

9 technology used. 

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

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

12 sure the consumer understands what they're 

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

14 they're looking for a performance and so by 

15 doing -- showing the watts and also showing the 

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

17 know, what are they getting compared to what 

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

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

20 So I mean, there are -- there is a 

21 requirement for those lamps to be more 

22 efficient on an efficacy basis. I think when 
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1 you're talking about what's important to 

2 consumers that's -- you know, I think that 

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

4 in a transition phase for all these products.

5 And so I think, especially -- I'll 

6 just say for the incandescents, the boxes that 

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

8 this 72-watt halogen bulb is equal to your old 

9 100-watt incandescent bulb so people know what 

10 they're getting and they know what the 

11 relatively equivalent light output is. 

12 Otherwise, again, whether we like it 

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

14 100 years most people associate higher watts 

15 with higher lumens and even with the CFLs and 

16 LEDs that's still the case.

17 MR. BROOKMAN: I think these points 

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

19 They've been made. 

20 MS. deBUTTS: Okay. So this slide 

21 shows the preliminary analysis stage and the 

22 analyses that were done by DOE. At this point, 
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1 Aisha will present the analysis for marketing 

2 and technology assessments and screening 

3 analysis.

4 MS. HUSAIN: Hi. My name is Aisha 

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

6 discuss the market and technology and screening 

7 analyses. 

8 The purpose of the market and 

9 technology assessment is to determine product 

10 classes and identify technology options that 

11 improve lamp efficacy.

12 Technology options are identified --

13 are then evaluated against four criteria, which 

14 are that the option is technologically 

15 feasible, that it is practical to manufacture, 

16 install and service on a commercial scale by 

17 the compliance date of the standards, that it 

18 doesn't have any adverse impacts on utility to 

19 the consumer or availability and it doesn't 

20 have any adverse impacts on health or safety.

21 Those technology options not 

22 screened out are analyzed as design options in 
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1 the engineering analysis.

2 For product classes, DOE divides 

3 covered products into classes by type of energy 

4 used, capacity of the product or any other 

5 performance-related features that might impact 

6 consumer utility.

7 A separate standard is then set for 

8 each of these categories of products. DOE is 

9 considering maintaining the same product class 

10 divisions established in the 2009 lamps rule. 

11 For GSFLs three product class 

12 setting factors are being considered. DOE is 

13 considering establishing a product class based 

14 on correlated color temperature, or CCT. 

15 CCT is a measure of perceived color 

16 of white light and therefore different CCTs can 

17 have different utilities for consumers. Also,

18 because the spectral emission of the lamp is 

19 modified to change CCT, the lamp efficacy also 

20 changes.

21 DOE has specifically observed that 

22 there's a decline in efficacy in lamps with 
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1 CCTs greater than 4,500 K and therefore is 

2 considering establishing a separate product 

3 class for lamps with CCTs less than or equal to 

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

5 DOE is also considering product 

6 classes based on physical constraints. 

7 Consumer utility may be impacted when consumers 

8 have to change, for example, the ceiling design 

9 or architecture in order to substitute lamps 

10 with different geometries.

11 Additionally, lamp length impacts 

12 efficacy. The 8-foot linear lamps are 

13 generally more efficacious than the 4-foot 

14 linear lamps. 

15 Shape is also a factor. The 2-foot 

16 U-shaped lamps are less efficacious than the 4-

17 foot linear lamps even though they are 4-feet 

18 when straightened out. Therefore, DOE is 

19 considering establishing product classes based 

20 on lamp length and shape.

21 DOE is also considering lumen 

22 package as a class setting factor. Lumen 
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1 package of fluorescent lamps is -- which is the 

2 quantity of light produced by the lamp and 

3 ballast system -- provides different utilities 

4 to consumers. 

5 High lumen outputs are -- tend to be 

6 used in high ceiling applications or outdoors 

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

8 higher currents, which results in a decrease in 

9 efficacy. 

10 Therefore, DOE is considering 

11 establishing separate product classes for 

12 standard output and high output lamps.

13 So this table presents the resulting 

14 12 product class divisions DOE is considering 

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

16 same product classes established in the 2009 

17 lamps rule.

18 MR. BROOKMAN: Steve Rosenstock?

19 MR. ROSENSTOCK: Steve Rosenstock, 

20 EEI. On that last one about the high lumen 

21 package in terms of designing to run with 

22 ballast at high currents, did the November 2011 
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1 rule change that? Did those ballasts also 

2 increase in efficacy as well as part of the 

3 November 2011 rule?

4 MS. HUSAIN: The ballast rule?

5 MR. ROSENSTOCK: Yes.

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

7 Maureen can answer that. 

8 MS. KIENLE: Yes. The standards 

9 increased for that 2011 rule.

10 MR. ROSENSTOCK: Thank you.

11 MR. BROOKMAN: Say your name again.

12 MS. KIENLE: Maureen Kienle.

13 MR. BROOKMAN: Maureen, leave that 

14 thing on.

15 MS. KIENLE: Okay.

16 MR. BROOKMAN: Thank you. Alex?

17 MR. BOESENBERG: Alex Boesenberg, 

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

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

20

21 Is that -- is for the lumen package 

22 and related analysis, did the DOE use 2011 rule 
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1 conforming ballasts for their analysis?

2 MS. KIENLE: Yes.

3 MR. BOESENBERG: Okay. That's --

4 thank you.

5 MR. BROOKMAN: Thank you. 

6 MS. HUSAIN: So for IRLs, DOE is 

7 also considering three product -- three product 

8 class setting factors. 

9 Let's see -- DOE is considering 

10 spectrum as a class setting factor. Modified 

11 spectrum lamps provide a different type of 

12 utility for consumers and they also change the 

13 spectrum because they absorb a portion of the 

14 visible light.

15 So DOE is considering establishing a 

16 separate product class for modified spectrums 

17 and standard spectrum lamps. 

18 DOE is also considering a product 

19 class setting factor as diameter. Small 

20 diameter lamps provide a different utility for 

21 consumers because they can be installed in 

22 smaller fixtures. 
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1 They also have an inherently lower 

2 optical efficiency than larger diameter lamps 

3 and they -- and they cannot utilize the same 

4 technology options as larger diameter lamps 

5 such as the double-ended capsule. 

6 So DOE is considering establishing 

7 separate product classes for lamps with a 

8 diameter of 2.5 inches or less and lamps with a 

9 diameter greater than 2.5 inches.

10 So DOE is also considering voltage 

11 as a class setting factor. DOE has found that 

12 most consumers operate 130-volt IRLs at 120, 

13 which reduces efficacy while increasing 

14 lifetime. 

15 However, existing DOE test 

16 procedures require lamps rated at 130 volts to 

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

18 120 to be tested at 120.

19 Therefore, compared to a 120-volt 

20 lamp, a 130-volt lamp will test at a higher 

21 efficacy. 

22 So when technologies -- so when you 
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1 have a single efficacy level for all voltages, 

2 the 130-volt lamp would not require as 

3 efficient technologies to meet the standard as 

4 a 120-volt lamp.

5 The need for less efficient 

6 technologies could make the 130-volt lamp less 

7 costly to produce and cheaper to buy. This 

8 could potentially result in a migration to 130-

9 volt lamps. 

10 Further these lamps are partially 

11 dimmed when operated at 120 volts and therefore 

12 to meet their light output consumers could 

13 purchase higher wattage 130-volt lamps or even 

14 more than one.

15 This could result in an increase in 

16 energy consumption. Therefore, DOE is 

17 considering separate product class divisions 

18 based on lamps with a rated voltage less than 

19 125 volts and rated voltage greater than 125 

20 volts.

21 MR. BROOKMAN: Steve Rosenstock?

22 MR. ROSENSTOCK: Steve Rosenstock, 
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1 EEI. A couple of quick comments. When you say 

2 a large number of consumers, what do you mean 

3 by that? 

4 What are -- what do you say is 

5 large? Is this 50 percent? Eighty percent of 

6 customers? Residential, commercial 50 percent? 

7 Twenty percent?

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

9 specific percentage but generally we got the 

10 impression that most consumers are operating 

11 them at 120 volts.

12 MR. ROSENSTOCK: Well, I understand 

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

14 they're getting in their house or their 

15 business. Yes, they are operating 120-volt. 

16 But you say -- yeah, I would say 

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

18 again, it's a matter of -- the issue is what 

19 percentage of -- I was really getting at what 

20 percentage of the market or sales is 130-volt 

21 lamps.

22 MS. HUSAIN: So as we stated 
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1 previously, we didn't find a lot of 130 -- we 

2 didn't find any compliant 130-volt products. 

3 The manufacturers can also maybe weigh in on 

4 the market share.

5 MR. ROSENSTOCK: Well, I have a 

6 couple other follow-up comments.

7 MR. BROOKMAN: Let's hear from the 

8 manufacturers. Joe, do you want to start?

9 MR. HOWLEY: The -- well, a few 

10 points. One is that the efficiency of a 130-

11 volt as you go higher in voltage, the 

12 efficiency actually decreases. It doesn't 

13 increase. 

14 We believe this was misanalyzed in 

15 the first rulemaking, the 2009 lamps rule, 

16 which led to an extremely high efficiency being 

17 set on them which led to the fact that today 

18 you don't see any 130-volt lamps in the market. 

19

20 They've essentially been regulated 

21 out of the marketplace by the somewhat 

22 misanalysis, let's say, in the 2009 rule, which 
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1 produced a higher standard for lamps which are 

2 less efficient at 130 volts.

3 And that's why we have the market 

4 condition we have today, which is since July 

5 2012, these products essentially no longer are 

6 manufactured.

7 MR. BROOKMAN: Okay. Steve?

8 MR. ROSENSTOCK: Thank you. I 

9 really appreciate that. I guess a couple of 

10 other thoughts is I recall after my going to 

11 the lighting school is that the 130-volt lamps 

12 operating at 120 volts, that the lifetime is 

13 increased by approximately 2.9 times. 

14 So if a standard lamp was 1,000 

15 hours that the 130-volt on a 120-volt system 

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

17 take. 

18 I think that was the ratio, again, 

19 based on what I had seen, again, for -- a 

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

21 half times. Does DOE consider that a bad 

22 thing?
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1 MS. HUSAIN: No, DOE doesn't 

2 consider that a bad thing.

3 MR. ROSENSTOCK: Okay. I'm just 

4 kind of curious because --

5 MS. HUSAIN: That was incorporated 

6 when we were determining the scaling factor.

7 MR. ROSENSTOCK: Okay. And when you 

8 say, you know, again, reduced efficacy probably 

9 before or after, again, just thinking with a 

10 lot of these lamps on dimmers it's even --

11 again, there was a reason for people putting in 

12 these lamps and, again, for some areas that 

13 they -- sometimes the voltage was higher than 

14 120 volts and they worried about, you know, 

15 sometimes lamps blowing out. 

16 If they put 130 volts give a little 

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

18 regulated out, the consumers have lost that 

19 utility. 

20 So I think -- and again, I know 

21 there's an anti-backsliding rule but, again, 

22 there's been -- for those consumers it's been a 
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1 loss of utility and if they've had to switch 

2 from 130 to 120 volts guess what? Their number 

3 of lamps they've had to buy has increased.

4 MR. BROOKMAN: Alex, do you want to 

5 comment here? Okay.

6 MR. deLASKI: I just have a data 

7 question, which is, Joe, what was the -- what 

8 were the sales of these lamps prior to the 2009 

9 rule going into effect?

10 MR. HOWLEY: I don't know the exact 

11 number but I think industry sold quite a few of 

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

13 MR. deLASKI: Was it 50 percent of 

14 the market or 1 percent of the market?

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

16 MR. deLASKI: Was it 1 percent?

17 MR. HOWLEY: It was higher than 1 

18 percent. Somewhere between 1 and 50 percent 

19 but I don't know what -

20 MR. deLASKI: Joe, your precision 

21 astounds me.

22 (Laughter.)
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1 MR. BROOKMAN: Does that data exist?

2 MR. deLASKI: Does NEMA -

3 MR. BOESENBERG: Well -- Alex 

4 Boesenberg, NEMA -- that would have been part 

5 of the previous rule since our strong 

6 inclination is to say there are no more 

7 products available. So we don't have a new --

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

9 -- so what Joe is describing for us is an 

10 unintended consequence of the rules. We're 

11 trying to understand -

12 MR. BOESENBERG: Right.

13 MR. deLASKI: -- what the breadth of 

14 that impact is and, you know --

15 MR. BOESENBERG: Well, perhaps since 

16 there was a previous rule perhaps Navigant have 

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

18 don't have it with me.

19 MR. deLASKI: Okay.

20 MR. BROOKMAN: Lucy deButts?

21 MS. deBUTTS: There's also data 

22 available in the docket which is online. So if 
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1 you'd like to visit the docket for the previous 

2 ruling you can do so as well.

3 MR. BROOKMAN: Do you think the data 

4 is there?

5 MS. deBUTTS: Well, whatever is 

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

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

8 specific data would be there but you can check.

9 MR. deLASKI: I mean, you guys know 

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

11 sense of -

12 MR. HOWLEY: Individual 

13 manufacturers know but I do not believe NEMA 

14 captures that --

15 MR. deLASKI: Okay.

16 MR. HOWLEY: -- particular product 

17 as a market segment. So the industry doesn't 

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

19 the industry was provided on that.

20 MR. deLASKI: Okay.

21 MR. HOWLEY: Individual 

22 manufacturers knew what their sales were 
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1 previously and there were manufacturer 

2 interviews where that was somewhat discussed 

3 but some of that information was proprietary. 

4 So I'm not sure if they'll --

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

6 by NEMA into data submitted by the department?

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

8 MR. deLASKI: Okay. All right. 

9 Thanks.

10 MR. BROOKMAN: Mike?

11 MR. MCGARAGHAN: Mike McGaraghan. I 

12 just want to clarify. Steve, you mentioned 

13 that there might be a utility that was taken 

14 from the consumers. 

15 I think my assumption and I think 

16 everyone would agree is that the overwhelming 

17 majority of those lamps, maybe even 100 

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

19 120 volts. 

20 The real utility that they provided 

21 was that they were long-life lamps. So maybe 

22 there's data on exactly how many people use 
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1 them because of voltage spikes. 

2 That would be great to see. But 

3 assuming their primary utility was long life, 

4 that utility has not been eliminated from the 

5 market. There are still lots of long-life 

6 lamps on the market.

7 MR. BOESENBERG: Alex Boesenberg, 

8 NEMA. I was going to comment that the feedback 

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

10 call from somebody it's about voltage spikes. 

11 They put in a 130-volt because it's more 

12 survivable. 

13 The lifetime -- what they want to do 

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

15 added lifetime is a -- that's gravy. 

16 The fact that it survives at all was 

17 the sales point, the purchase point, whatever 

18 you want to call it.

19 MR. BROOKMAN: Is there anything --

20 where are we at this moment?

21 MS. HUSAIN: We're summarizing the 

22 IRL product class division.
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1 MR. BROOKMAN: Okay. So keep going.

2 MS. HUSAIN: So this table presents 

3 the resulting eight product class divisions 

4 being considered for IRLs. As noted, these are 

5 the same as those for establishing the 2009 

6 lamps rule.

7 DOE requests comments on the product 

8 classes that it is considering for GSFLs and 

9 IRLs. 

10 MR. BROOKMAN: Comments on product 

11 classes? No comments here. Steve Rosenstock?

12 MR. ROSENSTOCK: Steve Rosenstock, 

13 EEI. I guess the issue is if the regulations 

14 have pretty much eliminated the production of 

15 125-volt -- 130-volt IRLs, I'm not sure what 

16 more analysis gets you.

17 MR. BROOKMAN: Okay. Thank you. No 

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

19 MS. HUSAIN: Okay. Now we will move 

20 on to a discussion of technology options. DOE 

21 has identified the following technology options 

22 that can improve GSFL efficacy. 
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1 These technology options include 

2 such technologies as high efficiency phosphors 

3 which increase conversion of UV to visible 

4 light, glass coatings which help phosphors 

5 absorb more UV light and high efficiency 

6 diameters.

7 For IRLs, DOE identified the 

8 following technology options that can improve 

9 IRL efficacy. These include technologies 

10 related to the filaments such as coiling, 

11 placement and orientation -- also the use of 

12 high efficiency fill gases, as well as 

13 coatings, such as infrared glass coatings that 

14 are used to reflect radiant energy back onto 

15 the filaments.

16 DOE requests comments on the 

17 technology options being considered for GSFLs 

18 and IRLs. 

19 For GSFLs in particular, DOE would 

20 like feedback on whether high efficiency 

21 diameters should be retained as a technology 

22 option in light of a possible market shift away 
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1 from less efficient diameters.

2 MR. BROOKMAN: Alex?

3 MR. BOESENBERG: Alex Boesenberg, 

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

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

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

7 remember where I put it.

8 Perhaps one of my members can chime 

9 in. Regarding technology options, one thing 

10 that we didn't agree with was glass coatings 

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

12 anybody remember the other one?

13 MR. BROOKMAN: Keith?

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

15 We did not understand what you meant by 

16 optimizing diameters. We couldn't figure that 

17 one out to save us.

18 MS. HUSAIN: The high efficiency 

19 diameters for -

20 MR. K. COOK: Yeah. Could you 

21 clarify that one for us, please?

22 MS. HUSAIN: So we're talking about 
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1 when you're able to -- for small diameter lamps 

2 increase the diameter and increase efficacy 

3 that way. 

4 Now, there is a limit when in large 

5 diameter lamps you wouldn't want to increase 

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

7 sort of range of a larger diameter that you 

8 could achieve that would improve efficacy.

9 MR. HOWLEY: Are you referring to 

10 GSFLs here or IRLs? Which technology?

11 MS. HUSAIN: This would be GSFLs.

12 MR. HOWLEY: Okay. So with GSFLs 

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

14 T12s, which are mostly being eliminated by the 

15 2009 rule, have actually a less efficient 

16 diameter. 

17 You said you're shifting towards 

18 less efficient diameters but indeed it's the 

19 opposite of that. We're shifting towards more 

20 efficient diameters. 

21 The T5 to T8 range is the most 

22 efficient diameter range for fluorescent 
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1 technology which is why the industry has 

2 gravitated to those diameters around the world. 

3 It does produce the highest efficiency. 

4 So this is why this comment doesn't 

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

6 gone is to the most efficient diameters for 

7 fluorescent technology.

8 MS. HUSAIN: Right. So we were 

9 asking that -- so the trend you're describing 

10 is the shift away from the less efficient 

11 diameters.

12 MR. HOWLEY: Right.

13 MS. HUSAIN: And if that is 

14 happening and all the diameters that are on the 

15 market right now are of optimal efficiency then 

16 we wouldn't consider this as a technology 

17 option.

18 So that's what we were trying to 

19 assess. If all the products have this in the -

20 - if all the products have this characteristic 

21 then there's, like, no room for using diameters 

22 as a means for improving efficacy.
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1 MR. HOWLEY: That's correct.

2 MR. BROOKMAN: That's correct.

3 MS. HUSAIN: That's all we were 

4 trying to ask.

5 MR. HOWLEY: Okay. Good.

6 MR. BOESENBERG: Alex Boesenberg. 

7 So industry feels that T5 and T8 are highly 

8 efficient optimized diameters and what we 

9 specifically were worried or want to state is 

10 that we can assure you is not the case, a T4 or 

11 a T7 is not the way to go.

12 MR. BROOKMAN: Pekka?

13 MR. HAKKARAINEN: My comment --

14 Pekka Hakkarainen in Lutron -- my comment is 

15 about the higher efficiency fill gas 

16 conversation -- again, very similar to what we 

17 already discussed before. 

18 If you mean fill gases that include, 

19 say, krypton you will find that those lamps are 

20 going to be unsatisfactory under dimming 

21 conditions. 

22 So I caution against going in that 
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1 direction because the savings that the 

2 technical support document attributes to 

3 operation under dimming systems will be lost 

4 and I think appendix whatever number it was 

5 indicated that the actual energy savings from 

6 those systems are 33 percent. We can argue 

7 whether that's the number or not. 

8 But I generally agree that that's 

9 the sort of actual energy savings that you are 

10 going to get as opposed to these on-paper 

11 energy savings that we are talking about here 

12 with regard to increased lamp efficacy.

13 MR. BROOKMAN: Alex?

14 MR. BOESENBERG: Alex Boesenberg, 

15 NEMA. I have two other points to raise 

16 regarding technology options. Listed on that 

17 is integral transformer low-voltage halogen IR 

18 and we disagree that that is suitable. 

19 That is not a viable technology for 

20 higher wattages. So in terms of Navigant 

21 terminology that's not scalable. So it's a 

22 niche product. 
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1 It works well at what it does. It's 

2 not a good option to apply across the board. 

3 And another note is we disagree that high 

4 efficiency or filament placement is a big deal 

5 for improving efficacy or efficiency. 

6 The filament placement is where it 

7 is, you know, largely because of the beam 

8 spread you're trying to achieve. 

9 That's one of those, you know, as 

10 listed in EPCA and already mentioned there on 

11 Slide 20 that's a performance characteristic.

12 You want the beam to be thrown a 

13 certain way. So where you place filament is 

14 directly -- affects that. So could it be a 

15 little more efficient if you rammed it down 

16 farther in the case? I don't know, but you 

17 won't get the same beam spread. That's the 

18 whole point. So you're -- when you push on one 

19 your raise the other and down, vice versa. 

20 So we disagree that that being a 

21 technology option for increasing efficiency. 

22 It's there for a reason.
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1 MR. BROOKMAN: Mike?

2 MR. MCGARAGHAN: Mike McGaraghan. 

3 MR. BROOKMAN: Hey, Mike, we have a 

4 comment from Navigant.

5 MS. PIERCE: Sorry. Julie Pierce, 

6 Navigant. For the integrally ballasted low 

7 voltage lamps what wattage ranges did those not 

8 work on?

9 MR. BOESENBERG: Good question. All 

10 I know is we disagree that it shouldn't go up. 

11 Anybody make one here? 

12 MR. BROOKMAN: Yes. 

13 MR. BOESENBERG: I can relay that in 

14 our public comments -- written comments.

15 MS. PIERCE: Okay. Thank you.

16 MR. BROOKMAN: And then Eric has a 

17 question.

18 MR. STAS: Early you mentioned that 

19 you disfavored the use of glass coatings. Can 

20 you explain why, briefly?

21 MR. BOESENBERG: I will also amplify 

22 on that in our public comments.
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1 MR. BROOKMAN: Okay. Mike?

2 MR. MCGARAGHAN: No comment.

3 MR. BROOKMAN: Okay. I can circle 

4 back if we need to. We're moving on.

5 MS. HUSAIN: Okay. I think we 

6 covered all the comments here. So now I'll 

7 move into screening analysis. 

8 For the screening analysis, DOE 

9 reviewed the technology options identified and 

10 assessed them based on the four screening 

11 criteria to determine which ones should be 

12 considered as design options in the engineering 

13 analysis. 

14 Of the technology options identified 

15 for improving GSFL efficacy, DOE determined 

16 that multi-photon phosphors should be screened 

17 out. Since this technology remains in the 

18 research phase, DOE determined that it is not 

19 technologically feasible.

20 Of the technology options identified 

21 for improving IRL efficacy, DOE determined that 

22 those shown in red here should be screened out. 
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1

2 The majority of these technology 

3 options were screened out because they were not 

4 found in commercially available lamps and 

5 therefore could not be determined to be 

6 practical to manufacture on a commercial scale. 

7

8 Some of the options were also not 

9 technologically feasible and a few had an 

10 adverse impact on product utility.

11 DOE requests comments on the 

12 technology options eliminated during the 

13 screening analysis.

14 MR. BROOKMAN: Alex?

15 MR. BOESENBERG: Alex Boesenberg, 

16 NEMA. I'll add a comment on the reference to 

17 high efficiency fill gases and such like that 

18 and will expand on this in our public comments. 

19

20 But relative to my earlier comment 

21 about driving to the -- increasing the use of 

22 low wattage lamps and the trade-off for 
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1 utilities, which is cold temperature, 

2 striation, dimmability and things like that, 

3 that's one of those things that we -- when you 

4 drive up the krypton in a lamp to increase its 

5 efficiency but krypton doesn't want to dim. 

6 So that's a performance 

7 characteristic, both the dimmability and the 

8 flicker instability, striations and things like 

9 that. 

10 So that's another trade-off that we 

11 encourage Navigant to explore and make sure you 

12 get the balance right.

13 MR. BROOKMAN: Steve Rosenstock?

14 MR. ROSENSTOCK: One thing to follow 

15 up on that issue is I'm involved with building 

16 codes with ASHRAE and IECC and in many -- most 

17 of the more recent iterations there was a 

18 requirement for more and more lighting controls 

19 to provide maximum energy savings and maximum 

20 flexibility for the occupants.

21 So especially when talking about 

22 dimmability that's a very big issue especially 
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1 when it comes to build newer buildings or 

2 totally renovated buildings because there is a 

3 requirement for pretty much lighting controls 

4 everywhere in those commercial buildings under 

5 the new codes. Thank you.

6 MR. BROOKMAN: Interesting. Alex?

7 MR. BOESENBERG: Alex Boesenberg, 

8 NEMA. I have one other that I forgot and, 

9 again, I'll expand on this in our public -- in 

10 our written comments. This is our public 

11 comment. 

12 In our written comment, we'll expand 

13 on the issue in IRLs for xenon. That is 

14 another efficiency-boosting fill gas, high 

15 efficiency fill gas that was on that list. 

16 Xenon is, we believe, sort of an 

17 endangered species in terms of gases. Its 

18 availability is decreasing. 

19 Therefore, if the rule pushes 

20 efficiency up to require the use of xenon we're 

21 going to increase the use of it, drive up 

22 price, reduce availability. 
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1 And as a corollary I would point out 

2 that the, as was already mentioned, the current 

3 rule all over the OHA waivers for rare earth 

4 element phosphors, the T700 series lamps, 

5 that's the exact same sort of a thing --

6 availability versus demand. 

7 Rule drives up demand and if the 

8 availability is going down price goes up and 

9 that is a factor for the cost analysis, et 

10 cetera. Thank you.

11 MR. BROOKMAN: Okay. Thank you. 

12 Additional comments? Technology options 

13 eliminated during the screening analysis -- 

14 the lists are there on 33 and 34. Mike?

15 MR. MCGARAGHAN: Mike McGaraghan. 

16 On efficient filament placement, which is what 

17 Alex commented on a minute ago, I wonder if 

18 that is referring to the placement of the 

19 filament in an infrared glass capsule. 

20 I understand that the placement of 

21 that filament does impact the amount of 

22 reflected radiation that hits the filament and 
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1 would then in turn impact the amount of light, 

2 so maybe that's what DOE is going after with 

3 that.

4 MR. HOWLEY: This is Joe from GE. I 

5 think our response to that is that the 

6 filaments are -- do have to be optimized.

7 They do have to be placed at the 

8 exact center of those IR capsules and they are 

9 optimized already, and the whole point of those 

10 products is to optimize them for maximum 

11 efficiency. 

12 But it certainly is a technology 

13 consideration but -- we agree with that but we 

14 would state that yes, it's a consideration that 

15 has already been optimized within our products.

16 MR. BROOKMAN: Keith?

17 MR. K. COOK: Keith Cook from 

18 Philips. Elaborating a little bit on what Joe 

19 was saying, today that is very, very precisely 

20 controlled, that filament placement.

21 If DOE knows of a better way of 

22 doing it, we would love to be made aware of it. 
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1 We don't know how to do it any better, 

2 honestly. It's been thoroughly studied.

3 MR. BROOKMAN: Okay. Thanks. Joe, 

4 do you have anything additional? Nothing. 

5 Okay.

6 MS. HUSAIN: Just to follow up on 

7 that. So would you say that that filament is 

8 placed optimally in every lamp as a matter of 

9 just process?

10 MR. K. COOK: Of course not. There 

11 is manufacturing variation. There's no way to 

12 get around that.

13 MR. HOWLEY: I would say as a design 

14 -- as a design, yes. It's designed to be 

15 placed optimally.

16 MS. HUSAIN: Okay. Okay.

17 MR. BROOKMAN: Okay. That's useful. 

18 Thank you. 

19 MS. HUSAIN: So now I'll be turning 

20 it over to my colleague, Maureen Kienle, who 

21 will discuss the engineering analysis.

22 MS. KIENLE: Good morning. My name 
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1 is Maureen Kienle and I'm with Navigant. We're 

2 going to get started now with the engineering 

3 analysis.

4 DOE used the following general 

5 methodology to develop the engineering for 

6 GSFLs and IRLs. Of the product classes 

7 identified, DOE first selected certain 

8 representative product classes to analyze.

9 DOE then selected baseline lamps for 

10 each representative product class to use as 

11 reference points. 

12 After that, for each baseline lamp, 

13 DOE identified more efficacious substitutes 

14 based on design options identified in the 

15 screening analysis. 

16 DOE then developed candidate 

17 standard levels, or CSLs, that span the range 

18 of efficacy from baseline to the maximum 

19 technologically feasible level.

20 Finally, DOE scaled its results to 

21 the product classes not analyzed. We are first 

22 going to cover the GSFL engineering analysis. 
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1 We will discuss the request for comment 

2 pertaining to GSFLs during this time.

3 The request for comment regarding 

4 IRLs will be discussed during the portion of 

5 the presentation that covers the IRL 

6 engineering analysis.

7 So as stated earlier, DOE is 

8 considering standards for 12 product classes 

9 for GSFLs. From this list, DOE plans to focus 

10 its analytical efforts on the product classes 

11 highlighted in the darker green shade here.

12 DOE directly analyzed all product 

13 classes with CCTs less than or equal to 4,500 K 

14 with the exception of the 2-foot U-shaped 

15 product class.

16 These representative product classes 

17 were primarily chosen on the basis of high 

18 market volume. DOE requests comment on the 

19 representative classes for GSFLs.

20 MR. BROOKMAN: Alex?

21 MR. BOESENBERG: Alex Boesenberg, 

22 NEMA. Just a question. We're confused as to 
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1 why the recently implemented previous rule 

2 doesn't -- hasn't the baseline for all products 

3 since it was just put through all products have 

4 to meet that minimum. Why isn't that the 

5 baseline?

6 MS. KIENLE: So we're actually going 

7 to cover baselines a little bit later. But if 

8 we can defer just for a few minutes before we 

9 get there.

10 MR. BOESENBERG: Okay.

11 MS. KIENLE: If that's okay with 

12 you. Great.

13 MR. BROOKMAN: Okay. Steve 

14 Rosenstock?

15 MR. ROSENSTOCK: Steve Rosenstock. 

16 I'm just kind of curious. Since you're looking 

17 at a separate standard for 2-foot U-shaped then 

18 there is a decent, you know -- it might not be 

19 as high volume as a 4-foot medium bi-pin. Why 

20 wasn't it -- isn't it going to be used as a 

21 part of the analysis?

22 MS. KIENLE: It was on the basis of, 
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1 I guess, the market share like we said so -

2 MR. ROSENSTOCK: I understand that 

3 but since you're doing a separate product, 

4 you're doing a separate efficiency standard, 

5 and there are a significant number of -- you 

6 know, it's not as high as a 4-foot. 

7 I'm still a little bit puzzled just 

8 because I'm thinking that the 2-foot U-tubes 

9 have as much of in terms of sales and in terms 

10 of market data as some of the other products on 

11 this list.

12 MS. HUSAIN: So we didn't --

13 MR. BROOKMAN: Aisha, say your name.

14 MS. HUSAIN: So I think what Maureen 

15 was trying to say was for representative 

16 product classes we choose product classes based 

17 on the market share and for the 2-foot U-shapes 

18 we didn't find a high market share, and based 

19 on manufacturer feedback we also confirmed 

20 that. 

21 But if anyone has any input on that 

22 at this point. So we wouldn't directly analyze 
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1 the 2-foot U-shaped unless the market share 

2 increased greatly or we found that to be true.

3 MR. BROOKMAN: Steve?

4 MR. ROSENSTOCK: Steve Rosenstock. 

5 I understand that but I think in this case 

6 since you are giving a separate efficiency 

7 standard using a 4-foot medium bi-pin as a 

8 proxy for the 2-foot U-tube is a little --

9 analytically I don't know if I agree with that. 

10 Thank you.

11 MR. BROOKMAN: Okay. Thank you. 

12 Charlie Stephens?

13 MR. STEPHENS: Charlie Stephens. Is 

14 there some reason why you are not going to 

15 analyze even one of the greater than 4,500 K 

16 categories? 

17 I mean, the department makes a case 

18 that they're different. It seems to me you 

19 ought to analyze at least one of those to see 

20 what the magnitude of that difference is, if it 

21 shows up in your analysis.

22 MS. KIENLE: Okay. So, again, it's 
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1 on the basis of high market share but we do 

2 consider the greater than 4,500 K in the 

3 scaling analysis and we can cover that a little 

4 bit more later on.

5 MR. BROOKMAN: Joe Howley?

6 MR. HOWLEY: Just a couple of 

7 comments. First is on the T5 lamps. During 

8 the 2009 rulemaking we had a lot of discussion 

9 about how it was critical and necessary to test 

10 these at 25 degrees Celsius. That's where our 

11 labs are capable of testing these.

12 Testing becomes very unreliable at 

13 35 degrees C. That's a significantly higher 

14 temperature and we do not have capability of 

15 having reliable test results at those levels.

16 The data that you have listed here 

17 though is based on 35 degrees C data. Again, 

18 we had this discussion in 2009 where we all had 

19 agreed that we would do test measurements and 

20 use numbers at 25 degrees C measurement but 

21 that -- we're having the same discussion over 

22 again that we had three years ago where this is 
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1 not appropriate to use. A lumen per watt level 

2 is based on 35 degrees C measurements for T5 

3 lamps. So we'll make that comment once again.

4 MR. BROOKMAN: Thank you. 

5 MS. KIENLE: Can I just respond to 

6 that quickly? We're actually -- one of the 

7 reasons why we're using the 35 C data in 

8 particular is because we actually don't have 25 

9 C data in manufacturer -- for all the 

10 manufacturers. 

11 Some manufacturers don't actually 

12 offer that data. So if we could collect the 

13 data we could also consider using that as well. 

14 But, again, the standard is set at 25 C so 

15 it's accounted for there.

16 MR. HOWLEY: There was one other 

17 comment I was wanting to make.

18 MR. BROOKMAN: Joe Howley?

19 MR. HOWLEY: Yes. That was again 

20 not related. This -- there was a comment about 

21 whether replacements of lamps or lamps less 

22 than 10 percent of the mean lumen output --
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1 with the replaced system occur in practice. 

2 Generally, not. 

3 People will not go in and replace 

4 lighting systems lamp for lamp that are more 

5 than 10 percent lower in light output unless 

6 it's felt that the space was overlit to begin 

7 with or the space was repurposed and they're 

8 using it for some other, you know, some other 

9 process than was used there before. Then they 

10 might lower the lumen output. 

11 But in general if the same tasks are 

12 being done, then customers will try to maintain 

13 the same light output or certainly within 10 

14 percent of the light output. That was a 

15 specific question asked here.

16 MR. BROOKMAN: Final comments on 

17 these product classes for GSFLs? 

18 MS. KIENLE: Okay. So next we're 

19 going to move on to the baseline lamp 

20 discussion for GSFLs. A baseline lamp 

21 represents the most common least efficacious 

22 model available on the market. 
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1 To note, when we refer to efficacy 

2 in this analysis we're referring to the rated 

3 efficacy of the lamp. 

4 So for GSFLs rated efficacy is the 

5 catalog initial lumen output divided by the 

6 ANSI-rated wattage and the ANSI-rated wattage 

7 is listed as rated wattage in the table shown 

8 here. 

9 In the case of GSFLs, one baseline 

10 lamp was chosen for each product class. The 

11 baseline lamps, again, are shown in the table 

12 here. DOE requests comment on the baseline 

13 lamps chosen for GSFLs. 

14 MR. BROOKMAN: Steve Rosenstock? 

15 MR. ROSENSTOCK: Steve Rosenstock, 

16 EEI. The values in this table reflect -- these 

17 are the July 2012 minimums, correct?

18 MS. KIENLE: Not exactly, no. So I 

19 can actually address that question now too. 

20 Thanks for letting me defer that to now. 

21 So essentially the 2009 lamps rule 

22 set the standards based on the catalog 
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1 efficacies and then those were then adjusted 

2 for compliance data. So there might not 

3 actually be lamps that show up at that minimum 

4 point. 

5 So these are actually just the 

6 commercially available lamps that we found that 

7 were the -- that we considered the most common 

8 and least efficacious that were actually 

9 available on the market.

10 MR. ROSENSTOCK: Steve Rosenstock, 

11 EEI. Do these meet the July 2012 standard?

12 MS. KIENLE: They do, yes.

13 MR. ROSENSTOCK: Thank you.

14 MR. BROOKMAN: Mike?

15 MR. MCGARAGHAN: Mike McGaraghan. I 

16 would echo NEMA's concern that these values 

17 should be placed at the standard levels 

18 themselves. 

19 I took a look at the certification 

20 database, which I think is a pretty good tool 

21 at this point for assessing actual reported 

22 compliance values, and there are products right 
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1 at the level, particularly for the 4-foot 

2 medium bi-pin class. I didn't look closely at 

3 all the other classes. 

4 So and then the follow-on question 

5 to that is would DOE agree that the 

6 certification database is now a great reference 

7 point for us to be using for this analysis or 

8 is there something about it that makes it 

9 inappropriate for that?

10 MS. deBUTTS: I can answer that. 

11 Lucy deButts, DOE. We actually used the 

12 certification database for our analysis right 

13 now on, basically, all lighting rulemakings. I 

14 know that for a fact. But I think on every 

15 other rules as well.

16 MR. BROOKMAN: Okay.

17 MR. HOWLEY: This is Joe from GE. 

18 And I would agree as well that you should use 

19 the 2009 regulatory levels as your baseline. 

20 If lamps aren't at that today and 

21 perhaps when you did your analysis and I'm not 

22 sure when you started -- it maybe a year ago --
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1 it could be very well be that when you looked 

2 at the database at that point there were no 

3 lamps right at that level. But the market will 

4 drive to lamps at that level due to the cost of 

5 rare earth materials. 

6 And so even though you may not find 

7 them right now I think you could -- it's easy 

8 to make an assumption that lamps will gravitate 

9 towards that bare minimum level over time and 

10 that that should be the analysis you're using 

11 going forward over the next, you know, six to 

12 ten years.

13 MR. BROOKMAN: Okay. Final comments 

14 here? 

15 MS. KIENLE: DOE then identified 

16 more efficacious substitutes for each baseline 

17 lamp. DOE sought to keep characteristics such 

18 as the rated life, CRI and CCTs similar to the 

19 baseline lamp. 

20 So as you can see in this 4-foot 

21 medium bi-pin example table, reduced wattage 

22 lamps were identified as more efficacious 
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1 substitutes as were full wattage lamps with 

2 higher efficacies. 

3 Additionally, the table presents 

4 both instant start and programmed start 

5 lifetimes because both were considered when 

6 selecting more efficacious substitutes for 

7 GSFLs.

8 MR. BROOKMAN: Mike?

9 MR. MCGARAGHAN: Sorry to interrupt. 

10 A question -- Mike McGaraghan, California 

11 IOUs. On the rated wattage can DOE explain the 

12 purpose of using the ANSI-rated wattage or 

13 anyone in the room, really, specifically now 

14 that we have the DOE -- the compliant 

15 certification database where products are 

16 listed with specific wattages, some of which 

17 aren't ANSI-rated wattages?

18 MS. KIENLE: So ideally we use the 

19 ANSI-rated wattage, and maybe the manufacturers 

20 would like to comment on this more too, but 

21 ideally we use the ANSI-rated wattage to more 

22 accurately reflect the lamp operation, and it 
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1 isn’t in the CCMS database. They generally do 

2 include the measured wattage. Sometimes it's 

3 not but maybe the manufacturers have another 

4 response. 

5 MR. MCGARAGHAN: So wouldn't measured 

6 wattage be a more accurate value than an ANSI 

7 standard wattage?

8 MS. KIENLE: Well, we account for 

9 the measured wattage too. That's what we do 

10 with the -- using the compliance data.

11 MR. BROOKMAN: When you say you 

12 account for it what did -- I didn't get that.

13 MS. KIENLE: Yes. So we'll discuss 

14 that a little bit more later on too. But 

15 essentially we're using the ANSI-rated wattage 

16 because it's a complete set of values to go by 

17 and it most accurately would represent lamp 

18 operation. 

19 It's obviously different than the 

20 nominal wattage so we -- it's generally higher, 

21 generally. So we would go with that. 

22 But, again, and when we consider the 
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1 compliance which would be a measured value 

2 ideally, that's when we can adjust for any 

3 differences.

4 MR. BROOKMAN: Alex Boesenberg?

5 MR. BOESENBERG: Alex Boesenberg, 

6 NEMA. The industry has a question in for 

7 clarification of the DOE on the use of the 

8 terms rated versus nominal, et cetera. 

9 But fundamentally the rated wattage 

10 in practice for reporting is based on a very 

11 large number of samples that you then average 

12 out and decide, ah, when we manufacture it we 

13 fall on and around that point. 

14 So hence your rated value, which may 

15 differ -- probably will differ for any 

16 individual lamp chosen and tested. 

17 But when you decide where to put 

18 your stake in the ground as far as yes, we 

19 produce a 32-watt lamp that's how you get there 

20 -- hundreds of data points, not thousands.

21 MR. MCGARAGHAN: So you support the 

22 use of ANSI-rated wattage rather than taking a 
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1 look at actual measured wattage of the products 

2 on the market?

3 MR. BOESENBERG: I'll defer to other 

4 members, but my understanding is yes.

5 MR. BROOKMAN: That was Alex. Now 

6 to Joe.

7 MR. HOWLEY: Well, it's -- and it 

8 is. I agree. It's a somewhat discussed topic 

9 within industry because we do have nominal 

10 wattages, rated wattages, measured wattages and 

11 it is not always clear, even in the reporting 

12 forms, what to use in which case. 

13 In fact, we have a question in to 

14 DOE right now that talks about clarification 

15 and exactly how we should report which wattage 

16 to use and what -- I think what was noted 

17 already is you find a selection of different 

18 wattages being reported depending on how people 

19 are interpreting this. 

20 But I'm not sure that we have a firm 

21 position on this. We recognize there's lots of 

22 different wattages you could be using and 
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1 that's why I can't give you a real strong 

2 response.

3 MR. MCGARAGHAN: Well -- Mike 

4 McGaraghan -- my recommendation would be 

5 looking at this -- from what I can see here 

6 you're basing a standard assuming the lamp has 

7 a rated wattage of 32.5 so that gives you your

8 target efficacy when maybe a lot of these lamps 

9 aren't at 32.5. 

10 It would be worth looking at in the 

11 database to see whether a lot of them are 

12 coming in at different levels and setting your 

13 baseline and your standards around more --

14 around measured data rather than a rated 

15 wattage. It seems logical to us.

16 MR. BROOKMAN: Okay. 

17 MS. KIENLE: Okay. So as I was 

18 saying before, the table here presents both the 

19 instant start and programmed start lifetimes 

20 because both were considered when selecting 

21 more efficacious substitutes for this product 

22 class. 
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1 And this is because multiple system 

2 pairings were analyzed for the 4-foot medium 

3 bi-pin product class and I'm going to explain 

4 that a little bit more in the next few slides.

5 Fluorescent lamps operate on a 

6 ballast in practice. Therefore, DOE analyzed 

7 lamp and ballast systems in the engineering 

8 analysis in order to capture real-world energy 

9 use and light output.

10 DOE used manufacturer input and 

11 information from the 2011 ballast rule to 

12 identify the ballast type most commonly paired 

13 with each lamp. 

14 So as you can see by this table, the 

15 4-foot medium bi-pin lamps were paired with 

16 multiple ballast types. Both instant start and 

17 programmed start ballasts were analyzed as well 

18 as ballasts that operate both two and four 

19 lamps. 

20 All of the other product classes 

21 analyzed were paired with one ballast type. 

22 When developing lamp and ballast systems, DOE 
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1 tried to select ballast models to pair with 

2 lamps that would maintain system mean lumen 

3 output within 10 percent of the baseline when 

4 possible.

5 This is an example table of the 4-

6 foot medium bi-pin two-lamp instant start lamp 

7 and ballast replacement scenario and so I have 

8 a few things to highlight here.

9 At the higher CSLs, DOE selected a 

10 ballast with a lower ballast factor when 

11 possible to further improve the energy savings. 

12

13 Specifically, DOE selected the 

14 lowest ballast factor possible that still 

15 maintained system mean lumen output within 10 

16 percent of the baseline.

17 So as you can see, the full wattage 

18 representative units at CSL 1 and CSL 2 were 

19 paired with low ballast factor ballasts.

20 Both systems still maintain system 

21 mean lumen output within 10 percent of the 

22 baseline. 
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1 In the case of the 25-watt reduced 

2 wattage lamp, DOE would have had to pair the

3 lamp with a high ballast factor ballast in 

4 order to maintain lumen output within 10 

5 percent of the system of the baseline system.

6 So instead, DOE selected a normal 

7 ballast factor ballast and is the same ballast 

8 that's used at the baseline so as to not 

9 increase energy consumption.

10 The system mean lumen output is 

11 approximately 14 percent lower than the 

12 baseline. 

13 MR. BROOKMAN: Steve Rosenstock?

14 MR. ROSENSTOCK: Steve Rosenstock, 

15 EEI. I appreciate this table because it's 

16 really giving a sense of what's going on and I 

17 think the issue here especially is in all of 

18 these cases you're reducing light output.

19 That's a fact. All of these CSLs 

20 you might say it's maintaining but you're 

21 reducing by anywhere from, I'll say, like 8 to 

22 13.8 percent in all of these cases. 
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1 And, again, now I know you went to 

2 the lowest ballast factor but some of the 

3 lowest ballast factors are the same or almost 

4 equal to the baseline ballast factor.

5 So in all these cases -- and the 

6 reason it's important especially for new 

7 buildings is, you know, you're doing -- you 

8 have to meet the code, you're meeting your 

9 watts per square foot but you also have to meet 

10 the lumen output on the surface for the people 

11 is you might be saving watts but you're going 

12 to have to put in more fixtures to meet the 

13 requirements of that space. 

14 So, you know, you might be showing 

15 some savings on this table in terms of system 

16 input power but once you design a space the 

17 savings are going to be -- will almost 

18 disappear probably. 

19 It all depends on the delta lumens 

20 versus the delta watts because you have to put 

21 in more fixtures for that space.

22 And I think -- and again, I think 
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1 the -- you know, it's not -- you know, when you 

2 say maintain if it's always less than it's not 

3 maintaining, in my book. I'm sorry. 

4 MR. BROOKMAN: Keith?

5 MR. K. COOK: I tend to agree with 

6 Steve on this. The problem you've got is 

7 putting in more fixtures is not going to help. 

8 It's typically in the middle of a room. 

9 It's still going to be just those 

10 fixtures above. It is not common practice to 

11 replace lamps with lower output lamps because 

12 most spaces are designed for recommended 

13 practices from IES. So there is a minimum 

14 light output that that space was designed for 

15 originally. So now you come in. 

16 Now you're going to be below those 

17 minimums and that's going to create problems 

18 and a lot of consumer dissatisfaction, which 

19 will be totally unacceptable. And there's 

20 other reasons too we have to be careful on the 

21 selection of these lamps. 

22 As Pekka pointed out earlier, in 
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1 some cases the lower output lamp will not work 

2 satisfactorily in dimming conditions. So if 

3 you've already got dimming installed in that 

4 application you just can't arbitrarily go to a 

5 lower output light. It may not work.

6 MR. BROOKMAN: Okay. Yes, Mike?

7 MR. MCGARAGHAN: Mike McGaraghan, 

8 California Utilities. Just speaking from the 

9 experience of the utilities running a huge 

10 amount of rebated lamps through our programs --

11 retrofit programs -- I completely agree that 

12 maintaining light output is an important part 

13 of a lighting retrofit and the last thing we 

14 would want to do is to promote retrofits that 

15 result in not enough light and can dissatisfy 

16 consumers. 

17 If consumers come to work and don't 

18 like the new project or whether you're talking 

19 residential or commercial or any sector of 

20 people don't like the result that's a bad 

21 outcome. 

22 They're not going to do it again. 
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1 They might actually retrace their steps, undo 

2 it. That said, nine times out of ten you 

3 change out the lights in a commercial space and 

4 everybody complains that it's too bright. 

5 Most spaces were not designed exactly to 

6 IES standards. They were often given a little 

7 extra light initially. Systems degrade. 

8 Lumen maintenance is a huge issue 

9 with fluorescent systems, particularly older 

10 systems, T12 systems. You come in and you 

11 retrofit all the lights to exactly the same 

12 level and it seems blinding to everybody in 

13 there. 

14 That's the comment you get over and 

15 over. Nobody comes in after a lighting 

16 retrofit and says oh, you took away all my 

17 light. So yes, it's important to provide 

18 enough light for people. 

19 It's important to meet the 

20 guidelines in IES. But scenarios where you add 

21 5, 8, 12 percent light are not going to fly 

22 with consumers. 
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1 Scenarios where you subtract 2, 4, 

2 6, 8 percent those -- a lot of those will still 

3 seem too bright to people too. So we would 

4 definitely recommend that you stick in that 

5 less than equal lumens range for your -- you 

6 know, equal to or less than in your scenarios 

7 here.

8 MR. BROOKMAN: Alex?

9 MR. BOESENBERG: Alex Boesenberg, 

10 NEMA. I would add to that or caveat Mr. 

11 McGaraghan's statement with remember that a lot 

12 of these retrofits, especially in California 

13 due to Title 24, include dimming as we already 

14 stated. So if you drive the lamp wattage too 

15 low you're sacrificing the dimmability. 

16 So when NEMA encourages high 

17 efficiency fluorescent retrofits through one of 

18 our marketing programs and we always try to 

19 encourage lighting controls and so yes, you 

20 relamp it and oh, my God, it's brighter -- we 

21 don't want that. 

22 Oh, well, there's this handy button 
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1 right here and it drops it right down. And we 

2 believe that is where the largest amount of 

3 savings lies. 

4 So reducing the capability, as we 

5 already said. I won't belabor it any further. 

6 But preserve the dimmability.

7 MR. BROOKMAN: Steve?

8 MR. ROSENSTOCK: Steve Rosenstock, 

9 EEI. I also work for a utility that had very 

10 big rebate programs, Pepco actually. 

11 In fact, this building took 

12 advantage of Pepco rebates, and the T12 to T8 

13 market shift over the last 20 years has been a 

14 huge success story and going from magnetic to 

15 electronic ballast has been a huge success 

16 story. 

17 But now, you know, we're almost --

18 in many areas we're past that. We're talking 

19 about T8 to T8. We're talking electronic 

20 ballast to electronic ballast. 

21 We're talking limited depreciation. 

22 That's at most, you know, 10 percent over 25 
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1 or 40,000 hours versus a 20 or 30 percent that 

2 we got with the T12. Going from T12 to T8 has 

3 always been a success story. 

4 We're just -- but the scenario now 

5 is T8 to T8 and it could make a difference 

6 especially -- and again, it may be my building 

7 code point of view, especially for new 

8 buildings or total renovations that are meeting 

9 the building codes. 

10 It will have an impact in terms of 

11 some of the possible designs. Thank you.

12 MR. BROOKMAN: John?

13 MR. GREEN: Yes. John Green, Cooper 

14 Lighting. I'd like to point out that personal 

15 perception of the light level is not the 

16 driving reason for IES recommended levels. 

17 It's performance, how to -- how to 

18 accurately and correctly do a task that's given 

19 them in that space. So I'd like to add that 

20 keeping light levels is important for 

21 efficiency in the work place.

22 MR. HOWLEY: And this is Joe and 
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1 last -- one last comment to add on. One of the 

2 reasons you get that reaction that there's a 

3 lot of light right after a retrofit is that 

4 these systems are designed to maintain mean 

5 lumens over approximately a five-year period. 

6 So day one is when you have your 

7 highest light output and, you know, the end of 

8 year five, let's say, where they're going from 

9 is when you have your lowest light output. 

10 That's why we design for mean 

11 lumens. You know, in the beginning you're 

12 above that mean lumen level. At the end you're 

13 below that mean lumen level. 

14 But still you have to factor in that 

15 over the course of five years you want to 

16 maintain approximately the same mean lumen 

17 output so that when you get to the end of that 

18 five-year period you're not -- people aren't 

19 bringing flashlights into work trying to figure 

20 out where all their lumens went.

21 And you have the lumen depreciation 

22 from the lamp but you also have the dirt 
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1 appreciation, fixture depreciation. 

2 There's other depreciation factors 

3 as well that factor in. So you have, you know, 

4 there could be a considerable difference in 

5 light output between the beginning and the end 

6 that is -- that's noticeable. 

7 But I think in this system on some 

8 of these I notice are not within 10 percent. I 

9 mean, you're dropping it more than 10 percent 

10 and I don't believe that is a fair comparison 

11 that you have to get these or you should strive 

12 to have these essentially equal as we go from, 

13 as Steve said, T8 to T8. 

14 It's no longer older T12 systems, 

15 many of which were overlit, to mere T8 systems. 

16 Right now, we've had a lot of retrofitting 

17 happen in the last two decades. A lot of light 

18 levels now have been reset at levels that are 

19 appropriate for computer use. They are 

20 fairly low today and we have to recognize that 

21 in terms of this analysis -- that we should try 

22 to maintain approximately the same light output 
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1 we have today as we look at this in terms of 

2 energy savings. Thank you.

3 MR. BROOKMAN: Okay. Maureen, why 

4 don't you queue up the comment boxes?

5 MS. KIENLE: Sure.

6 MR. BROOKMAN: I think we've begun 

7 to cover these but just let us -- give us -

8 MS. KIENLE: Sure. So the first 

9 request for comment is on the more efficacious 

10 substitutes identified for GSFLs. 

11 DOE also requests comment on its 

12 methodology and the representative lamp and 

13 ballast systems for GSFLs, in particular, the 

14 ballast luminous efficiency of each system and 

15 also the ballast factor of the reduced wattage 

16 systems. 

17 MR. BROOKMAN: Mike?

18 MR. MCGARAGHAN: Mike McGaraghan, 

19 California Utilities. So this is your -- this 

20 comment is about more efficacious substitutes 

21 so how you set each CSL level, essentially?

22 MS. KIENLE: We're not at the CSLs 
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1 yet but essentially these will feed into the 

2 CSLs. So the more efficacious substitutes that 

3 we identified, essentially.

4 MR. MCGARAGHAN: Okay. So I'll ask 

5 my question now. The certification database 

6 seems to have a large number of products that 

7 far exceed anything DOE has acknowledged in 

8 this document. 

9 So the question is is there -- why 

10 did DOE not include those products. 

11 They're in the range of -- there's 

12 probably 20 or 30 products that are above 96 

13 lumens per watt in the database looking at just 

14 one product class. I believe that's less than 

15 4,000 or 4,500 Kelvin in 4-foot lamps.

16 MS. KIENLE: I guess I would ask do 

17 you have specific examples or --

18 MR. MCGARAGHAN: There were about 

19 ten manufacturers. They were MaxLite, Satco, 

20 Philips, Westinghouse -- a lot of products. 

21 Unless I'm reading the database wrong it looks 

22 like there's a huge cluster above 100 lumens 
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1 per watt.

2 MR. BROOKMAN: Joe?

3 MR. HOWLEY: I would suggest that 

4 perhaps either you're reading the database 

5 wrong or you don't understand the data being 

6 inputted or manufacturers are confused about 

7 what to put in different categories so you're 

8 getting false calculations if you see numbers 

9 like that because those are not achievable in a 

10 measured basis. 

11 So I think there's database issues 

12 when you're coming up with numbers like that.

13 MR. MCGARAGHAN: Thank you. I 

14 appreciate that. That was my reaction when I 

15 saw those high values as well. I didn't 

16 realize that there were products achieving that 

17 efficiency. So I'll double check. 

18 Maybe I can talk with one of you 

19 guys in the break to see if I'm misreading the 

20 database but I looked at it pretty closely. 

21 I suspect that there is some sort of 

22 reporting inconsistency or confusion with which 
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1 values get in there somehow. So I would 

2 encourage DOE to take a look at that.

3 MR. BROOKMAN: Aisha?

4 MS. HUSAIN: Yes, this is Aisha. So 

5 as Maureen has said, we did look at the 

6 compliance database and we will look at it 

7 again. 

8 So these new products -- the March 

9 deadline for certification just came along so 

10 we will be looking at the data again for the 

11 NOPR stage so we can look at those things. 

12 But the compliance data is taken in 

13 account not at this stage but this is based 

14 along catalog values because that's where we 

15 found the most data and then we took the 

16 compliance -- we looked at the certification 

17 database and then adjusted those levels that we 

18 came up with.

19 MR. BROOKMAN: Steve?

20 MR. ROSENSTOCK: Steve Rosenstock, 

21 EEI. Again, looking at that slide -- the 

22 previous slide, 43 -- you have CSL 2 with three 
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1 different -- three technologies there. 

2 So I'm just -- you know, even though they 

3 have different efficacies and different light 

4 output is, again, I'm not -- I'm used to 

5 seeing, you know, one, two, three, four and 

6 usually the four is the highest efficacy, let's 

7 say, you know, typically.

8 In this case, they're not really the 

9 same efficacy or light output. Is this because 

10 -- is the DOE thought process that it will just 

11 only use one of these in the final NOPR 

12 analysis as at CSL 2 or -- I guess I'm a little 

13 confused by the -- by the labeling of three 

14 different technologies as the same candidate 

15 standard level.

16 MS. KIENLE: Right. So DOE will 

17 consider all three of these at CSL 2 so we 

18 actually analyzed them separately and the 

19 impacts that any standard level or the life 

20 cycle cost analysis as well is analyzed for 

21 each representative unit.

22 MR. ROSENSTOCK: Okay. And my --
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1 MS. KIENLE: So the CSL -- the CSL 

2 doesn't necessarily correlate to, like, one in 

3 particular. 

4 It would -- generally you would 

5 think that it would go to the lowest and then, 

6 again, the CSLs are adjusted based on 

7 compliance so it might not -- might not 

8 actually fall at that lowest efficacy value. 

9 But these are -- all three representative units 

10 were considered at CSL 2.

11 MR. ROSENSTOCK: Steve Rosenstock, 

12 EEI. I thank you for that but I guess that 

13 leads to the next one and maybe you're not at a 

14 decision point yet but what it also kind of 

15 looks at is to say that it almost would say 

16 that for I'll say CSL 2 with a 25-watt nominal 

17 wattage and CSL 2 with 28 nominal wattage would 

18 almost say that DOE is considering a standard 

19 that would almost eliminate the 32-watt lamp in 

20 the marketplace.

21 MS. KIENLE: No, that's not --

22 MR. ROSENSTOCK: No? Okay.
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1 MS. KIENLE: -- what DOE is 

2 considering. We're going to discuss this in a 

3 little bit too but just to, I guess, to clarify 

4 at this point, DOE is not considering any CSLs 

5 that a full wattage lamp cannot meet.

6 MR. ROSENSTOCK: Thank you very 

7 much. Appreciate that.

8 MS. KIENLE: Sure.

9 MR. BROOKMAN: Additional comments 

10 here on these two comment boxes? Aisha?

11 MS. HUSAIN: This is Aisha. I just 

12 had a quick question on we discussed the 

13 baseline meeting the 10 percent of the light 

14 output. 

15 I was wondering if manufacturers had 

16 any recommendation as to a number we should be 

17 using or it should be. I know Joe had said 

18 approximately equal. Was there any number that 

19 we could use?

20 MR. BROOKMAN: Joe?

21 MR. HOWLEY: I think just from a 

22 evaluation standpoint I think it's fairest if 
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1 you try to match up the systems as closely as 

2 possible with one another from a lumen output.

3 And I understand it's not, you know, 

4 technically possible in all cases because 

5 you're dealing with different ballast factors 

6 and different lamps. 

7 But and I think you asked this 

8 before but if you stay within 10 percent at 

9 least it's -- perhaps you could argue it's a 

10 fair comparison. 

11 I think once you get beyond that 10 

12 percent range you no longer can say that's a --

13 that's a fair comparison lighting system to 

14 lighting system. 

15 And I just noted that some of yours 

16 seem to go beyond the 10 percent where we no 

17 longer consider that to be a fair comparison. 

18 So, again, try to make it as close 

19 as possible or certainly less than 10 percent 

20 would be our advice.

21 MS. HUSAIN: Okay. Thank you.

22 MR. BROOKMAN: Alex?
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1 MR. BOESENBERG: And Alex Boesenberg 

2 from NEMA. I think in an action we will expand 

3 on that in our written comments.

4 MR. BROOKMAN: Thank you. Steve?

5 MR. ROSENSTOCK: Steve Rosenstock, 

6 EEI. I know I'm not a manufacturer but just 

7 seeing what can happen in the marketplace I 

8 would say equal to or higher to maximize 

9 customer utility. Thank you.

10 MR. BROOKMAN: Thank you. Other 

11 comments on these two issues? Take a peek. 

12 Let's cover it here effectively. Okay. 

13 MS. KIENLE: So moving on to the 

14 CSLs, DOE used commercially available lamps 

15 when possible and their associated rated 

16 efficacy to determine the initial CSLs. 

17 Then to establish final minimum 

18 efficacy requirements for CSLs, DOE coupled 

19 publicly available compliance data with rated 

20 efficacy to determine if any adjustments were 

21 necessary to the initial CSLs. 

22 When determining CSLs, DOE only 
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1 considered CSLs at which a full wattage version 

2 of the lamp type was available because reduced 

3 wattage lamps cannot be used in all 

4 applications such as cold temperature 

5 applications and also because striations still 

6 remain an issue for reduced wattage lamps.

7 So to do that full wattage 

8 requirement, DOE modeled a lamp for the 4-foot 

9 T5 mini bi-pin high output product class 

10 because no full wattage higher efficacy 

11 replacement was commercially available. 

12 In order to model the lamp, DOE used 

13 a commercially available reduced wattage T5 

14 high output lamp that was more efficacious than 

15 the baseline lamp to scale to a full wattage T5 

16 high output lamp of comparable efficacy.

17 This table here displays the 

18 baseline lamp characteristics and the 

19 performance characteristics of the model lamp 

20 at CSL 1. 

21 So as you can see, the model lamp 

22 has both the higher lumen output and lifetime 
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1 compared to the baseline lamp.

2 The rated efficacy at 35 degrees C 

3 is improved from 92.9 lumens per watt at the 

4 baseline to 97.3 lumens per watt at CSL 1.

5 DOE requests comment on the 

6 methodology and performance characteristics of 

7 this model lamp. Specifically, DOE requests 

8 information on the manufacturability and 

9 functionality of this lamp as well as its 

10 expected efficacy when manufactured on a 

11 commercial scale.

12 MR. BROOKMAN: Steve?

13 MR. ROSENSTOCK: Steve Rosenstock, 

14 EEI. The CSL 1 -- is this also the max tech? 

15 Would this also be considered the max tech? 

16 Because as I recall that in your 

17 analysis you're supposed to show some sort of 

18 max tech option. So I'm just -- is this max 

19 tech as well?

20 MS. KIENLE: Yes. At this point 

21 this would be considered the max tech level.

22 MR. BROOKMAN: Keith?
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1 MR. K. COOK: This whole thing kind 

2 of scares me a little bit because it almost 

3 comes across now that DOE is designing and 

4 inventing new lamps and the problem is is this 

5 may not even be feasible. 

6 We don't know, and so as a result we 

7 may end up establishing a class where there is 

8 no products available as a result of this 

9 approach.

10 MR. BROOKMAN: Steve?

11 MR. ROSENSTOCK: Steve Rosenstock, 

12 EEI. I also -- again, just because of all the 

13 other rulemakings I don't know if I've ever 

14 seen another rulemaking where it's just been 

15 baseline and max tech. 

16 Usually there's something in between 

17 and if there's nothing in between I think 

18 that's a significant issue. Thank you.

19 MR. BROOKMAN: Okay. Thank you. 

20 Alex?

21 MR. BOESENBERG: Alex Boesenberg, 

22 NEMA. Regarding that creation of this lamp, as 
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1 it were, in the past in situations such as this 

2 the government, DOE, has commissioned the 

3 design and test of a product where one doesn't 

4 exist.

5 Will the department make one of 

6 these lamps or actually several of these lamps 

7 and test them, confirm the performance?

8 MS. KIENLE: So at this point we're 

9 looking for feedback from the manufacturers on 

10 the feasibility of this lamp.

11 MR. BOESENBERG: Do you want us to 

12 make one?

13 MS. KIENLE: If you'd like. No, any 

14 information that you can submit would be really 

15 helpful on this in particular. Any reasons why 

16 you think this isn't feasible -- for example, 

17 if you've tried it, if it hasn't worked.

18 MR. BROOKMAN: Pekka? No?

19 MR. HAKKARAINEN: Not yet. Next 

20 slide.

21 MR. BROOKMAN: Okay. Joe?

22 MR. HOWLEY: I think our engineers 
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1 do have concerns and have to get more 

2 information but they have significant concerns 

3 about how this T5 area was analyzed and this 

4 CSL 1 max tech level being proposed which also 

5 I think they have significant concerns about 

6 it. 

7 I notice in this case it claims to 

8 reflect operation at 25 degrees C versus the 

9 other operation at 35 degrees C but I think 

10 this is where they thought this more was 

11 indicative of 35 degrees C as well. 

12 The levels seem very high to them. 

13 We need to get more feedback on this. But 

14 where you're heading with these T5s, because 

15 the T5 levels are significantly lower than this 

16 right now in the standard and it seems like 

17 you're going from a standard -- you know, T5 

18 levels that are relatively easy to meet to 

19 levels that may not even be technically 

20 possible, and as Steve said he hasn't seen this 

21 before.

22 We haven't seen this before either. 
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1 This is really concerning that DOE is taking 

2 this approach with these T5 lamps.

3 MS. KIENLE: So just to clarify, 

4 this is lamp operation at 35 degrees C.

5 MR. HOWLEY: It is lamp operation?

6 MS. KIENLE: Yes.

7 MR. K. COOK: You know, which we 

8 don't test at so we don't know. So you're 

9 asking us if it's been looked at. We test at 

10 25 degrees C. I can't answer your questions.

11 MS. KIENLE: Information on testing 

12 at 25 degrees C or any kind of information on 

13 that would be useful as well.

14 MR. K. COOK: Okay.

15 MR. BROOKMAN: Alex?

16 MR. BOESENBERG: This is Alex 

17 Boesenberg, NEMA. Doesn't the test procedure 

18 state testing at 25 degrees C?

19 MS. KIENLE: It does but there is 

20 performance characteristics in manufacturer 

21 catalogs at 35 degrees C. That's most 

22 commonly, I would say, reported.
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1 MR. K. COOK: Those are particular 

2 amalgam lamps that were designed specifically 

3 for that environment. It's not generally 

4 applied, though.

5 MR. BOESENBERG: Yes. We begged the 

6 government to stick to the test procedure. 

7 That's what it's for.

8 MR. HOWLEY: So one other just 

9 comment and, again, the concern and confusion 

10 on Page 47 or Slide 47 you do have a footnote 

11 that says it reflects it at 25 degrees C, 

12 unless I'm misinterpreting that. 

13 But so we see that footnote at 25 

14 degrees C but yet the numbers do seem to 

15 reflect 35 degrees C. So that's -- we're 

16 having some confusion here. Slide 47.

17 MS. KIENLE: Yes. So Slide 47 that 

18 is the T5 high output. That would be the 

19 proposed standard level at 25 degrees C. So if 

20 you compare it to the efficacy on the previous 

21 slide that's lower.

22 MR. HOWLEY: But it's still a very 
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1 high -

2 MS. KIENLE: Okay. I see what 

3 you're saying.

4 MR. HOWLEY: -- and very concerning 

5 at those levels.

6 MR. BROOKMAN: Pekka?

7 MR. HAKKARAINEN: Since we are now 

8 on Slide 47 -- Pekka Hakkarainen from Lutron 

9 commenting -- when I'm -- this slide says that 

10 the following CSLs are now under consideration. 

11

12 I'm looking at the final rule from 

13 2009, Table IV.1 which lists max tech levels 

14 for GSFLs, and with the exception of the first 

15 item shown on Slide 47 where the CSL 2 is at 

16 the 2012 max tech level all the other CSLs are 

17 higher than the max tech levels in 2012. 

18 I'm now really curious to understand 

19 how you arrived at these numbers.

20 MS. KIENLE: I guess I'd have to --

21 can you clarify, like, what specifically are 

22 you interested at?
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1 MR. HAKKARAINEN: Well, if I just go 

2 down the list we are currently saying that on 

3 this rulemaking the 8-foot slimline lamp would 

4 have one candidate standard level at 99 lumens 

5 per watt and in 2012 the max tech was 98 lumens 

6 per watt. The next one down we are currently 

7 considering 97. In 2012, the max tech was 95. 

8

9 With the T5 standard output we are 

10 now at 98.2. Max tech was 90. The high output 

11 T5 at 86.2 when max tech was 76.

12 Especially for the T5 lamps, this is 

13 a huge jump and I don't know anything -- maybe 

14 somebody has invented something miraculous but 

15 I know nothing that would justify going beyond 

16 max tech in 2012.

17 MR. BROOKMAN: Keith?

18 MR. K. COOK: Yes, I don't know of 

19 any new products that have come out in the last 

20 year or so that comes anywhere close to these 

21 new levels you're showing.

22 MR. HOWLEY: Same. Just to 
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1 reiterate, there's been no major technology 

2 changes in this area in the last two or three 

3 or four years since the 2009 rulemaking. 

4 So, again, there would be no reason 

5 for max tech to jump with no technology changes 

6 during this last couple year period.

7 MR. BROOKMAN: Let's go to the 

8 comment boxes. 

9 MS. KIENLE: DOE requests comment on 

10 the CSLs under consideration for GSFLs, in 

11 particular the appropriateness of developing a 

12 CSL 1 for the T5 high output product class 

13 based on the model lamp. 

14 DOE also requests comment on whether 

15 additional adjustments to the CSLs are needed 

16 to account for compliance requirements.

17 MR. BROOKMAN: Alex?

18 MR. BOESENBERG: Alex Boesenberg, 

19 NEMA. Regarding item -- issue 13, and I guess

20 I'll just say number two, ability to comply but 

21 also relates to number one, you mentioned 

22 phosphor there. 
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1 What factor has DOE or Navigant in 

2 their analysis given the current shortage of 

3 rare earth elements and the existing practice 

4 of waivers? How does that factor in to 

5 compliance capability, if you will?

6 MS. KIENLE: So DOE is considering 

7 the waiver and also the rare earth. It's 

8 analyzed as an LCC sensitivity and then also in 

9 the NIA as an alternative scenario, which we'll 

10 cover a little bit more later on.

11 MR. BOESENBERG: Thank you.

12 MR. BROOKMAN: Other comments? What 

13 about compliance requirements? I think we need 

14 a break. 

15 It's -- we may not be 100 percent 

16 finished with these two comments but let's 

17 break here and we can return to them and give 

18 you a chance to dwell on them while we go and 

19 walk around a little bit.

20 It's now 10:55. Let's resume here 

21 in this room at 11:10, 15 minutes.

22 (Whereupon, the above-entitled 
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1 meeting went off the record at 10:57 a.m. and 

2 resumed at 11:10 a.m.)

3 MR. BROOKMAN: Once again, welcome 

4 to those joining us via the webinar. We're 

5 going to pick up where we left off. I'm not 

6 convinced that we got all the comments that 

7 were waiting for -- either 13 or 14, so I want 

8 to take us back to that and maybe the break 

9 jarred some content loose. Pekka and Keith, 

10 whichever of you is first.

11 MR. HAKKARAINEN: Pekka Hakkarainen, 

12 Lutron. I guess my conclusion, when I'm 

13 looking at slide 47 and addressing the, 

14 perhaps, issue, the thing is that the numbers 

15 shown in the table, to me, contradict the 

16 statement made on slide 45, which says that DOE 

17 is considering CSLs at which full-wattage 

18 versions of the lamps are available to meet the 

19 standards. These standards are set so high 

20 that I am very concerned that full-wattage 

21 lamps will be eliminated. And with that, 

22 significant energy savings are going to be 
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1 eliminated and not be the theoretical a couple 

2 of percent energy savings that we are looking 

3 at with lamp efficacy, which may or may not 

4 result in any actual energy savings in 

5 buildings. 

6 MR. BROOKMAN: Okay. Thank you. 

7 Keith? 

8 MR. K. COOK: Regarding issue 14, 

9 the compliance requirements, just want to 

10 reiterate the fact that we do need to make sure 

11 that the standards do reflect manufacturing 

12 tolerance, testing tolerances, and all those 

13 other things that have been reviewed before 

14 with the DOE. And I'd like to reference LSD 63 

15 from NEMA, which very clearly specifies what 

16 the requirements should be based upon all those 

17 tolerances I mentioned.

18 MR. BROOKMAN: Okay. Thank you. 

19 MS. KIENLE: And just to clarify, 

20 I'm not sure if I mentioned this before, we 

21 might have breezed over this slide a little 

22 quickly, but the final CSLs that are presented 
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1 here are accounting for compliance 

2 requirements. 

3 MR. BROOKMAN: Did you have 

4 additional comments? No? Nothing additional. 

5 Mike first.

6 MR. MCGARAGHAN: Mike McGaraghan, 

7 California Utilities. I just want to echo 

8 Pekka's comment that we see dimming as an 

9 extremely valuable asset in this market and DOE 

10 should take care not to eliminate products that 

11 dim. That's maybe something that we could have 

12 talked about in the scope section or the 

13 product class section, but if there are, you 

14 know, two sets of products, one set that can 

15 dim and one set that's much more efficient, 

16 then maybe that's grounds for covering them in 

17 separate product classes so that we can ensure 

18 you either comply by being very efficient or by 

19 having your dimmable product. 

20 MR. BROOKMAN: Steve Rosenstock?

21 MR. ROSENSTOCK: Steve Rosenstock. 

22 And, again, that table on 47 makes it, again, 
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1 for four out of the five products, CSL 1 

2 represent what DOE considers max tech, correct, 

3 in these product categories? Maximum 

4 technology. That's --

5 MS. KIENLE: Right. DOE is 

6 currently considering 1 CSL for all the product 

7 classes --

8 MR. ROSENSTOCK: And that is 

9 equivalent to the max, that would be equivalent 

10 to a max tech for all these, for these four 

11 products? 

12 MS. KIENLE: Right. So a max tech 

13 lamp, specifically, might perform higher than 

14 the CSL. But, again, since we're accounting 

15 for that full wattage requirement, the CSL is 

16 set here to account for the full wattage. And 

17 then, additionally, any max tech products would 

18 also fall at the same level. Is that more 

19 confusing?

20 MR. ROSENSTOCK: I think, I think I 

21 hear what you're saying. But, again, the fact 

22 that there's no higher CSLs, basically, in 
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1 DOE's mind, this is the max that's out there 

2 for those products, based on the criteria about 

3 the full-wattage lamp?

4 MS. KIENLE: Right.

5 MR. ROSENSTOCK: Thank you. 

6 MR. BROOKMAN: Alex? 

7 MR. BOESENBERG: Alex Boesenberg, 

8 NEMA. So returning to Dr. Hakkarainen's 

9 earlier comment, some of those numbers in CSL 1 

10 are higher than the max tech previously noted, 

11 so how did max tech get maxier if the tech 

12 hasn't changed? 

13 MS. KIENLE: So these CSLs are based 

14 on catalog initial lumen output divided by the 

15 ANSI-rated wattage. So these are catalog 

16 values, so I just want to express that these 

17 are levels are based on commercially available 

18 products.

19 MR. BOESENBERG: So was the previous 

20 iterations max tech based on a different 

21 equation then?

22 MS. KIENLE: No, I don't think so.
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1 MR. BOESENBERG: Well, the number --

2 MR. deLASKI: Some years have 

3 elapsed, Alex. 

4 MR. BOESENBERG: True, but there 

5 have been no major technical innovations. I 

6 just don't understand how the numbers changed. 

7 MR. BROOKMAN: Lucy deButts? 

8 MS. deBUTTS: Well, I can't really 

9 speak to the catalog data that was available 

10 prior to 2009. If you have further data that 

11 could help us, we'd appreciate your input.

12 MR. BROOKMAN: Joe? 

13 MR. HOWLEY: Our concern is that 

14 these are simply based on finding more 

15 aggressive marketing claims in catalogs, not 

16 finding any real change in technology. There's 

17 always some manufacturers that are willing to 

18 claim more, faster, higher, when, you know, it 

19 tends to be, perhaps, more of a marketing claim 

20 than a technology reality. And that may be 

21 what's going on here, and, if that's the case, 

22 we have concerns about going to the most 
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1 aggressive marketing claim, product claim, out 

2 there by any manufacturer because some of them 

3 do stretch in terms of claims. 

4 MR. BROOKMAN: Andrew? 

5 MR. deLASKI: Just to follow-up. 

6 It's Andrew deLaski from ASAP. That would 

7 suggest that there's some enforcement action 

8 the Department should be taking if there are 

9 products out there that are being certified in 

10 the database that aren't, you know, that aren't 

11 compliant so --

12 MR. BROOKMAN: Charlie? 

13 MR. STEPHENS: Yes. Charlie 

14 Stephens. I'd like to go back to Mike's 

15 earlier comment. I don't think he was 

16 misreading the database. I mean, the column, 

17 it says efficacy. You know, you put the number 

18 in there. I mean, I think everybody who puts 

19 that number in there knows what that means, so, 

20 you know, somebody ought to, you know -- yes, 

21 so do we. And I think, you know, I think until 

22 we all know that we're dealing with consistent 
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1 data here, it's darn hard to make any decisions 

2 about whether this looks right or not. I mean, 

3 I don't know about everybody else, but with all 

4 the different numbers being bandied about here, 

5 I'm just nothing but confused at this point. 

6 So maybe if we can clear this up, I could make 

7 some rational judgment as to whether this makes 

8 sense or not.

9 MR. BROOKMAN: Lucy. 

10 MS. deBUTTS: Lucy deButts, DOE. So 

11 if we, as I understand this correctly, we're 

12 saying that there's some manufacturers that 

13 certify products that are not compliant and DOE 

14 should go after them because the data that 

15 we're presenting actually uses the 

16 certification data, as well. We can look into 

17 it.

18 MR. STAS: Eric Stas. Maybe I'll 

19 ask this question. Is it that they're not 

20 meeting the minimum standards or they're 

21 overstating the maximum, so they would still 

22 comply with the minimum standards? Is that 
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1 what's happening? 

2 MR. BROOKMAN: Joe? 

3 MR. HOWLEY: It's hard to say. I 

4 think there's also a lot of confusion among 

5 manufacturers about what exactly to report and 

6 what column, but that could be part of it, as 

7 well. It could be that the lamps are in 

8 compliance, but some of the claims being made 

9 are aggressive.

10 MR. BROOKMAN: You think there's 

11 confusion about which data to put in which 

12 columns? 

13 MR. HOWLEY: Yes. We have a series 

14 of questions into DOE right now about how to 

15 report, and there's a lot of confusion among 

16 manufacturers in industry about this.

17 MR. BROOKMAN: Interesting. Go 

18 ahead, Keith. 

19 MR. K. COOK: Now I'm confused. I 

20 thought that this data was catalog data, but 

21 Lucy led me to believe that this is compliance 

22 reported data.
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1 MS. deBUTTS: What I said is that we 

2 looked at the catalog data. We also looked at 

3 the compliance data and adjusted for that, but 

4 there was not enough compliance data at the 

5 time when we were doing the analysis. Aisha, 

6 correct me if I'm wrong. So we will analyze it 

7 further. I'm not saying this is it. NOPR 

8 stage will create, you know, another round of 

9 analyses, but it's based on catalog first and 

10 then adjusted for the compliance data that we 

11 had at the time.

12 MR. BROOKMAN: Eric Stas? 

13 MR. STAS: Okay. Eric Stas, DOE. 

14 So a follow-up question for everybody. So in 

15 the 2009 lamps rule, was the level setting in 

16 the analysis done the same way? So did 

17 manufacturers make wilder claims in the 

18 intervening years, or was there more compliance 

19 data then to check against that that you didn't 

20 have any objections at the 2009 time frame? 

21 MR. BROOKMAN: Keith? 

22 MR. K. COOK: More compliance data 
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1 now, considerably more. There's a much larger 

2 database. 

3 MR. BROOKMAN: Okay. Thank you, 

4 Keith. Andrew deLaski? 

5 MR. deLASKI: A question. So, Alex, 

6 you suggested, you told us a couple of times 

7 that you have a request into the Department for 

8 clarification on these points, and I wonder if 

9 you could share that request. DOE probably 

10 will publish it, but, if you could share it, 

11 that would help us to understand the sort of 

12 questions you guys are grappling with.

13 MR. BOESENBERG: I'll talk to my 

14 counsel. I don't see a reason why we can't, 

15 but I have to --

16 MR. deLASKI: It will be public 

17 eventually.

18 MR. BOESENBERG: It will be public 

19 eventually, right. 

20 MR. BROOKMAN: Lucy?

21 MR. BOESENBERG: I'll connect with 

22 you offline. 
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1 MR. deLASKI: Okay. 

2 MS. deBUTTS: Lucy DeButts, DOE. So 

3 DOE is addressing comments that we received 

4 from NEMA, and we are working on a set of 

5 guidance. I cannot say when it's going to come 

6 out, but we're actively working on responding 

7 to those questions. So as soon as they're 

8 available, we're going to publish them on the 

9 guidance database, which is accessible through 

10 the DOE website. 

11 MR. deLASKI: It sounds like these 

12 issues are very much interconnected. The kind 

13 of guidance that you guys are seeking is 

14 interconnected with the concerns being raised 

15 right here. Okay.

16 MR. BROOKMAN: Okay.

17 MR. deLASKI: So if you could share 

18 that with us, it would help us to put in 

19 thoughtful comments, frankly. 

20 MR. HOWLEY: I think this overall 

21 issue is a function of the fact that, you know, 

22 in the last rulemaking, we were going from a 
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1 relatively modest efficiency regulation of 75 

2 lumens per watt to something higher. In fact, 

3 for a long time we discussed 83 lumens per watt 

4 as being the next level, and we were actually 

5 somewhat surprised when it came out at the 89 

6 lumen per watt level when we were talking four7 foot lamps at that time. But there was, 

8 obviously, a policy change where they decided 

9 to go to a very high level, as opposed to 

10 moderate level. So most of the discussion was 

11 around going mid 83 and, of course, we knew we 

12 had products that easily met 83. So there 

13 wasn't a lot of discussion in this area about 

14 who's reporting what or what levels are on or 

15 what's in people's catalogs. But now that we 

16 are talking about numbers at the very tippy-top 

17 of the highest claim anybody would make, then 

18 all of this stuff becomes relevant where it 

19 wasn't relevant before, is all these real, can 

20 these lamps actually meet these levels, are 

21 these lumen per watt numbers actually 

22 achievable?
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1 When we're talking about the 

2 absolute ceiling, these all come into play. 

3 And so I think the DOE needs to make sure they 

4 have actual test data from labs that show 

5 exactly what these products are capable of and 

6 not based on marketing claims when we're 

7 talking about the absolute maximum technology, 

8 or you can inadvertently end up in a situation 

9 like we have with the 130-volt power lamps. We 

10 set a level so high that, although it appeared 

11 on paper that some people might make these, in 

12 reality, they're technically not achievable, 

13 and we don't want to inadvertently wipe out 

14 entire product classes here.

15 MR. K. COOK: In that same vein that 

16 Keith got from Philips, the proposed candidate 

17 standard levels is to appoint two of a decimal 

18 place. That is providing an artificial measure 

19 of accuracy that doesn't even exist. I think 

20 we can’t measure it that accurately. 

21 MR. deLASKI: Maybe this can't be 

22 entered today, but are we seeing a discrepancy 
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1 between, is the Department seeing a discrepancy 

2 between the catalog datas for given models and 

3 what's in the database being certified to you? 

4 MS. KIENLE: So there's generally 

5 some variation, yes. I would say there's 

6 definitely variation between what's reported, 

7 which would be a tested value, and then what's 

8 presented in the catalogs. 

9 MR. BROOKMAN: Significant 

10 variation? 

11 MS. KIENLE: There's some variation.

12 MR. K. COOK: You need to recognize 

13 the process that we have to go through in 

14 developing new products. And, you know, when 

15 we set up our catalog values, we start that 

16 very early in the process with only a handful 

17 of samples completed at that time. Now, the 

18 database is thousands of samples, essentially, 

19 later, and so it's much more representative of 

20 the manufacturing. But in the meantime, the 

21 catalog is already out there, and it's already 

22 based upon much smaller sample size. So 
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1 there's going to be a difference between those 

2 two. 

3 MR. deLASKI: Do you eventually sync 

4 them up eventually? 

5 MR. K. COOK: Yes, eventually, there 

6 will be a true up, but, usually, we only 

7 refresh our catalog every two or three years. 

8 MR. deLASKI: Are you required to? 

9 I mean, are you allowed to market a level 

10 different than what you certified with DOE? 

11 MR. K. COOK: Yes, there is some, 

12 there is allowable difference there.

13 MR. deLASKI: Okay.

14 MR. K. COOK: And, typically, 

15 typically, well, there is some allowable 

16 difference. It's recognized that this is a 

17 problem. 

18 MR. deLASKI: I remember it came up 

19 in the last rulemaking, too. We had this 

20 discrepancy between the catalog because DOE was 

21 working on catalog values, and you all said, 

22 well, hang on here, this has created some 
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1 problems. I remember we never quite got to the 

2 bottom of it, in my recollection.

3 MR. BROOKMAN: Lucy? 

4 MS. deBUTTS: Lucy DeButts, DOE. I 

5 think this is question, this question can be 

6 addressed by recent FTC rulemaking where they 

7 have labeling requirements for lamps. I would 

8 refer to that for the answer.

9 MR. BROOKMAN: Charlie? 

10 MR. STEPHENS: Yes, Charlie 

11 Stephens. I would just remind everybody that 

12 the market out there, the designers are using 

13 catalog values, so it would be a little 

14 discouraging to find out that they weren't 

15 real. 

16 MR. BROOKMAN: Mike? 

17 MR. MCGARAGHAN: Mike McGaraghan, 

18 California Utilities. Keith, your comment 

19 about significant digits and accuracy of the 

20 measurement, I wanted to ask about -- my 

21 understanding is that the test procedure is 

22 very specific on -- I'm talking about 
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1 certification now -- the test procedure is very 

2 specific on the sample size and the way you 

3 gather products for the sample. You measure 

4 all the products, you take the mean, and then 

5 you also calculate, you do a statistical test 

6 on the upper 99 percent confidence limit or 

7 something along those lines. So you have two 

8 values, and you just take the smaller. That 

9 might have any number of decimal points after 

10 it, so I guess I'm confused why one significant 

11 digit is considered too inappropriate or --

12 MR. BOESENBERG: This is Alex 

13 Boesenberg, NEMA. Mike, have you read NEMA LSD 

14 63? I'll send you a copy happily. We argue 

15 these decimal point percentages are getting 

16 past the realm of repeated and reliable 

17 measurement.

18 MR. MCGARAGHAN: So I'm not 

19 referring to the NEMA test procedure. I'm 

20 referring to the DOE test procedure. 

21 MR. BOESENBERG: We have submitted 

22 various comments to that effect, to the DOE 
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1 test procedure and to other rulemakings.

2 MR. MCGARAGHAN: As long as that 

3 test procedure exists, that's what we're using, 

4 and it has, it has a procedure to come to a 

5 very specific number.

6 MR. BROOKMAN: Steve Rosenstock?

7 MR. ROSENSTOCK: Steve Rosenstock, 

8 EEI. I know that, like with, I'm familiar with 

9 other, like, heating and cooling equipment, 

10 like AHRI. I believe the tolerance that 

11 they're allowed in their test, in terms of, 

12 let's say it's an AFUE or anywhere between five 

13 and ten percent, depending on the product, just 

14 because of the testing equipment accuracy. So 

15 there is going to be -- so the higher the 

16 number and if you try to make it a smaller 

17 range, it just might not be possible just to 

18 get the test equipment. So you have to have a 

19 certain tolerance in terms of, because you're 

20 testing a product with a piece of testing 

21 equipment, there is going to be some sort of 

22 error. That's always going to happen and, you 
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1 know, the higher the numbers, the more that 

2 becomes an issue. 

3 MR. BROOKMAN: Maureen, as you look 

4 at 15 or 14, is there anything specifically you 

5 wish to queue for them to respond to or have we 

6 covered it? 

7 MS. KIENLE: I think we've covered 

8 it at this point.

9 MR. BROOKMAN: Okay. Let's keep 

10 going. 

11 MS. KIENLE: Okay. So once CSLs are 

12 established for the representative product 

13 classes, DOE develops scaling factors to apply 

14 those CSLs to the remaining product classes. 

15 This process involved comparison of lamps that 

16 differ only by the parameter under 

17 consideration for scaling. So in this case, it 

18 would be shape or CCT. 

19 To develop a scaling factor to 

20 account for shape, DOE compared commercially

21 available two-foot U-shaped lamps with CCTs 

22 less than or equal to 4,500 K and the 
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1 equivalent four-foot medium bi-pin version. By 

2 comparing catalog ratings, DOE found that an 

3 average efficacy reduction of two percent from 

4 the four-foot medium bi-pin CSLs was 

5 appropriate for the two-foot U-shaped lamps.

6 Similarly, to develop a scaling 

7 factor to account for CCT, DOE identified pairs 

8 of lamps in which the only difference was CCT. 

9 DOE compared lamps with a CCT of 4,100 K to 

10 lamps of a CCT of 5,000 K and also 6,500 K. 

11 DOE determined that a two-percent reduction of 

12 the CSL as established for the less than or 

13 equal to 4,500 K representative product class 

14 was appropriate. In both cases, DOE also 

15 confirmed that the scaling factor did not 

16 result in backsliding from the current 

17 standards.

18 DOE requests comment on the 

19 methodology and the results of its scaling 

20 analysis for GSFLs.

21 MR. BROOKMAN: Joe? 

22 MR. HOWLEY: Well, I believe your 
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1 two-percent decrease for the high chromaticity 

2 lamps is probably accurate. I don't believe 

3 your two-percent decrease for U lamps is 

4 accurate. The percentage decrease on those 

5 lamps, typically, more is in the four- to six6 percent range when you are going from a four 

7 foot to a U lamp. 

8 Again, if you're going off catalog 

9 data, there's other confounding factors 

10 happening here, but I believe if you looked at, 

11 perhaps, manufacturer to manufacturer, even 

12 with that there's issues with some of the 

13 catalog data that I've seen in the industry. 

14 But from a technology standpoint, again, I'll 

15 double check with our engineers, but I believe 

16 it's more in the four- to six-percent range, as 

17 opposed to, perhaps, what you've found in 

18 catalogs.

19 MR. BROOKMAN: Okay. Other comments 

20 here? Scaling and -- did you queue the 

21 engineering analysis?

22 MS. KIENLE: Yes. So at this time, 
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1 also, we'd like to request any comments on the 

2 overall methodology and results of the GSFL 

3 engineering analysis. 

4 MR. BROOKMAN: No additional 

5 comments? Okay.

6 MS. KIENLE: Okay. I'm going to 

7 hand this off to my colleague, Julie Pierce.

8 MS. PIERCE: Hi. My name is Julie 

9 Pierce, and I am with Navigant. I will discuss 

10 the IRL engineering analysis. In general, DOE 

11 chooses representative product classes on which 

12 to focus its analytical effort. Of the eight 

13 IRL product classes, which are shown in this 

14 table, the standard spectrum, greater than 2.5 

15 inches, less than 125-volt product class shown 

16 in darker green was chosen as representative 

17 based on its high market volume.

18 DOE requests comment on its choice 

19 of the representative product class for IRLs.

20 MR. BROOKMAN: No comments here? 

21 MS. PIERCE: All right. The 

22 baseline lamp is the most common, least 
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1 efficacious model on the market for each 

2 representative product class. For IRLs, DOE 

3 found two common low-efficacy lamps for the 

4 representative product class and is considering 

5 both as baseline models. They are both 60-watt 

6 PAR38s. 

7 The first is an improved halogen 

8 lamp, which means it is a halogen lamp with an 

9 improved reflector. It has a light output of 

10 1070 lumens, an efficacy of 17.8 lumens per 

11 watt, and a lifetime of 1,500 hours.

12 The second is an HIR lamp. It has a 

13 light output of 1100 lumens, an efficacy of 

14 18.3 lumens per watt, and a lifetime of 3,000 

15 hours. 

16 DOE requests comment on its

17 selection of two baseline lamps with similar 

18 efficacies but distinct technologies and 

19 lifetimes. 

20 MR. BROOKMAN: Steve Rosenstock?

21 MR. ROSENSTOCK: Steve Rosenstock, 

22 EEI. You said most common. Is that just in 
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1 terms of models or sales, just out of 

2 curiosity, in your analysis? 

3 MS. PIERCE: It was based on catalog 

4 data.

5 MR. ROSENSTOCK: On catalog data. 

6 So -- Steve Rosenstock, EEI. I thank you for 

7 that. So did you do any analysis, are there 

8 any other lamps, I'll say 60-watt lamps, that 

9 represent, I'll say 50 percent of sales in the 

10 marketplace that might have different 

11 characteristics? I know you're looking at 

12 catalog, but what's happening in the 

13 marketplace if there's 2012 or 2013 data in 

14 terms of what's actually being sold that might 

15 be different from this baseline? I'm just kind 

16 of curious about what's happening in the 

17 marketplace in terms of a baseline. 

18 MS. PIERCE: Does anyone have 

19 comment on that? 

20 MR. ROSENSTOCK: You don't have --

21 okay. 

22 MR. BROOKMAN: Andrew? 
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1 MR. deLASKI: This is one of our 

2 areas of highest concern in the P-TSD. It's 

3 really unusual to see two baseline products, 

4 and, you know, we're still kind of wrestling 

5 with it, but my intuition is that it's the 

6 wrong path. I'm struck that -- really, two 

7 things. One is that this is different than how 

8 DOE typically does a baseline. Typically, a 

9 baseline is the minimum product available. So, 

10 for example, if you're going to use the most 

11 common dishwasher available for the baseline, 

12 it would have been the last standard because 

13 the most common dishwasher available was an 

14 ENERGY STAR compliant product. It was above 

15 the minimum. So using the most common product, 

16 as Steve points out, is a different question 

17 than what is the least efficient product 

18 available.

19 MS. PIERCE: We found these two 

20 products to have similar efficacies and --

21 MR. deLASKI: But what they don't 

22 have is similar lifetimes.
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1 MS. PIERCE: Correct. But we felt 

2 that the consumer economics would be different 

3 for the two baselines because of the lifetime 

4 difference, so we assess both in the LCC 

5 analysis --

6 MR. deLASKI: Right. So what's 

7 puzzling to me is that -- I'm not a lighting 

8 engineer. The lighting engineers are on that 

9 side of the table or else they work with you 

10 guys, so you can answer that better than I can. 

11 So the question is, I mean, my understanding 

12 is that lifetime and efficacy are very much 

13 related when it comes to incandescent 

14 technology. These two things, they go in 

15 opposite directions so that, as a product, as 

16 you increase lifetime, you're reducing efficacy 

17 in an incandescent product, all other things 

18 equal.

19 MR. BROOKMAN: Joe? 

20 MR. HOWLEY: Right, that's correct. 

21 Therefore, if a lighting engineer were to look 

22 at these two products, they would clearly point 
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1 out that the first one was a lesser technology 

2 because it was only able to achieve 1,500 hours 

3 of life, where the second one is a more 

4 advanced technology. What you found in 

5 marketing catalogs is, basically, products that 

6 are designed for the consumer market or they 

7 don't need the long lifetime, and they're 

8 looking for, perhaps, a less expensive opening 

9 price point.

10 The second one is a product that 

11 would be sold more towards a commercial 

12 customer who is more concerned about long 

13 operating hours because they might use it in a 

14 store that burns them, you know, 16 hours a day 

15 and they don't want to be replacing lamps every 

16 other day. So they would gravitate more 

17 towards the higher-technology lamp, trying to 

18 reduce maintenance costs and those kinds of 

19 things.

20 So although they might have a 

21 similar efficacy, the first one truly would be 

22 the baseline lamp, as you described it, Andrew. 
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1 The second one would not be the baseline lamp. 

2 MR. deLASKI: Right. Adding from an 

3 analytical point of view, from an analytical 

4 point of view, what you've just done is you've 

5 just went up the first step on the energy curve 

6 with that because you just went up the 

7 technology curve, as Joe described it, to the 

8 first improvement. You've taken that first 

9 improvement, and you put it into the baseline, 

10 and that's the most cost effective improvement 

11 that has now been, basically, averaged into the 

12 baseline.

13 Now, the market, I think, is 

14 important. What Joe is describing, these 

15 market pieces is something that would come in 

16 somewhere else in the analysis, but not in the 

17 baseline. And to me, you know, your lifetime -

18 - so if you were to take that lamp, that 3,000-

19 hour lamp, hold all other things equal and 

20 reduced that lifetime, then it would have a 

21 higher efficacy.

22 MR. BROOKMAN: Steve? 
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1 MR. ROSENSTOCK: Steve Rosenstock, 

2 EEI. Especially to follow-up with Joe and 

3 Andrew, I guess then -- and please forgive me. 

4 I didn't read that part of the technical 

5 support document. In the LCC, are you doing, 

6 I'll say separate tracks for, I'll say the 

7 residential consumer market with, I'll say 

8 baseline one and the commercial market for 

9 baseline two and then aggregating the results? 

10 MS. PIERCE: We don't aggregate the 

11 results. They're separate. There's a 1,500-

12 hour residential, separate from commercial, and 

13 then a 3,000-hour residential separate from 

14 commercial.

15 MR. ROSENSTOCK: Okay, thanks. 

16 MR. deLASKI: This is Andrew again. 

17 And the way you would typically deal with that 

18 is you would, you know, deal with how the 

19 shipments shake out in your shipments baseline. 

20 If 100-percent of commercial shipments are 

21 already at this level, then you would reflect 

22 that in your shipments analysis and it would 
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1 flow through to the LCC and NIA, but you 

2 wouldn't capture that until you got those later 

3 analyses, as opposed to trying to build it into 

4 the baseline, which seems to me to be a more 

5 typical approach to this problem.

6 MR. BROOKMAN: Joe? No? Mike?

7 MR. MCGARAGHAN: Mike McGaraghan, 

8 California Utilities. I just wanted to 

9 reiterate the same point that Joe and Andrew 

10 just made. That was a big concern for us 

11 coming here today was these two baselines, and 

12 we agree that the true baseline here is the 

13 less efficient product with the shorter 

14 lifetime. Fifteen hundred hours is more 

15 representative of the sort of minimum lifetime 

16 that consumers expect from these lamps, so we 

17 recommend using that as your baseline product. 

18 MR. BROOKMAN: Okay, thank you. 

19 Steve? 

20 MR. ROSENSTOCK: Steve Rosenstock, 

21 EEI. I guess a quick follow-up. In your 

22 research, what percentage of the market for 
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1 these lamps is consumer and what percentage is 

2 commercial? 

3 MS. PIERCE: I know the answer to 

4 that, but I think it's confidential so --

5 MR. ROSENSTOCK: I'm not trying to 

6 get anything proprietary, just a generic --

7 MS. PIERCE: So I'll refrain from 

8 answering. 

9 MR. BROOKMAN: Charlie? 

10 MR. STEPHENS: Charlie Stephens. To 

11 follow-up on Steve's question, how do you 

12 determine what's residential and what's 

13 commercial? Do you do that by distribution 

14 channel, or do you do that by what socket it 

15 ends up in?

16 MS. PIERCE: Well, we just consider 

17 both in the LCC analysis. 

18 MR. STEPHENS: Consider both what?

19 MS. PIERCE: Commercial and 

20 residential.

21 MR. STEPHENS: I understand that, 

22 but I guess I'm wondering, given the volumes 
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1 that currently go through distribution channels 

2 like Lowe's and Home Depot right now where you 

3 really don't know whether it was commercial or 

4 residential, the socket that it ended up in, I 

5 guess I'm wondering how you knew that. 

6 MS. PIERCE: That might be more of 

7 an NIA question, which we'll get to later.

8 MR. STEPHENS: We can probably talk 

9 about that later, but I think when you start 

10 talking about lifetime and everything else, you 

11 know, I can buy that second lamp at Home Depot 

12 and I can do that for a commercial socket or a 

13 residential socket. 

14 MR. BROOKMAN: Alex? 

15 MR. BOESENBERG: This is Alex 

16 Boesenberg, NEMA. Perhaps Aisha knows, is that 

17 part of DOE's lighting market characterization? 

18 I don't recall. 

19 MS. HUSAIN: Specifically, the 60-

20 watt PAR38 distribution or --

21 MR. BOESENBERG: Well, I think 

22 there's a socketing data set there, and we can, 
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1 perhaps we can arrive at some agreement as to 

2 what percentage of those tend to be the higher 

3 technology.

4 MS. HUSAIN: Yes, they have splits 

5 on residential and commercial based on socket, 

6 as well, so --

7 MR. BOESENBERG: I think that's the 

8 answer then. 

9 MR. BROOKMAN: Are we ready to move 

10 on now? I think so. 

11 MS. PIERCE: Okay. DOE identified a 

12 more efficacious replacement lamp with a lower 

13 wattage and a lumen output within ten percent 

14 of the baseline lamps. The replacement lamp 

15 for both baselines was a 55-watt PAR38 improved 

16 HIR lamp, which means it is an HIR lamp with an 

17 improved reflector. It has a light output of 

18 1,100 lumens, an efficacy of 20 lumens per 

19 watt, and a lifetime of 4,400 hours. 

20 For the more efficacious 

21 substitutes, DOE requests comment on the 

22 criteria used in selecting substitute lamps, as 
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1 well as the characteristics of the lamps 

2 selected.

3 MR. BROOKMAN: Steve Rosenstock?

4 MR. ROSENSTOCK: Steven Rosenstock, 

5 EEI. I remember from the last rulemaking where 

6 the Justice Department was concerned about the 

7 higher standard levels because of that certain 

8 technologies for halogen infrareds were 

9 proprietary and that there were going to be 

10 competitive concerns because only a couple of 

11 companies were making, I'll say the highest 

12 efficacy lamp in this product category. So 

13 with this particular technology, is this, 

14 again, the issue where this might be a 

15 proprietary technology that's only made by a 

16 very limited or even just only one manufacturer 

17 -- again, I'm not trying to cause any trouble 

18 with anyone across the table here -- that is 

19 going to be limited in both, you know, also 

20 limited in availability and also the fact that 

21 it's, you know, the price could be, well, I'll 

22 just say extremely high, could have an 
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1 extremely high price point? 

2 MS. PIERCE: No, we did not find 

3 that to be an issue. 

4 MR. ROSENSTOCK: Okay, thank you. 

5 MR. BROOKMAN: Andrew? 

6 MR. deLASKI: So my concern with 

7 this table is that, you know, we're moving 

8 again, the table moves these two dependent 

9 variables, both lumens per watt and lifetime, 

10 so that the product that now is the more 

11 efficacious substitute is providing not just 

12 greater efficacy but also more light, more 

13 hours of lighting, greater utility. So we're 

14 ending up with a different product, which I 

15 think is being designed to meet some commercial 

16 consumer's desire for a long-lived product. 

17 And if you were to take that same product and 

18 reduce its hours to be the same hours as the 

19 baseline lamp, it would have a significantly 

20 higher efficacy, I think, from an engineering 

21 perspective.

22 MS. PIERCE: We were using only 
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1 commercially available lamps in the analysis.

2 MR. deLASKI: Right. I think that's 

3 probably, I think, in this case, the standard, 

4 the hours here are a limiting factor on your 

5 efficacies that you're looking at. 

6 MR. BROOKMAN: Keith? 

7 MR. K. COOK: Could you explain what 

8 is meant by an improved reflector? 

9 MS. PIERCE: So it uses the higher 

10 efficiency reflector, such as silver.

11 MR. K. COOK: But that is 

12 proprietary. 

13 MS. PIERCE: Would anyone like to 

14 comment on that? 

15 MR. HOWLEY: Well, I'd just like to 

16 comment that -- Joe Howley -- that DOE did find 

17 this to be an issue in the 2009 rulemaking. 

18 There's not been a lot of change in the world 

19 in the last three years, and I do think this 

20 factors in to your factor of impact on 

21 lessening the competition. I think this does 

22 probably have an impact there. I can't go any 
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1 further but to say that the world hasn't 

2 changed that much in three years when, as Steve 

3 pointed out, you did have that finding a few 

4 years ago. 

5 MR. BROOKMAN: Thank you. Mike?

6 MR. MCGARAGHAN: Mike McGaraghan, 

7 California Utilities. I believe that the world 

8 has changed a little bit since 2009 because 

9 we're starting to see other silverized 

10 reflector products on the market. And we'd be 

11 happy to submit comments along those lines 

12 documenting them. The one that comes to mind 

13 is Halco is marketing a silverized PAR product.

14 In terms of patents out there, I 

15 believe GE has one, I think DSI has one, and I 

16 know there's one at Lawrence Livermore Lab. I 

17 think there are other manufacturers that now 

18 have silverized reflectors, as well. I don't 

19 know if there's any in the room here that have 

20 a product with a silverized reflector that can 

21 speak to that, but it doesn't seem like it's a 

22 niche product anymore. It seems like that's 
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1 widely available so we support the use of that 

2 as a design option. 

3 And I guess I'll keep going. While 

4 we're talking about more efficacious 

5 substitutes, I am pretty concerned that there's 

6 only one CSL. There is huge potential in the 

7 IRL market for efficacy gains, and some of that 

8 is commercially available, some of it isn't. 

9 But starting with what's 

10 commercially available, DOE has not come close 

11 to identifying it, and I wrote them all down 

12 here so I can go through. But, at least 

13 according to the certification database, 

14 Philips has a 70-watt PAR38 at 22 lumens per 

15 watt. That's 13 percent better than the CSL 

16 value here. They have a 55 watt at 20.1 lumens 

17 per watt, 10 percent better than the CSL value. 

18 GE has a 23 lumens per watt product, 12 

19 percent better. I think Osram's best products 

20 are not in the certification database right 

21 now, at least I couldn't find them. 

22 And then there's a bunch of other 
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1 smaller manufacturers now that aren't 

2 represented here that have great products. The 

3 best one on the list was 25 percent better than 

4 CSL 1. 

5 There is huge potential for 

6 additional CSLs, two, three, four, among just 

7 the commercially available products. And that 

8 doesn't get into the products that are in 

9 development that have made huge strides in the 

10 last couple of years. I'm sure everyone has 

11 heard of the 2X lamp. You can buy them online. 

12 There's a website, 2X light now, or I'll send 

13 the link, but they have A lamps, they have MR16 

14 lamps, the PAR lamps it says coming soon. 

15 But DOE needs to think outside the 

16 box a little bit because these capsules which 

17 achieve this high efficacy are not rare 

18 products at this point or unachievable. 

19 They're not just prototypes. They're 

20 commercial products that can easily be dropped 

21 into other lamp form factors into reflector 

22 lamps. 
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1 And then they blow this number out 

2 of the water. We're talking 28, 30, 32. The 

3 lamp that we assembled in 2009 was a 37 lumen 

4 per watt lamp. That's almost twice as 

5 efficient as this CSL.

6 Now, there may be limitations, and 

7 that's part of the process. We need to look at 

8 the lamps and explore how much these lamps 

9 cost, can they be made, can they scale up 

10 production? But that's not even addressed 

11 here. DOE needs to look at max tech and then 

12 identify what's cost effective and feasible.

13 And we have a lot of data and would 

14 be happy to submit more information about this 

15 in our comments. But, at a glance, it just 

16 seems like we're aiming really short here.

17 MR. BROOKMAN: Okay. Keith? 

18 MR. K. COOK: I guess I'm a little 

19 concerned that here we are inventing lamps. We 

20 don't know anything about whether or not 

21 they're commercially available. In fact, we 

22 know they're not in some cases. We don't even 
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1 know if they're technically viable. We have 

2 demonstrated high as 37 lumens per watt, but, 

3 as far as we know, it only lasts 24 hours. So 

4 I think I've got a great concern over where 

5 we're headed on this discussion.

6 MR. BROOKMAN: Andrew? 

7 MR. deLASKI: I wanted to follow on 

8 to Keith and Mike. So, Mike, my understanding 

9 is that, because we talked before this, that 

10 you found a number of products in the DOE 

11 certification database that are certified to 

12 DOE today and then also just online in catalogs 

13 that have efficacies above the CSL 1. So these 

14 are not just the model that we --

15 MR. MCGARAGHAN: Correct. 

16 Currently, commercially available products --

17 MR. deLASKI: So I was puzzled -- so 

18 I guess our question to the Department is it 

19 seems like, in your own database, that there's 

20 a bunch of lamps that are higher than CSL 1, 

21 not just one or two but a bunch that are quite, 

22 if you put the plot up, you would see the dots 
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1 and there's quite a distribution. It looks 

2 like there should be two or three more CSLs 

3 above there. 

4 So I guess the question is how old 

5 is your data? Why is that? What happened? Is 

6 there any explanation, do you have any thought 

7 what the explanation would be why you wouldn't 

8 have captured those lamps that are --

9 MS. PIERCE: Sure, yes. Well, for 

10 one, we will reassess this in the NOPR 

11 analysis. Another consideration is that we try 

12 to keep the baseline, or the CSL lumens within 

13 ten percent of the baseline. So we base the 

14 CSLs on what technology options can be used to 

15 achieve them, so we adjusted them for 

16 compliance based on the range of technology 

17 options that could meet that. So if you have 

18 suggestions for alternative technology options 

19 that could meet those higher levels, we would 

20 take those. 

21 MR. deLASKI: So by that last point, 

22 do you mean that you may have ruled out some 
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1 lamps because you thought they were proprietary 

2 technologies? 

3 MS. PIERCE: No. We believed that 

4 they were all at the max tech technology option 

5 level. They were HIR lamps with improved 

6 reflectors.

7 MR. BROOKMAN: Joe? 

8 MR. HOWLEY: And if I could just 

9 make some comments. We would disagree with a 

10 lot of these comments being made here. We 

11 don't believe there's this pie-in-the-sky 

12 mystical technology out there that's going to 

13 triple the efficiency of these lamps. They are 

14 darn close to max tech right now. We believe 

15 this represents a very high efficiency level. 

16 What you're proposing is about where max tech 

17 was last time that you looked at it. Although 

18 there may be a couple more players in the 

19 market, the technology itself hasn't changed in 

20 the last three or four years or what you can do 

21 with it. And, certainly, this improved HIR 

22 does represent the highest technology class of 
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1 what we have today that has to meet many 

2 different customer requirements, have many 

3 different utilities, and address a lot of 

4 different needs in the marketplace.

5 And as you're moving up even to this 

6 level, you're starting to strain several of 

7 these utility product class needs based on 

8 technical feasibility, economic feasibility. 

9 As you go up higher, you're basically cutting 

10 out lots of different market utility leading to 

11 the fact that you might end up with one product 

12 that works for one customer and one 

13 application, and that's the only thing that's 

14 economically or technically feasible.

15 So it's a lot more complex than 

16 what's being portrayed here. And you are 

17 proposing a very high level which I would 

18 suggest, we would even suggest where you're at 

19 right now is fine. You don't need to go any 

20 higher. This, though, does represent kind of 

21 your max tech of what's available today that 

22 could cover across all the different market 
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1 needs.

2 MR. BROOKMAN: Mike, do you want to 

3 go next? 

4 MR. MCGARAGHAN: I'll let Alex go.

5 MR. BROOKMAN: Okay. Alex? 

6 MR. BOESENBERG: This is Alex 

7 Boesenberg, NEMA. Reading the previous rule, I 

8 didn't look it up myself but I'm told it was 

9 page 34096 in the Federal Register, I'll 

10 paraphrase here and there. Per IRL DOE will be 

11 determined the maximum max tech would 

12 incorporate the highest efficiency reflector 

13 halogen or coating filament design. Combining 

14 all three of these technologies simultaneously 

15 results in the max tech. However, because the 

16 only technology pathway to this level is 

17 dependent on a proprietary technology, DOE did 

18 not consider this level further in its 

19 analysis. The level set by the last rule was 

20 as high as we could get, certainly at that 

21 time.

22 So whether there are any 
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1 technological innovations that have happened 

2 since then is a valid point of discussion. But 

3 each one would have to be given the same level 

4 of rigor regarding whether it's a feasible 

5 pathway or not. 

6 MR. BROOKMAN: Mike?

7 MR. MCGARAGHAN: Yes, thank you for 

8 those comments. And I didn't mean to imply 

9 that it's simple. I think there are some 

10 complex issues. My point is that it's DOE's 

11 responsibility to look into those lamps and 

12 identify whether they're feasible or not. This 

13 lamp right here I think was $7 or something 

14 online. It's an MR16, so it's not a covered 

15 lamp. It's a smaller form factor. It's 37 

16 watt equals 50. It's essentially one of the 2X 

17 products I'm talking about. It's not pie-in18 the-sky, it's not mystical. It's a 

19 commercially available product.

20 Of course, it's not apples to 

21 apples. MR16 lamps have different design 

22 parameters, coatings on the lenses and they're 
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1 low voltage. They're also, being a smaller 

2 form factor is often considered a challenge for 

3 designing lamps. So, in that sense, some of 

4 that might even out, and you could expect to 

5 see real high efficacies and higher diameters, 

6 as well.

7 The prototype lamp that we developed 

8 last time, it's possible that we forgot to list 

9 its rated hours in our comment letter, which 

10 was our mistake. And there were a couple of 

11 things like that about the lamp, and DOE's 

12 response was California Utilities did not list 

13 the lifetime of that lamp so we can't consider 

14 it.

15 We would ask you to reach out to us 

16 and ask us that sort of question because we'd 

17 be happy to provide it was a 1,500-hour lamp, 

18 and these products are out there. They're not 

19 so far off. So this doesn't cover the 

20 potential of the market, by any means. And if 

21 DOE needs help gathering data, we're happy to 

22 help gather data.
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1 MR. BROOKMAN: Andrew? 

2 MR. deLASKI: On Joe's comment about 

3 utility impacts, absolutely, you know, we've 

4 got to look at the utility impacts of going to 

5 higher standard levels. It doesn't mean you 

6 don't look at the levels, though. To me, the 

7 issue here is DOE, in every rulemaking that 

8 I've been involved in, tries to cover the 

9 space, the efficiency space. And then as you 

10 get to higher levels, if you have utility 

11 impact, the whole utility impact analysis, that 

12 has to be done. So sometimes that leads to 

13 different choices about product classes, but 

14 you don't cut off the analysis. This is not a 

15 proposed level. It's just a level for 

16 analysis. The level that's even here is not a 

17 proposed level. It's just a level for 

18 analysis. And we think it's important that you 

19 cover the entire space of -- certainly what's 

20 available in the market and, as Mike suggests, 

21 even things that could be available. Max tech, 

22 typically, is something that, again, it's max 
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1 tech. The limitation is not market 

2 availability on max tech. But at a minimum, 

3 you need to cover what's available in the 

4 market and then look at the good questions that 

5 are being raised by industry that, you know, 

6 doesn't meet the needs of the market or the 

7 utility impacts. And then that's part of what 

8 DOE is compelled to do.

9 MR. BROOKMAN: Julie, go to the next 

10 comment box. Have we covered that?

11 MS. PIERCE: I think so. 

12 MR. BROOKMAN: I think so, as well. 

13 Let's move on.

14 MS. PIERCE: Okay. So we've touched 

15 on this, but, after identifying more 

16 efficacious substitutes for each of the 

17 baseline lamps, DOE developed CSLs based on the 

18 consideration of several factors, including the 

19 design options associated with the specific 

20 lamps being studied, for example the use of 

21 infrared coatings for IRLs; the ability of 

22 lamps across wattages to comply with the 
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1 standard level of a given product class, and

2 the max tech level.

3 DOE used an equation that is a 

4 function of wattage to determine the CSL. To 

5 determine the coefficient of the CSL equation, 

6 DOE reviewed catalog data of commercially

7 available lamps and their associated catalog8 rated efficacies. To establish final minimum 

9 efficacy requirements for CSLs, DOE analyzed 

10 publically available compliance data and 

11 adjusted the CSLs when necessary. As shown in 

12 the table, CSL 1 is 6.2 times the wattage to 

13 the 0.27 power.

14 DOE requests comment on the CSLs 

15 under consideration for IRLs.

16 MR. BROOKMAN: Including design 

17 options, ability of lamps across wattages to 

18 comply, and max tech level. Steve Rosenstock?

19 MR. ROSENSTOCK: Steve Rosenstock, 

20 EEI. The value that you showed inside 55, 

21 that's not adjusted for the spectrum diameter 

22 voltage, those are other values, correct? Or 
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1 is that, you know -- that's just for, I'll say 

2 the baseline, the baseline lamp, that's just 

3 for the two and a half, standard greater than 

4 two and a half-inch, less than 125-volt lamp --

5 MS. PIERCE: Right. 

6 MR. ROSENSTOCK: -- before the 

7 scaling? And the follow-up is the current 

8 number, is it 5.9 is the coefficient?

9 MS. PIERCE: That's correct.

10 MR. ROSENSTOCK: And this would go 

11 up to 6.2?

12 MS. PIERCE: That's correct.

13 MR. ROSENSTOCK: And, again, based 

14 on your analysis, again, this is basically --

15 and, again, based on what you showed before, 

16 this would be your consideration before the 

17 other analysis, before other things would be 

18 possibly considered, I'll say CSL 1 is equal to 

19 a max tech based on your current analysis?

20 MS. PIERCE: That's correct.

21 MR. ROSENSTOCK: Thank you. 

22 MS. PIERCE: Okay. And -- oh, 
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1 sorry. 

2 MR. deLASKI: I'm trying to 

3 understand how -- you based your analysis on 

4 products that are available in the marketplace.

5 MS. PIERCE: Yes.

6 MR. deLASKI: That's how you figured 

7 your CSLs. So then how did the design options 

8 play into that? Because you ask about design 

9 options here. I mean, how do you then use the 

10 design options to -- what role do they play in 

11 your analysis going forward since all you did 

12 is look at a product that's there so --

13 MS. PIERCE: That's, for example, 

14 the two baselines had distinct technology 

15 options. There was the improved halogen and 

16 the HIR and then the CSL 1 is based on an 

17 improved HIR. So if there are other technology 

18 options that we should consider, we would 

19 welcome comment going forward.

20 MR. deLASKI: To get you beyond the 

21 products that you're observing in the market?

22 MS. PIERCE: Right.
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1 MR. deLASKI: Okay.

2 MS. PIERCE: Okay. And issue 14, 

3 DOE invites comment on whether additional 

4 adjustments to the CSLs are needed to account 

5 for compliance requirements.

6 MR. BROOKMAN: Comments on 

7 compliance requirements? I see none.

8 MS. PIERCE: All right. Once DOE --

9 MR. BROOKMAN: We do have one. 

10 MS. PIERCE: Oh, sorry.

11 MR. BROOKMAN: Keith, please.

12 MR. K. COOK: Just maybe so you get 

13 a feel for how big this impact is, for our 

14 products right now, to move it to this 6.2 

15 coefficient would actually result in 59 percent 

16 of our products being eliminated from the 

17 market. And on the consumer channel, as it 

18 turns out, 81 percent would be eliminated. 

19 It's a huge impact, absolutely huge.

20 MR. BROOKMAN: And that's your 

21 company? 

22 MR. K. COOK: Yes, just Philips 
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1 alone.

2 MR. BROOKMAN: Steve Rosenstock?

3 MR. ROSENSTOCK: Steve Rosenstock, 

4 EEI. So those are products that are compliant 

5 with the 2012 standard, so, basically, if the 

6 manufacturers did a long-term investment, if 

7 they hadn't made their money within six years, 

8 oh, well.

9 MR. BROOKMAN: Andrew? Well, Keith, 

10 do you want to reply? 

11 MR. K. COOK: No, Steve is 

12 absolutely right. And that is what our major 

13 concern is is we did invest millions of dollars 

14 in this technology in order to meet EISA's 

15 requirements to have products that met the 

16 phase-out of tungsten filament incandescent, 

17 and now, all of a sudden, it's being 

18 potentially obsoleted with this rulemaking. 

19 It's just unbelievable. 

20 MR. deLASKI: So just to follow on, 

21 I think those numbers are, it makes sense to 

22 me. That's kind of what I would expect. If 
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1 anything, it's a little higher than I, I'm 

2 sorry, a little lower than I would have 

3 expected. I'm surprised to hear that 41 

4 percent of the products are already above the 

5 minimum standard, so that's impressive. You 

6 know, and that's why there's a manufacturer 

7 impact analysis and that's where a big part of 

8 the decision-making in any rulemaking, and 

9 rightly so. 

10 MR. BROOKMAN: Joe? 

11 MR. HOWLEY: And that's a concern 

12 industry has, just about the speed of this 

13 standard in back of the previous standard. 

14 We're only talking five and a half years, as 

15 was pointed out earlier, and that is, you know, 

16 makes it very difficult for manufacturers to 

17 recover investments in new technologies, even 

18 pushing up to their proposed levels, let alone 

19 anything further. It has a severe and negative 

20 manufacturer impact when you have these 

21 rulemakings so close together.

22 MR. BROOKMAN: Okay, thank you. 
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1 MR. deLASKI: Let me just follow on 

2 to that because that was being discussed when I 

3 came in this morning. I apologize for being a 

4 little bit late this morning. But my 

5 understanding is that DOE has a statutory 

6 obligation to do this rulemaking right now, so 

7 my reading of the law is that this is a 

8 statutorily required rulemaking, so it's not 

9 discretionary for DOE to do any other schedule 

10 than what they're doing right now. 

11 MR. K. COOK: That was my original 

12 question. I don't think there's any time frame 

13 that this one had to occur right now.

14 MR. deLASKI: I'll look at the 

15 statute, but that's not my understanding. I'll 

16 take a look. EPACT 92 is still the law of the 

17 land, and the law -- we can -- the law said you 

18 had to do it within a certain period of time 

19 after the last final rule. The last final rule 

20 was issued in 2009. That clock was triggered. 

21 This rulemaking is due now, according to the 

22 statute that your companies and our allies 
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1 worked out in 1992. 

2 MR. BROOKMAN: I think that we 

3 covered that this morning. Final comments here 

4 before we move on? Okay. 

5 MS. PIERCE: Okay. Once DOE 

6 determined CSLs for the representative product 

7 classes, it scaled the results to non8 representative product classes. For IRLs, DOE 

9 used a 15-percent decrease from standard 

10 spectrum to modified spectrum, a 15.5 percent 

11 decrease from large diameter to small diameter, 

12 and a 15-percent increase for 120-volt to 130-

13 volt lamps. These are the same scaling factors 

14 that were used in the 2009 lamps rule.

15 MR. BROOKMAN: Steve? 

16 MR. ROSENSTOCK: Steve Rosenstock, 

17 EEI. Just out of curiosity, what kind of range 

18 did you see? 

19 MS. PIERCE: I'm sorry. I don't 

20 understand the question. 

21 MR. ROSENSTOCK: Range of decrease. 

22 What was the range, just out of curiosity?
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1 MS. PIERCE: I still don't 

2 understand.

3 MR. ROSENSTOCK: This is a median 

4 value or a mean value. What you're trying to 

5 say is, for the most part, when you're scaling, 

6 basically, because most of the lamps that are 

7 not analyzed will have a 15-percent decrease in 

8 the efficacy. I'm just kind of curious about 

9 what was the range of decrease in efficacy that 

10 you saw. I'd like to know about the variance. 

11 Was it 14 to 16? Was it 10 to 20? Was it 5 

12 to 20, you know, 5 to 25? What was the range 

13 of the decrease that you saw?

14 MS. PIERCE: So I would encourage 

15 you to look in the TSD. Each of these scaling 

16 factors had a different way that it was 

17 analyzed, so some were using test results, et 

18 cetera. So I would encourage you to look 

19 there.

20 MR. ROSENSTOCK: Thank you. 

21 MR. BROOKMAN: Joe? 

22 MR. HOWLEY: So the results, Steve 
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1 and others, we, industry, originally asked for 

2 more leeway on the modified spectrum. Fifteen 

3 percent was settled on. And I think you have a 

4 note somewhere in here. I'm wondering why 

5 there's almost no modified spectrum lamps in 

6 the market today because that was barely enough 

7 of a decrease to have that technology continue.

8 The PAR20s have the same issue. I 

9 think there's a comment about why don't we 

10 still have PAR20s that are compliant. Again, 

11 this percentage decrease is barely enough of a 

12 decrease to continue to make compliant PAR20 

13 lamps due to difficulties in trying to fit 

14 halogen IR tubes into small PAR20 envelopes, 

15 which we also discussed in the 2009 rulemaking. 

16 The 130-volt lamps, and we discussed 

17 this again in 2009, actually are less efficient 

18 than 120-volt lamps. So when you apply a 15-

19 percent increase on a less efficient 

20 technology, you really don't have to ask why 

21 these products don't exist at all today. They 

22 have been pretty much wiped out by the 2009 
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1 rulemaking because we believe they're being 

2 corrected in the wrong direction, making it 

3 impossible to hit these levels. 

4 So if you're to increase this yet 15 

5 percent on top of already an unachievable 

6 standard, I'm not sure how you justify energy 

7 savings, given that there is no products in the 

8 marketplace today. So now I'm not sure what it 

9 is. You're 15 percent on top of a level that 

10 can't be met, so I'm not sure how energy 

11 savings are justified. Now it's just we're off 

12 into outer space and we just keep going out 

13 there, although there's no products that are 

14 going to be made that ever meet these levels. 

15 So it just seems, it doesn't seem right, from a 

16 technology review standpoint. We'd disagree 

17 strongly with the 15-percent increase for the 

18 130-volt lamps on top of a level that's already 

19 unachievable. 

20 MR. BROOKMAN: Mike? 

21 MR. MCGARAGHAN: Mike McGaraghan, 

22 California Utilities. I wanted to comment on 
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1 the allowance given to small-diameter 

2 directional lamps. My read of DOE's analysis 

3 was that you compared a bunch of existing lamps 

4 on the market, small-diameter lamps to larger 

5 diameter lamps, and established that there was 

6 a 12-percent difference.

7 MS. PIERCE: That's correct. 

8 MR. MCGARAGHAN: And then you made 

9 an assumption that double-ended burners could 

10 not be fit into those smaller lamps, and so you 

11 modeled the losses from double-ended burners or 

12 single-ended burners and added that. So I 

13 didn't understand why you would add those two 

14 together. To me, the original analysis, 

15 comparing small-diameter lamps to larger 

16 diameter lamps, gave you a number. It was 12 

17 percent. So maybe I'll stop there and let you 

18 answer that. 

19 MS. PIERCE: Yes. So that 

20 comparison was done using lamps before the 2012 

21 standards went into effect, so they may not 

22 have been using halogen technology. We found 
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1 limited small-diameter lamps on the market now. 

2

3 MR. MCGARAGHAN: That doesn't answer 

4 the question of why you would add the losses 

5 from a single-ended burner, once you've already 

6 established that there's a 12-percent 

7 difference between large and small.

8 MS. PIERCE: Because that 12 percent 

9 was with lamps without burners.

10 MR. MCGARAGHAN: Okay. Okay. 

11 Second point here is that there are small12 diameter lamps with double-ended burners. This 

13 is a Philips product currently on the market. 

14 It's an MR lamp, so it's even smaller than a 

15 PAR20, and it has a double-ended burner in it. 

16 It could mean that the filter is, I'm sorry, 

17 the lens is clear, so you can see it. I can 

18 pass it around. This isn't a PAR20 lamp with a 

19 double-ended burner. This one is in pre20 production right now. A manufacturer sent it 

21 to someone in my company, and I brought it to 

22 show today, but it's a PAR20 with a double-
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1 ended burner. So I can leave this with DOE if 

2 you would like to look at it, but double-ended 

3 burners can fit in small-diameter lamps.

4 MS. PIERCE: Yes, that would be 

5 great. Actually, part of this request for 

6 comment, and we would like to get feedback from 

7 manufacturers, as well, if possible, is if our 

8 assumption that double-ended burners cannot fit 

9 into small-diameter PAR lamps is correct. We 

10 can't use the MR16 because that's out of scope, 

11 but we were curious to see what feedback there 

12 was on that, so thank you. 

13 MR. BROOKMAN: Any additional 

14 comment here? Andrew? 

15 MR. deLASKI: A follow-up. I 

16 understand the MR16 is out of scope, but the 

17 burner in that would fit into that lamp. 

18 MS. PIERCE: Can the manufacturers 

19 speak to that? 

20 MR. BROOKMAN: Joe? 

21 MR. HOWLEY: It's a 12-volt 

22 filament, which are much, much shorter than 
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1 120-volt filaments.

2 MR. MCGARAGHAN: The other one is

3 line voltage, and, yes, DOE can -- actually, I 

4 could leave both of them, and you can take them 

5 apart and play with them. Yes, that's -- I'll 

6 leave it there. 

7 MR. BROOKMAN: Okay. Final comments 

8 here? Okay.

9 MS. PIERCE: Okay. Another part of 

10 this request for comment was DOE was unable to 

11 identify the specific UL safety standard 

12 mentioned by NEMA that requires a minimum 

13 distance between the halogen capsule and the 

14 glass envelope. DOE requests additional 

15 information on this UL safety standard, 

16 including the standard number and minimum 

17 required distance.

18 MR. BOESENBERG: This is Alex 

19 Boesenberg, NEMA. I'm still looking for that. 

20 I may have spoken incorrectly about it being 

21 an issue of the glass envelope, you know, sort 

22 of the front half or the face of it. And it 
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1 may be that the issue, as raised to me, has to 

2 do with socket heating or the luminaire 

3 heating. The classic example would be every 

4 lamp you have at home with a screw-based socket 

5 has a sticker on it that says 60 watts max or 

6 something like that. That has to do with heat. 

7 I'm now going down that road to see what I can 

8 figure out. 

9 MS. PIERCE: Okay. Thank you. 

10 MR. BROOKMAN: Okay. 

11 MS. PIERCE: Okay. DOE also 

12 generally requests comments on the overall 

13 methodology and results of the GSFL and IRL 

14 engineering analyses. 

15 MR. BROOKMAN: I think we've 

16 received some global comment on the overall 

17 methodology and results. Additional comments 

18 here? No additional comments. Okay. Let's 

19 press on with product price determination.

20 MS. PIERCE: Okay. Now I will 

21 discuss the product price determination. DOE 

22 estimated end user lamp prices directly, rather 
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1 than developing manufacturer selling prices, 

2 because GSFLs and IRLs are difficult to break 

3 down to discrete components and reverse 

4 engineer. In its research, DOE found a range 

5 of end user prices that were dependent on the 

6 distribution channel used. 

7 To represent this range, DOE 

8 developed three discounts using lamp blue book 

9 prices. The low end lamp user prices are based 

10 on purchases through state procurement 

11 channels. The medium prices are representative 

12 of purchases through large distributors or DIY 

13 stores. And high prices are based on internet 

14 retailers.

15 Data for this analysis was gathered 

16 after the July 2012 standards required 

17 compliance. DOE also estimated end user prices 

18 for fluorescent lamp ballasts using the pricing 

19 information developed in the 2011 ballast rule. 

20

21 DOE requests comment on the 

22 estimated end user prices for GSFLs and IRLs, 
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1 as well as the methodology used to develop 

2 them. 

3 MR. BROOKMAN: Andrew deLaski?

4 MR. deLASKI: So it looks like 

5 they're not going to show you the prices that 

6 you came up with in your slide, but they're in 

7 the materials for the TSD. So we tried to, the 

8 high prices on IRLs surprised us on how high 

9 they were, $23 I think in one case for CSL 1. 

10 So we tried to corroborate those just through 

11 some internet searches, and we couldn't. So 

12 those high prices strike us as being too high.

13 It also strikes us that, you know --

14 I'm curious, you know. So the DIY, just the 

15 Lowe's, Home Depot, et cetera, is your medium 

16 case, yet there are these internet sales that 

17 are the high case, so who the heck is buying 

18 off the internet because I could buy from 

19 Lowe's and Home Depot off the internet, too. 

20 If you want to do an internet search, that's 

21 what you're going to get first if you're a 

22 consumer. And if you're commercial, hopefully 
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1 you're smart enough not to pay more.

2 So I'm wondering what's this high 

3 channel? 

4 MS. PIERCE: Can manufacturers speak 

5 to that? 

6 MR. BROOKMAN: Joe? 

7 MR. HOWLEY: I mean, all I can say 

8 is that DOE and the internet is a vast and wide 

9 place. DOE obviously found these prices. It 

10 doesn't surprise us they found these prices. 

11 We know that these lamps are sold in a myriad 

12 of different channels, which, you know, exist 

13 out there. So it probably represents a high 

14 point on those lamps, but some retailers, even 

15 small stores or internet, have set their own 

16 price points and can set very high price points 

17 on these products. It's not surprising to us 

18 the price levels they had. 

19 MR. deLASKI: So how would DOE 

20 weight those prices in your analysis? Have you 

21 thought about that yet? 

22 MS. PIERCE: Yes. So we used the 
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1 medium lamp price, and then we did 

2 sensitivities in the LCC analysis using high 

3 and low prices.

4 MR. deLASKI: Okay. I mean, I'm 

5 struck by that, you know. I think you'd be 

6 careful about both the high and the low because 

7 I can't get the low price. That's a state 

8 purchase contract. The consumer certainly 

9 can't get that. And if a consumer is choosing 

10 that high price point, the consumer is making 

11 that, that's their choice. If I want to buy 

12 the new Stephen King novel, I can walk down to 

13 my local retailer near my house and pay $33, 

14 you know, the list price on the book. I could 

15 buy it from Amazon for 50 percent of that or I 

16 can go to Barnes and Noble now, I guess I can't 

17 go to Borders anymore, and get it for 30 

18 percent off. So I have all kind of prices I 

19 can pay for the new Stephen King novel, but if 

20 I'm choosing to pay that list price it's 

21 because I want to support my local bookseller 

22 who's my friend or something. I'm getting a 
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1 different value out of that is my point. So 

2 I'm suspicious of this high price in your 

3 analysis. 

4 However, my point, I guess, is that 

5 I think very few lamps are being sold at that 

6 price would be my supposition, whereas at that 

7 low price a lot of lamps are being sold at that 

8 because those are big contracts. So I'm not 

9 quite sure how that, ultimately, should be 

10 weighted, but I would think that you should 

11 weight both that medium and that low price in 

12 the analysis.

13 MS. PIERCE: So we'll look at the 

14 results of the LCC sensitivities more in the 

15 NOPR stage.

16 MR. BROOKMAN: Charlie Stephens?

17 MR. STEPHENS: Charlie Stephens. 

18 Just to add on to what Andrew said, I don't 

19 think it calls for sensitivity. I think it 

20 calls for an attempt to weight the prices and 

21 come up with some sort of rational weighting 

22 for that, as he pointed out. I know where I 
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1 live, the state contract is available for every 

2 government entity or semi-government entity to 

3 buy with. And so Andrew is right, there's a 

4 lot of lamps go through those channels, and I 

5 think it's important that you give appropriate 

6 weight to the pricing that is actually used in 

7 the marketplace.

8 MR. BROOKMAN: Okay, thank you. Did 

9 we cover ballast prices? I don't think so.

10 MS. PIERCE: No. So in issue 18, 

11 DOE requests comment on the estimated ballast 

12 prices developed using the 2011 ballast rule. 

13 DOE also requests comment on the assumption 

14 that ballast pricing does not change between 

15 low and normal ballast factor ballasts. As 

16 will be discussed in a few slides, DOE 

17 evaluated the effects of lighting controls on 

18 life-cycle costs for GSFLs by examining impacts 

19 of dimmers on GSFLs. Therefore, DOE also 

20 estimated end user prices for dimming ballasts.

21 DOE requests comment on its 

22 determination that prices of dimming ballasts 
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1 are, on average, 120-percent higher than prices 

2 of fixed light output ballasts. 

3 MR. BROOKMAN: Comments on ballasts, 

4 ballast prices? Michael?

5 MR. MCGARAGHAN: Just a question. 

6 Did the ballast prices change in your standards 

7 case scenario versus your base case scenario? 

8 MS. PIERCE: Maureen can speak to 

9 that.

10 MS. KIENLE: It's the same price.

11 MR. BROOKMAN: No comments from 

12 manufacturers on ballast prices? Too close to 

13 home. 

14 MR. K. COOK: Well, technically, 

15 we're not allowed to.

16 MR. BROOKMAN: Yes, right, right. 

17 Mike? 

18 MR. MCGARAGHAN: Mike McGaraghan. 

19 Another question. In the portion of the TSD 

20 that discusses life-cycle cost analysis, 

21 there's a line item called installation cost, 

22 which I think is a roll up of the product cost 
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1 and the labor to install. Is there a place in 

2 the TSD where we can see that breakout 

3 specifically for each scenario, what was the 

4 assumed product cost and what was the assumed 

5 installation cost? 

6 MS. PIERCE: Yes, Chapter 7 has the 

7 product costs and Chapter 8 has the 

8 installation costs. 

9 MR. MCGARAGHAN: Thank you. Those 

10 are by your LCC scenario, though.

11 MS. PIERCE: They may not be listed 

12 out for each scenario, but from the surrounding 

13 information you should be able to determine it. 

14 MR. BROOKMAN: Additional comments 

15 here? I'm going to suggest we take lunch. 

16 It's now 12:20, and we're a little behind 

17 schedule, maybe as much as a half an hour or 

18 more. But we'll make that up as we go along. 

19 It's now 12:20. Do any of you not know where 

20 you're going in this building at this point? I 

21 think most of you are -- down to the ground 

22 floor, about 100 yards in that direction.
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1 (Whereupon, the foregoing matter 

2 went off the record at 12:20 p.m. and went back 

3 on the record at 1:23 p.m.)

4

5

6

7

8

9

10

11

12

13

14

15

16

17 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N

18 (1:23 p.m.)

19 MR. BROOKMAN: Let's start back up. 

20 I hope you had a nice lunch. We are going to 

21 pick up where we left off with Julie, and I 

22 believe that's energy use.
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1 MS. PIERCE: Yes. So now we will 

2 discuss the energy use and life-cycle cost 

3 analysis. The purpose of the energy use 

4 characterization is to estimate the energy 

5 consumption of baseline and higher efficacy 

6 lamps. The results of this analysis are used 

7 in the LCC, payback period, and NIA analyses. 

8 Energy use is calculated as input power times 

9 operating hours.

10 Various DOE sources were used to 

11 derive the operating hours, including the 

12 Lighting Market Characterization and EIA's 

13 CBECS, RECS, and MECS data sets. Using these 

14 sources allows DOE to account for variation in 

15 annual operating hours across census divisions 

16 and large states by building type and lighting 

17 application.

18 This table shows average annual 

19 operating hours for GSFLs and IRLs in each 

20 sector. IRLs were not analyzed in the 

21 industrial sector since they have such a small 

22 market share in that sector.
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1 DOE welcomes comment on the end use 

2 operating profiles for the lamp types covered 

3 under this rulemaking.

4 MR. BROOKMAN: Steve? 

5 MR. ROSENSTOCK: Steve Rosenstock. 

6 Going back to the slide in terms of residential 

7 operation, especially for IRLs, you show 761, 

8 which I've seen other studies that that's seen 

9 that way, but the key issue is, since there's

10 so many fixtures in typical residential 

11 applications, is what kind of diversity factor 

12 are you assuming for those IRLs in the home? 

13 MS. PIERCE: I'm not sure what you 

14 mean by diversity.

15 MR. ROSENSTOCK: Suppose there's ten 

16 fixtures for the IRLs in the home. How many of 

17 them are you thinking that are operating that 

18 will have these operating hours in the 

19 analysis? 

20 MS. PIERCE: So these are the 

21 average operating hours. The LMC provides data 

22 for IRLs broken down by room and building type. 
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1 And then we used the EIA data sets to take a 

2 weighted average, so this was a weighted 

3 average value. 

4 MR. BROOKMAN: Charlie? 

5 MR. STEPHENS: Charlie Stephens. 

6 I'll get you some data probably next month from 

7 our field survey. We monitored 2,200 fixtures 

8 in the residential sector for energy use, and 

9 we surveyed 1,400 houses for exactly what type 

10 of technology is in what fixture type in what 

11 room in those houses. And so, hopefully, you 

12 can have at least some data to verify what you 

13 have up here. 

14 MR. BROOKMAN: Can you give us a 

15 flavor, an early snapshot? Are these anywhere 

16 in the ballpark?

17 MR. STEPHENS: I can't right now. 

18 We're getting the report published here 

19 probably the first week of next month. It will 

20 be available on our website. And the database 

21 will be available with the raw data in it, 

22 cleansed of addresses, that has all the 
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1 demographics and everything that go along with 

2 it. 

3 MR. BROOKMAN: Great, thank you. 

4 Other -- yes, Joe? 

5 MR. HOWLEY: Just another question 

6 about the analysis. 

7 MR. BROOKMAN: Are you on?

8 MR. HOWLEY: I'm on.

9 MR. BROOKMAN: Oh, okay.

10 MR. HOWLEY: I’ll get a little 

11 closer. Do these hours include any kind of 

12 analysis for dimming effects, or are these 

13 operating hours assuming sort of a full on 

14 position?

15 MS. PIERCE: So the LMC actually 

16 accounts for occupancy sensors, so it would 

17 just be the on/off, and then we treat dimming 

18 in a separate analysis.

19 MR. HOWLEY: Okay. So that's 

20 factored on top of this analysis. So they're 

21 on, but you don't have what state they're on. 

22 The state that they're on is, like, how dimmed 
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1 or not dimmed they are. That's looked at in a 

2 different analysis? 

3 MS. PIERCE: Yes. 

4 MR. HOWLEY: Okay.

5 MR. STEPHENS: I should probably add 

6 we're doing the same thing in the commercial 

7 sector right now, and I don't know if I can get 

8 you any data by the fall but we'll try to get 

9 you updated data from the commercial sector as 

10 quickly as we can.

11 MS. PIERCE: Okay.

12 MR. BROOKMAN: This is an important 

13 bit of data here. It would be useful if 

14 someone could comment about what they think 

15 about these numbers, if anybody is in a 

16 position to do so. Joe?

17 MR. HOWLEY: They look reasonable.

18 MR. BROOKMAN: Okay. That's a 

19 start. Okay. Yes?

20 MR. ROSENSTOCK: Steve Rosenstock, 

21 EEI. The industrial number is interesting to 

22 me because industrial in the process area, I 
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1 mean the GSFL in the process area versus the 

2 office area, it's going to be, I think it 

3 should be a little bit more bifurcated than 

4 that.

5 MR. BROOKMAN: Good. 

6 MS. PIERCE: DOE assessed impacts on 

7 life-cycle costs and payback periods in 

8 sensitivity scenarios where GSFLs and IRLs are 

9 operated on dimming systems. To develop annual 

10 energy consumption for these dimming systems, 

11 DOE used the system input power ratings as a 

12 result of dimming and the annual operating 

13 hours. 

14 DOE made certain assumptions to 

15 determine the system input power ratings. For 

16 GSFLs, DOE assumed a 33-percent lamp and 

17 ballast lumen reduction, on average. The 

18 associated system input power reduction was 

19 calculated based on characteristics of the 

20 dimming ballasts analyzed. DOE assumed that 

21 dimming does not change lamp lifetime for 

22 GSFLs. 
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1 For IRLs, DOE assumed a 25-percent 

2 lumen reduction, on average, which corresponds 

3 to a 20-percent reduction in wattage and a 

4 lifetime multiplier of 3.94. For IRLs, in 

5 addition to calculating LCC savings for 

6 individually dimmed lamps, DOE also assessed an 

7 LCC scenario in which a certain percentage of 

8 the population used dimmers: 29 percent for the 

9 residential sector and 5 percent for the 

10 commercial sector. Lighting controls are also 

11 analyzed as part of the NIA. 

12 DOE requests comment on the dimmed 

13 GSFL systems analyzed, in particular the lamp 

14 types included in the dimming scenarios and the 

15 assumption that light output and input power 

16 scale linearly for dimming systems. 

17 MR. BROOKMAN: Pekka?

18 MR. HAKKARAINEN: Pekka Hakkarainen, 

19 Lutron. I don't have comments on the 

20 fluorescent lamps. I have a couple of comments 

21 on the IRLs. The lifetime multiplier that you 

22 reported, 3.94, I believe is based on the 
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1 standard incandescent formula that's published 

2 in the IES handbook, for example, for reduction 

3 to 20 percent of wattage, 20-percent reduction 

4 in wattage. 

5 I was a co-author on a paper some 

6 years ago that we presented at IES that I'm 

7 happy to supply with our written comments. We 

8 think that the multiplier is lower for halogen 

9 PAR lamps, somewhere between three and four but 

10 not as close to four as you are indicating 

11 here. 

12 And then as far as the percentage of 

13 IRLs in the residential sector being on 

14 dimmers, I'm curious what the source of your 

15 data, what your source is for this number, the 

16 29 percent number is. I think the Lighting 

17 Market Characterization say 25 percent, so 

18 maybe you have something else.

19 MS. PIERCE: It's from the Lighting 

20 Market Characterization, and we also added 

21 light sensors because we assumed that they had 

22 the same impact as dimmers. So we welcome 
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1 comment on that. It was 25 percent for dimmers 

2 and 4 percent for light sensors. 

3 MR. BROOKMAN: Steve Rosenstock?

4 MR. ROSENSTOCK: Steve Rosenstock, 

5 EEI. You know, with the sensors, it's not a 

6 dimming sensor, it's an on/off sensor, right? 

7 That's the other four percent? 

8 MS. PIERCE: No, I'm sorry. It was 

9 light sensors where --

10 MR. ROSENSTOCK: Daylight sensors?

11 MS. PIERCE: Yes, yes.

12 MR. ROSENSTOCK: Daylight sensors.

13 MS. PIERCE: So the occupancy 

14 sensors are accounted for in the energy use 

15 profile.

16 MR. ROSENSTOCK: Okay. And Steve 

17 Rosenstock, EEI. I'm surprised that, for the 

18 commercial sector, that five percent. I'm just 

19 surprised it's that low. I just figured that, 

20 especially in the commercial sector, I thought 

21 it would be higher, just so many conference 

22 rooms. A lot of areas where they'd be tend to 
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1 be a lot of dimmer control, so that number

2 looked, seemed a little low to me. Again, I 

3 didn't do any studies, just from some of my 

4 experiences. 

5 MR. HAKKARAINEN: I don't have any 

6 independent data, Steve. But this may be 

7 reasonably accurate.

8 MR. BROOKMAN: Joe? 

9 MR. HOWLEY: I think, perhaps, that 

10 was based on what has occurred in the past. 

11 Perhaps, five percent of these systems are 

12 dimmed. But going forward in the future, and 

13 I'm not sure how far you took this into the 

14 future, we expect a lot more fluorescent 

15 systems to be controlled and dimmed. Some of 

16 the building energy codes are requiring it in 

17 more and more spaces. Therefore, I think you 

18 shouldn't leave the five percent steady state 

19 over the analysis period. It should be an 

20 increasing number as these codes come into 

21 play.

22 MR. BROOKMAN: Steve?
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1 MR. ROSENSTOCK: Steve Rosenstock, 

2 EEI. Especially the next edition of ASHRAE, 

3 90.1-2013, there are more requirements for more 

4 lighting systems to have control systems. 

5

6 MS. PIERCE: Yes, just to reiterate what 

7 she said. That's accounted for in the NIA. So 

8 these are specific to the LCC, which is a one9 time consumer impact.

10 MR. BROOKMAN: Pekka? 

11 MR. HAKKARAINEN: Pekka Hakkarainen 

12 from Lutron. Did you also take into account 

13 Title 24 in California that comes into effect 

14 next January where virtually every lamp in 

15 commercial installations is going to have some 

16 level of level control? 

17 MS. PIERCE: If it's accounted for 

18 in the LMC, then I did. But I didn't use it 

19 independently. They --

20 MR. BROOKMAN: Mike? 

21 MR. MCGARAGHAN: Mike McGaraghan, 

22 California Utilities. That would not be 
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1 accounted for the LMC because that was passed 

2 after that document was published. 

3 MS. PIERCE: Okay. We'll look into 

4 that. 

5 MR. MCGARAGHAN: And then a question 

6 here. I see 29 percent of halogen IRLs in the 

7 residential sector will be on a dimmer and 5 

8 percent in the commercial sector. Did you 

9 present those numbers for GSFLs already and I 

10 missed them? 

11 MS. PIERCE: No. So in the LCC, we 

12 didn't do a population-based GSFL analysis 

13 because of the different types of dimmers used. 

14 We were only able to do it for IRLs.

15 MR. MCGARAGHAN: I see.

16 MS. PIERCE: But the NIA addresses 

17 GSFLs more.

18 MR. MCGARAGHAN: Okay. And did you 

19 explain where you got the five percent from?

20 MS. PIERCE: The LMC.

21 MR. MCGARAGHAN: It specifically 

22 called out commercial sector reflector lamps?
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1 MS. PIERCE: Yes. 

2 MR. BROOKMAN: Pekka? 

3 MR. HAKKARAINEN: Pekka Hakkarainen, 

4 Lutron. I did actually have a fluorescent 

5 comment. I forgot about that earlier. Sorry. 

6 In issue 20, you say that the light output and 

7 input power scale linearly for dimming systems. 

8 Not quite. They have an offset at the low end 

9 that accounts for the required electrode 

10 heating in the lamps, and that's typically a 

11 few percent of the total maximum rated power. 

12 And then it's, more or less, linear from there. 

13 Thereon, you can draw a straight line between 

14 those two points, but it's not from zero. 

15 MS. PIERCE: Okay, thank you. 

16 MR. BROOKMAN: Thank you. Helpful. 

17 Joe? 

18 MR. HOWLEY: Yes, just one more 

19 thought, as this discussion is going on. Is 

20 that -- for the GSFL, if the lumen per watt 

21 level is set such that you'd have to go to a 

22 krypton-based lamp, in other words a heavier 
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1 fill gas to hit those levels, you would have to 

2 then start to reduce your national impact 

3 savings because what you would do at that point 

4 is eliminate the ability to control and dim 

5 them. Although the dimmers and controls may be 

6 forced to be in these buildings, none of them 

7 would work very well. So you would actually 

8 have negative savings nationwide due to lack of 

9 dimming if the standards went so high on a 

10 lumen per watt standpoint that you had to use a 

11 krypton-based lamp to meet that standard. So 

12 you're at a tipping point here where, if you go 

13 too far, you're going to have a negative impact 

14 on national energy savings. 

15 MR. BROOKMAN: Mike? 

16 MR. MCGARAGHAN: Mike McGaraghan. 

17 I'm just curious if there are studies or anyone 

18 could help break down that issue a little bit 

19 more, in a little bit more detail what the 

20 impact of going to krypton as a fill gas has on 

21 dimming. You said they won't dim well. Has 

22 this been published or tested, or is this sort 
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1 of empirical? Can you expand on that? 

2 MR. HAKKARAINEN: Pekka Hakkarainen, 

3 Lutron. There is a lot of, certainly, 

4 manufacturer testing that has been done. I'm 

5 not aware of any NEMA publication on this 

6 topic, so probably nothing that has been 

7 published. Keith, do you know? 

8 MR. K. COOK: No, and the problem is 

9 the same one that ENERGY STAR’s running into. 

10 There's no standards right now for dimming, so 

11 there would not be anything published because 

12 there's nothing to compare to.

13 MR. BROOKMAN: Thank you, Keith.

14 MR. HAKKARAINEN: So just to 

15 clarify, the standards do exist for argon16 filled lamps for dimming purposes but not for 

17 lamps that have krypton in them.

18 MR. BROOKMAN: So that was Pekka. 

19 Now to Joe. 

20 MR. HOWLEY: Just manufacturer 

21 experience, we know that these issues occur 

22 because we get customer complaints when people 
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1 attempt to do this and they don't work 

2 properly, and we suggest they go back to an 

3 argon-based lamp in those applications. There 

4 are some applications where they do work okay, 

5 but we get into more questionable dimming 

6 whenever we have to put krypton in them and we 

7 try to control or dim them. 

8 So it's not a, there's not a bright 

9 line here. It's kind of an application-by10 application issue that we're running into.

11 MR. BROOKMAN: Please say your name. 

12 That's not on. There ought to be a button 

13 there. There you go. 

14 DR. GARBESI: Hi. So Karina Garbesi 

15 from LBL. Just for clarification for the 

16 analysis, you referred a couple of times to the 

17 krypton having problems with dimming. Are 

18 there any other technologies in these low19 wattage lamps that we know of that do not have 

20 those kinds of problems, or is krypton really 

21 the only option there? You know of nothing 

22 else. Thank you. 
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1 MR. BROOKMAN: So for the record, 

2 Joe says that's the only option they're using 

3 right now, and he knows of nothing else. Alex? 

4 MR. BOESENBERG: Alex Boesenberg, 

5 NEMA. So I want to paraphrase or summarize 

6 what I heard from the different manufacturers I 

7 have present in the room about krypton and its 

8 effects is what I've heard, and I'll allow them 

9 to contradict me, is the lamps in the market 

10 are optimized for their performance if you want 

11 them to dim. To add any krypton, you start to 

12 lose performance, and the reason they don't use 

13 it is because they don't, it's a feature or 

14 whatever. Does that make sense? Customers 

15 want it to dim, so that's why they don't put 

16 krypton in them. 

17 MR. BROOKMAN: Okay. Mike?

18 MR. MCGARAGHAN: Sorry. To make 

19 sure I'm clear on this, the manufacturers at 

20 the table here are not aware of any way to make 

21 a low-wattage lamp that dims well; is that a 

22 simple way to say that? 
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1 MR. BROOKMAN: Keith? 

2 MR. K. COOK: It's not quite that 

3 clear. I mean, the problem is is there is 

4 sometimes compatibility issues. You can have -

5 - typically, there's three things that would be 

6 involved. It's ballasted is one thing. We 

7 have issues between compatibility of the dimmer 

8 and the lamp itself, and so with certain 

9 dimmers you may end up possibly working in a 

10 certain environment in a certain application. 

11 We've seen cases where we take that exact same 

12 setup and put it into a different building, and 

13 it wouldn't work. We can't explain it. We 

14 don't understand. But that's reality. That's 

15 the way it works. So in the first application, 

16 it may work perfect. You couldn't find anything 

17 better. 

18 So we're still trying to understand 

19 it ourselves, and that's the reason we're 

20 working on all sorts of new specifications, 

21 trying to get our arms around it. But it's 

22 still kind of more art than science. 
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1 MR. MCGARAGHAN: And does the 

2 problem get worse as you go down in wattage, 

3 typically?

4 MR. K. COOK: Yes. 

5 MS. PIERCE: Okay. Thank you. Now 

6 I will discuss the life-cycle cost and payback 

7 period analyses. The LCC and payback period 

8 analysis is used to assess the impacts on a 

9 consumer due to potential energy conservation 

10 standards. The analysis is conducted from a 

11 consumer's perspective and shows the cost of 

12 owning and operating the lamp over its 

13 lifetime. 

14 As indicated in the diagram, the LCC 

15 considers two components. One is first cost, 

16 which is the product price and installation 

17 costs. The other is the operating cost of the 

18 lamp, which is discounted to the present value.

19 When the standard level lamp 

20 lifetime is different from the baseline lamp 

21 lifetime, DOE also calculates a residual value 

22 for the remaining useful life of the lamp at 
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1 the end of the analysis period and subtracts 

2 this from the total LCC value. From this, DOE 

3 calculates the total life-cycle cost for each 

4 standard level considered.

5 The results are expressed as LCC 

6 savings, which are the baseline LCC value minus 

7 the standard level LCC value. The simple 

8 payback period is also calculated and reported.

9 Now I will discuss some of the key 

10 inputs to the LCC model, such as electricity 

11 prices, installation costs, ballast lifetimes, 

12 and discount rates. DOE calculated average 

13 electricity prices using EIA 861 data. DOE 

14 then applied electricity price trends from AEO 

15 to project future electricity prices. DOE used 

16 the 2011 ballast rule, RS Means, and the U.S. 

17 Bureau of Labor Statistics to calculate 

18 installation costs. DOE calculated ballast 

19 lifetimes in hours, which translated to 

20 approximately 12 years for the commercial 

21 sector, 11 years in the industrial sector, and 

22 15 years in the residential sector. 
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1 DOE uses a discount rate to 

2 calculate the present value of expenses over 

3 the analysis period. For the commercial sector 

4 DOE calculated a discount rate of 5 percent, 

5 for the industrial sector 5.6 percent, and 

6 residential 5.2 percent.

7 MR. BROOKMAN: Steve Rosenstock?

8 MR. ROSENSTOCK: Steve Rosenstock, 

9 EEI. I know we've had these discussions

10 before. Maybe because lighting products are 

11 low-cost products, but it always seems 

12 fascinating to me that I see some of these and 

13 that a residential customer would have a lower 

14 discount rate than an industrial customer. It 

15 just kind of blows my mind sometimes just 

16 because of, you know, with lighting products, 

17 again, people, residential customers can pay 

18 cash, but if they decide to use any form of 

19 credit, any form of credit card, the nominal 

20 interest rate is going to be, typically, 10 

21 percent plus. 

22 And, you know, I see these numbers, 
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1 and, again, maybe that's a weighted average 

2 because of cash versus credit transactions. 

3 But I always find it interesting when I see 

4 things like that where a pretty well 

5 capitalized industrial company will have a 

6 higher discount rate than a residential 

7 customer of varying incomes and different 

8 credit card interest rates. Thank you. 

9 MR. BROOKMAN: Okay, thank you. 

10 MS. PIERCE: Okay. DOE is also 

11 considering a new method for calculating the 

12 average sales tax in the NOPR. DOE currently 

13 weights the sales tax by population but is 

14 considering changing the weighting to be based 

15 on the prevalence of building types within each 

16 sector. This would create a different weighted 

17 average sales tax value for each sector due to 

18 the likelihood of different types of buildings 

19 to be in certain areas of the country.

20 DOE requests comment on this 

21 potential change for the NOPR. 

22 MR. BROOKMAN: Comments on the life-
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1 cycle cost analysis? 

2 MR. ROSENSTOCK: Steven Rosenstock, 

3 EEI. You know, in certain areas of the 

4 country, there's local sales tax, as well. 

5 Like New York City might have a local -- do you 

6 have some of that information, as well, in case 

7 there's like local, I'll say city or county 

8 taxes that go on top of the state sales taxes? 

9 MS. PIERCE: Right now, we just 

10 weight it by state. 

11 MR. ROSENSTOCK: The reason I'm 

12 asking that -- Steve Rosenstock, EEI -- is that 

13 if you're starting to do this and let's say 

14 you're weighting however many commercial 

15 buildings in New York City, they're going to 

16 pay the city tax, as well as the state tax, on 

17 some of these issues. And then there might be 

18 other areas, especially urban areas with 

19 commercial buildings, that have the same 

20 scenario. So I don't mind this process. I 

21 don't mind the thought behind this. But if you 

22 don't have the data on those local conditions, 
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1 then you might be missing some of the data. 

2 MS. PIERCE: If you have data for 

3 that, please submit it as a comment.

4 MR. BROOKMAN: Do you think the 

5 state rate provides some sort of a weighted 

6 average that would incorporate the cities? 

7 MS. PIERCE: I would think so, but 

8 I'm not familiar with how they derive those. 

9 MR. BROOKMAN: That would be my 

10 guess. Charlie? 

11 MR. STEPHENS: Charlie Stephens. 

12 Yes, I'm pretty sure there's some data out 

13 there. It's by county, which would be, you 

14 know, pretty close to what you're looking for. 

15 The other thing is this is where we get back 

16 to your pricing for things in the life-cycle 

17 cost. If you're going to do the typical Monte 

18 Carlo on this thing, I'd like to reiterate the 

19 comments that Andrew and I were emphasizing 

20 this morning about getting a proper weight on 

21 the different low, medium, and high prices that 

22 you found out there, the right market weight, 
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1 because that will impact this life-cycle cost 

2 analysis substantially. And so we still 

3 strongly recommend that you weight these 

4 pricings that you use. And I assume you're 

5 using markups and other such things, or are 

6 you? 

7 MS. PIERCE: We don't actually use -

8 -

9 MR. STEPHENS: You're not using 

10 markups this time because -- yes. But this is 

11 a hazard. I think you really need to do, if 

12 you're not going to use the typical 

13 methodologies, I think you really need to be 

14 very careful about data about who's paying, 

15 what fraction of the market is paying what 

16 price here, because when you go to do this 

17 analysis it's going to make a huge difference 

18 in how the results come out. 

19 MS. PIERCE: Okay. We'll consider 

20 that. 

21 MR. BROOKMAN: Additional comments 

22 on life-cycle cost? 
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1 MS. PIERCE: There are more slides 

2 if --

3 MR. BROOKMAN: Yes. Mike? 

4 MR. MCGARAGHAN: Mike McGaraghan, 

5 California Utilities. You mentioned that when 

6 a replacement lamp has a different remaining or 

7 a different useful life, you calculate a 

8 residual value. Is that identified in the TSD 

9 somewhere in each particular scenario what that 

10 residual value is, or is it folded in to the 

11 LCC chapter in such a way where you can't break 

12 it out? 

13 MS. PIERCE: So the equation is in 

14 Chapter 8. And if you go into the actual LCC 

15 model in Excel, I think you can figure it out 

16 that way. 

17 MR. MCGARAGHAN: Okay. Then one 

18 other question was you mentioned the cost of or 

19 the replacement cycle for ballasts, and I asked 

20 earlier about the cost of the ballasts. And 

21 sort of the follow-up question is does the lamp 

22 rule being proposed here ever have any impact 
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1 on the ballast cost or the ballast lifetime or 

2 the assumed replacement schedule for the 

3 ballast to the consumer in any way? 

4 MS. PIERCE: I'll let my colleagues 

5 answer that one. 

6 MS. MCDONALD: This is Ali McDonald. 

7 I don't believe that any lamp standard ends up 

8 impacting the lifetime of a ballast selected. 

9 Do you have a specific scenario you're 

10 concerned about? 

11 MR. MCGARAGHAN: Just that I 

12 understand that you're plugging in ballast 

13 replacement and ballast cost to your LCC, but I 

14 just want to make sure that those assumptions 

15 are the same in the standards case as the base 

16 case. 

17 MS. MCDONALD: They are.

18 MR. MCGARAGHAN: Okay, thank you. 

19 MS. PIERCE: Okay. DOE uses several 

20 lamp purchasing events in the LCC model. The 

21 first event is lamp failure in which a lamp 

22 fails and must be replaced. The second event, 
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1 ballast failure, is only for GSFLs and includes 

2 situations where the failure of the installed 

3 ballast requires a new lamp and ballast 

4 purchase. The third event is new construction 

5 and renovation where new fixture installations 

6 occur and are not restrained to the previous 

7 configuration.

8 In the residential GSFL analysis, 

9 since the lamp lifetime is longer than the 

10 ballast lifetime for that sector, DOE assumes 

11 in the lamp failure event that GSFL consumers 

12 preserve their lamps when replacing a ballast 

13 and utilize the same lamps on the new ballast. 

14 DOE requests comment on how likely consumers 

15 are to exhibit lamp preserving behavior. 

16 MR. BROOKMAN: Joe? 

17 MR. HOWLEY: I guess I'll make the 

18 comment, or Keith can. But what we've been 

19 told is, often, when a ballast fails, it 

20 operates in a way that tends to chew up the 

21 lamp, and the lamp is not in good condition, as 

22 the ballasts don't typically fail in a nice 
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1 way, because they're trying to start the lamp, 

2 they're trying to do various things with the 

3 lamp, and it results in a lot of starts and a 

4 lot of damage to the cathodes. 

5 Often, the other thing that we 

6 recognize is when a light goes out, for a 

7 homeowner, the most likely thing they assume is 

8 that the light bulb needs to be replaced. They 

9 never assume the ballast has gone. In fact, 

10 most consumers don't even understand what a 

11 ballast is or that it's in that fixture. So 

12 they will go out and buy a new lamp and attempt 

13 to replace that first. Then, finding the new 

14 lamp doesn't light either, they'll go further 

15 to -- and, often, at that time, they simply 

16 just buy a new fixture. There could be a few 

17 enterprising consumers that attempt to buy a 

18 ballast and change their ballast. Especially, 

19 perhaps, if they're in the lighting industry, 

20 maybe they would know enough to do that, or 

21 they're an electrician they would know enough 

22 to do that. But in many cases, consumers will 
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1 simply just then go to buying a new fixture to 

2 use with the new lamps that they've already 

3 bought.

4 So they almost never would encounter 

5 the situation that you're referring to where 

6 they would keep these old lamps and change the 

7 ballast. That's a situation that almost never 

8 occurs. 

9 MS. PIERCE: Okay, thank you. 

10 MR. BROOKMAN: Thank you. Mike?

11 MR. MCGARAGHAN: Mike McGaraghan. 

12 In that comment box it says that in the lamp 

13 failure event --

14 MS. PIERCE: Yes.

15 MR. MCGARAGHAN: -- you would assume 

16 they would preserve their lamps and replace the 

17 ballast. Is that supposed to read in the 

18 ballast failure event?

19 MS. PIERCE: No, it's in the lamp 

20 failure event because, in that case, we were 

21 trying to determine what the LCC would be if 

22 the lamp were able to live for its entire 
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1 lifetime independently of the ballast. So in 

2 the ballast failure event, you would replace 

3 the lamp and ballast. In the lamp failure 

4 event, you would just replace the lamp.

5 MS. MCDONALD: This is Ali McDonald. 

6 We actually did this two different ways to try 

7 to get a range of results. And, you know, one 

8 of the ways is assuming that the lamp lives for 

9 its entire lifetime, even though you may be 

10 replacing the ballast. And so we did it both 

11 ways, and we're just asking for comment on 

12 whether one of these ways is actually a likely 

13 scenario.

14 MR. K. COOK: What I think is 

15 confusing everybody is, if you look at the 

16 bullets up there, event two, the sub-bullet 

17 says the failure of the installed ballast 

18 triggers a lamp and ballast purchase. In other 

19 words, the lamp is also purchased. But then in 

20 the box down below, that's not the case. 

21 That's where the confusion is arising.

22 MS. MCDONALD: Sure. So when the 
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1 ballast fails, there's a new lamp and ballast 

2 purchase. And when just the lamp fails, 

3 there's just a new lamp purchase. That lamp 

4 lives for its entire lifetime, and so we 

5 assume, in that case, that the consumer is just 

6 replacing the ballast because, in the 

7 residential sector, it lives for 37, the lamp 

8 lives for 37 years, and so the ballast has to 

9 be replaced over that course in time. 

10 MS. PIERCE: Right. So it's a 

11 question of, in that first event, do we cut it 

12 off when the ballast fails or when the lamp 

13 fails? 

14 MR. BROOKMAN: People are still 

15 giving me confused looks here. Keith, start us 

16 off. 

17 MR. K. COOK: Well, down there where 

18 it says replacing a ballast and utilize same 

19 lamps on the new ballast. In other words, 

20 you're carrying over the lamps. That's where 

21 we're confused. 

22 MS. deBUTTS: I understand. It 
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1 could have been phrased better, yes. But we 

2 described all the scenarios we're asking 

3 comment on, so, hopefully, you can comment on 

4 the scenarios. 

5 MR. BROOKMAN: Steve? 

6 MR. ROSENSTOCK: Steve Rosenstock, 

7 EEI. Just to make things even more fascinating 

8 and interesting, is just because of the new 

9 lamp and the ballast standards, you know, for a 

10 majority of residential customers, myself 

11 included, is that they still have the T12 lamps 

12 with the magnetic ballasts in their home, so it 

13 makes things even more, you know, they can't 

14 use the T8 lamps with existing ballasts 

15 anywhere. Basically, if a lamp goes out, they 

16 might be forced to do the new fixture anyway, 

17 so it gets -- I'm not trying to add another 

18 complication. It's just, especially in the 

19 early years of your analysis, 10, 15 years,

20 whatever, there's still going to be the T8 

21 older ballast conundrum where the consumer 

22 isn't going to be able to find the replacement. 
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1 So that might steer the consumers towards the 

2 fixture replacement case anyway, regardless of 

3 whether it's just the lamp or the ballast. 

4 MR. BROOKMAN: Charlie? 

5 MR. STEPHENS: Yes, Charlie 

6 Stephens. I'm hoping we're going to have some 

7 data on this when we get into it, but our 

8 sense, initially, is that people, if what they 

9 have is a T12 fixture and the ballast goes out, 

10 what I do is I special order a rapid start 

11 ballast and go to a T8, but most people are not 

12 going to re-ballast. They're going to go buy a 

13 new fixture. But it's likely to be a newer 

14 ballast and probably a T8 lamp if what they're 

15 getting rid of is a T12.

16 When that happens and I still have a 

17 T12 or two or three or four fixtures in the 

18 house, I just set aside the lamp for another 

19 fixture until that ballast goes out. And then 

20 I do the thing again, and, hopefully, I'll run 

21 out of ballasts and lamps at about the same 

22 time. But at least I'm angling for that.
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1 But I think a lot of people are 

2 going to go get a new fixture, and they're 

3 going to be using a newer lamp if what they 

4 started with is a T12. In our survey, about 10 

5 percent of the lamps in the residential sector 

6 were linear fluorescent types. I can't tell 

7 you until the new data comes out next month how 

8 many were T12 and how many were T8s, but I 

9 think there is that segment out there for which 

10 it matters.

11 MR. BROOKMAN: Brian? 

12 DR. GERKE: This is Brian Gerke from 

13 LBNL. Just to respond to those two comments, 

14 the issue of T12s leaving the market is handled 

15 in the NIA. The LCC only considers the 

16 products that meet current standards for the 

17 life-cycle cost analysis, so it folds in later.

18 MR. BROOKMAN: Okay, good. Keith?

19 MR. K. COOK: A question. What are 

20 you assuming for the frequency of renovation? 

21 MS. PIERCE: It's just a matter of 

22 when the lamp and -- well, can I get back to 
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1 you on that? I'm sorry. 

2 DR. GERKE: Frequency of renovation, 

3 we followed the ballast rulemaking so a fixed 

4 percentage of the stock in each year. I 

5 believe it was three percent renovation, which 

6 was the same as the stock modeling in the 

7 ballast rulemaking. 

8 MS. PIERCE: There we go. It was an 

9 NIA question. 

10 MR. BROOKMAN: Thank you, Brian. 

11 Okay. Mike, one more? 

12 MR. MCGARAGHAN: Is renovation 

13 synonymous with lighting retrofit in your 

14 analysis? 

15 MS. PIERCE: Yes. 

16 MR. BROOKMAN: Alex? 

17 MR. BOESENBERG: And Alex 

18 Boesenberg, NEMA. So one more tier on that 

19 series of questions. Does that mean they'll 

20 switch probably to a different technology, like 

21 from T12, T8, T5, et cetera, or you're just 

22 triggering a purchase? 
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1 DR. GERKE: Certainly, if they have 

2 T12s, they would have to switch at this point. 

3 For T8s and T5s, I'll get into that switching 

4 when I actually present. 

5 MS. PIERCE: All right. This table 

6 shows the range of results for four-foot medium 

7 bi-pin lamps on instant start ballasts across 

8 all sectors and lamp replacement systems for 

9 each CSL. For this product class, there are no 

10 lamp replacements in the lamp failure event at 

11 CSL 1 because there are no energy-saving lamps 

12 available at that level. This is indicated by 

13 NR in the table. 

14 LCC results show positive savings, 

15 except for some results in the residential 

16 sector. For all GSFL results, the results are 

17 the same for the ballast failure and new 

18 construction and renovation events since we 

19 assumed no spacing adjustments in the latter 

20 event. This is because the replacement systems 

21 were chosen such that the lumen output was 

22 within ten percent of the baseline system, when 
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1 possible.

2 MR. BROOKMAN: Steve? 

3 MR. ROSENSTOCK: Steve Rosenstock, 

4 EEI. I'm going to refer back to the slide back 

5 on 43 that showed the baseline levels with 

6 different CSLs. And a few thoughts are coming 

7 out at me, is that you're showing no results 

8 for CSL 1, but CSL 1 is a candidate, so I think 

9 you really need to show the LCC savings. 

10 That's part of the analysis. And, yes, 

11 basically, the baseline and CSL 1 lamp have the 

12 same nominal wattage and the same rated 

13 wattage. If there's no savings, there's no 

14 savings. And to say that that's NR, that is 

15 going to be a scenario for these lamps, and it 

16 is a candidate under this preliminary analysis.

17 The other question, the other 

18 thought I had was, under CSL 2, one of the 

19 lamps, again, has the same nominal wattage and 

20 same rated wattage going into that existing 

21 fixture. So, again, there's probably not going 

22 to be, I don't think there's going to be any 
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1 energy savings because you have the same 

2 ballast with that CSL 2 with 95.4 rated 

3 efficacy of 95.4 lumens per watt, but you're 

4 showing positive LCC savings. 

5 I guess I'm extremely concerned 

6 because, number one, it seems like you're 

7 ignoring the analysis of a lamp failure for CSL 

8 1, which is going to be a scenario if it 

9 becomes the standard and, number two, showing 

10 very positive savings for one of the technology 

11 scenarios in CSL 2, which is not going to 

12 provide any energy savings. So can you explain 

13 that? 

14 MS. PIERCE: Sure. So to address 

15 the first comment, we do provide results for 

16 CSL 1 in events two and three. And we consider 

17 all events in the LCC analysis. 

18 MR. ROSENSTOCK: But why aren't you 

19 showing any results -- Steve Rosenstock, EEI. 

20 What about event one, which will happen for 

21 these lamps? 

22 MS. PIERCE: Because there was no 
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1 energy-saving replacement for --

2 MR. ROSENSTOCK: But if that becomes 

3 a standard, it's still going to be an economic 

4 cost to the consumer.

5 MS. MCDONALD: This is Ali McDonald. 

6 Steve, that NR is an acknowledgment that there 

7 aren't positive savings at that level. You 

8 don't have any energy savings. 

9 MR. ROSENSTOCK: But there are costs 

10 to the consumers.

11 MS. MCDONALD: Okay.

12 MR. BOESENBERG: Right. But zero is 

13 a number, not NR.

14 MR. ROSENSTOCK: Or it could be 

15 negative.

16 MS. MCDONALD: Right, it would be 

17 negative. 

18 MR. ROSENSTOCK: So this is Steve 

19 Rosenstock, EEI. That should be shown in here 

20 because it is going to happen because, 

21 otherwise, then it's not counted, otherwise it 

22 might not be counted with event two and three.
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1 DR. GERKE: This is Brian Gerke from 

2 LBNL. Just to allay any further concerns, we 

3 do consider all these possibilities in the NIA. 

4 So in the LCC, there's no energy-saving 

5 alternative, but in the NIA, at that choice 

6 point, you can, if you are a consumer, choose 

7 something that doesn't save you any money. 

8 It's allowed.

9 MR. ROSENSTOCK: That could happen 

10 in this scenario. If that is the standard 

11 chosen by DOE, you'll save in event two and 

12 three but you won't save in event one, but both 

13 will happen in the marketplace. So to only 

14 show the positive savings for event two and 

15 three and then ignoring the negative savings in 

16 event one is not doing a complete analysis. 

17 MR. BROOKMAN: We got it. 

18 MR. ROSENSTOCK: Sorry. Thank you. 

19 MS. PIERCE: Okay. This table shows 

20 the range of results for four-foot medium bi21 pin lamps on programmed start ballasts across 

22 all sectors and lamp replacement systems for 
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1 each CSL. Consumers purchasing higher efficacy 

2 four-foot medium bi-pin lamps for use on 

3 programmed start ballasts would experience 

4 positive LCC savings only for reduced wattage 

5 lamps. 

6 MR. BROOKMAN: Steve? 

7 MR. ROSENSTOCK: Steve Rosenstock, 

8 EEI. Same comment. Thank you. 

9 MR. BROOKMAN: Okay, thank you. 

10 Mike? 

11 MR. MCGARAGHAN: Mike McGaraghan, 

12 California Utilities. There are a number of 

13 scenarios that aren't shown on your slide here 

14 but that are in the TSD when you start looking 

15 at individual replacement scenarios where DOE 

16 has assumed, in the standards case, there's an 

17 increase in installed cost and, yet, the 

18 operating cost is identical. 

19 MS. PIERCE: Correct.

20 MR. MCGARAGHAN: It appears that 

21 it's the same equipment being installed in the 

22 base case as the standards case. I don't see 
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1 how you could end up with a more expensive 

2 replacement scenario, but you're using the 

3 exact same equipment. It's calculated to the 

4 penny the same energy or the same operating 

5 cost.

6 MS. MCDONALD: This is Ali McDonald. 

7 That's a factor of the ballast factors that 

8 are available in program start. For instant 

9 start, there are a wide variety of ballast 

10 factors, and so we selected a ballast factor to 

11 pair with the lamp that would reduce energy use 

12 and have energy savings. For the programmed 

13 start systems, there were a selection of low 

14 ballast factor ballasts, and so we ran into 

15 some instances where they were, the 32-watt 

16 more efficient lamps were paired with the same 

17 ballast factor and so they had the same energy 

18 use. 

19 So, for instant start systems, we 

20 were able to identify lamp and ballast systems 

21 for the 32-watt lamps that saved energy by 

22 choosing a lower ballast factor ballast to pair 
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1 with the lamp. And for programmed start 

2 ballasts, those same low ballast factor options 

3 weren't available. And so what we're showing 

4 there is we're pairing more efficient 32-watt 

5 lamps with the same ballast factor, so we have 

6 the same energy consumption. 

7 MR. MCGARAGHAN: Thank you. 

8 MR. BROOKMAN: Yes, Pekka? 

9 MR. HAKKARAINEN: Pekka Hakkarainen, 

10 Lutron. What are we looking at? Seventy-two, 

11 yes. The bullet point at the top says positive 

12 life-cycle cost savings only for reduced 

13 wattage lamp replacements, so now I'm 

14 concerned, does this analysis take into account 

15 the probable increased use of dimming systems 

16 in the future, especially in new construction 

17 and renovation? And that would have the effect 

18 of not allowing the use of reduced wattage 

19 lamps and, therefore, the life-cycle cost 

20 savings, as shown, would likely be lower here 

21 but greater if you take into account the total 

22 energy use. 
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1 MS. PIERCE: So this table does not 

2 show that, but that is done as a sensitivity in 

3 Appendix 8B.

4 MR. HAKKARAINEN: 8B.

5 MS. PIERCE: Yes. 

6 MS. MCDONALD: I also want to --

7 this is Ali McDonald. I also want to point out 

8 that we're identifying potential levels here 

9 and putting forward results for them, but we're 

10 not proposing anything yet. You know, we'll be 

11 weighing the results, the benefits versus the 

12 burdens at the NOPR stage before we would 

13 propose a level.

14 MS. PIERCE: Okay. This table shows 

15 the range of results for the remaining GSFLs 

16 across all sectors and lamp replacement systems 

17 for each CSL. Consumers purchasing higher 

18 efficacy T5 or eight-foot slimline lamps would 

19 experience positive LCC savings. However, 

20 consumers purchasing eight-foot high-output 

21 lamps would experience negative LCC savings. 

22 MR. BROOKMAN: Mike?
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1 MR. MCGARAGHAN: Mike McGaraghan. 

2 Just a question on the selection of ballast 

3 factors. It looks like you used mostly 0.88 

4 and 0.87 and occasionally dropped to 0.77. 

5 Those are very common ballast factors. 

6 I also notice a bunch of 0.83s. Are 

7 those common in the market? Is that why DOE 

8 chose 0.83? 

9 MS. KIENLE: Yes, those are 

10 commercially available ballasts that are 

11 available in the market place. And if you 

12 notice, too, those are particularly common for 

13 the residential ballasts. 

14 MR. MCGARAGHAN: Okay. So one 

15 comment on that. There were a number of 

16 scenarios where DOE dropped to 0.83 where it 

17 could have dropped to 0.77 and still stayed 

18 within five percent of initial lumens. So I 

19 would recommend, rather than increasing light 

20 to go with the 0.83, in any scenario where you 

21 can stay pretty close with a 0.77, that you do 

22 that. 
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1 I also wondered if DOE had 

2 considered -- I guess this is all lamp for 

3 lamp, so there is no scenario where you assume 

4 a delamp and going to a high ballast factor, 

5 1.0 or 1.15, adding reflectors or any other 

6 kind of optimized retrofit scenario. 

7 MR. BROOKMAN: Brian? 

8 DR. GERKE: We didn't end up 

9 considering that explicitly in the NIA, but we 

10 did try to get a sense of the average ballast 

11 factor out there right now to account for that 

12 sort of decision that is made.

13 MR. MCGARAGHAN: Okay. I'm more 

14 interested in seeing it in the LCC because 

15 there would be scenarios where you could 

16 optimize cost-effectiveness that might not be 

17 displayed here. 

18 MR. BROOKMAN: Steve? 

19 MR. ROSENSTOCK: Steve Rosenstock, 

20 EEI. I guess the issue with that is then now 

21 you're presenting much more, you know, new 

22 materials. Like if you're presenting 
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1 reflectors, that adds another layer to the 

2 analysis that, you know, it may or may not be -

3 - again, as you broaden the analysis, you get 

4 so many more scenarios that it's really -- you 

5 lose what's happening necessarily, possibly, 

6 with what's actually happening with the lamp 

7 efficacy so that you add reflectors or you're 

8 thinking about delamping, that can change your 

9 analysis so much that you go from a three-lamp 

10 ballast to a two-lamp ballast, maybe with 

11 tandem wiring. I mean, you get, you can get, 

12 easily, hundreds of installation scenarios 

13 where you can easily lose what's probably going 

14 to happen, whether it's new construction or 

15 retrofit market in terms of what's the most 

16 likely scenario for this lamp after a standard 

17 is put into place. I mean, obviously, those 

18 options exist, but you throw those in and then 

19 you just get all sorts of things. Well, why 

20 did you do it in the baseline? Some of those 

21 things could be applicable in the baseline, 

22 too. Hey, we can put the reflector or tandem 
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1 wiring with the baseline lamps, too. That 

2 would lower the savings. 

3 MS. MCDONALD: This is Ali McDonald. 

4 We do know that that's a possibility we didn't 

5 consider in this analysis, but we'd welcome any 

6 information you have about how common that is 

7 and what the most typical delamping scenario is 

8 so that we could possibly consider it in the 

9 next phase.

10 MR. BROOKMAN: Charlie? 

11 MR. STEPHENS: Yes, Charlie 

12 Stephens. We might have some data on that. It 

13 is a pretty common scenario. If you include 

14 lighting retrofit as renovation, then this is 

15 one manner that that particular kind of 

16 renovation is done, and it's done fairly often. 

17 So we might be able to get you some data on 

18 that if I scrounge around a little bit.

19 MR. BROOKMAN: Okay, thank you. 

20 Yes, Joe? 

21 MR. HOWLEY: Joe, GE. I would 

22 counter that it was a very typical situation 
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1 when people are moving from T12 to T8 systems. 

2 As this forward-looking analysis is T8 to T8, 

3 I think it would be much less likely that 

4 people are going to move in this direction. 

5 But I agree, in the past, it has been. I just 

6 don't think it's going to be that common going 

7 forward.

8 MR. BROOKMAN: Final comments here? 

9

10 MS. PIERCE: This table shows the 

11 range of LCC savings results for IRLs across 

12 all sectors. Consumers with the 1,500-hour 

13 improved halogen baseline have positive LCC 

14 savings, but consumers with the 3,000-hour 

15 baseline lamp have negative savings. 

16 DOE requests comment on the 

17 likelihood that fixture spacing is adjusted 

18 during new construction and renovation if 

19 systems considered for installation all have 

20 similar lumen outputs. 

21 MR. BROOKMAN: Steve? 

22 MR. ROSENSTOCK: Steve Rosenstock, 
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1 EEI. We talked about this before, and, again, 

2 it's really, I'm not a lighting designer but, 

3 again, it's a matter of if there is so many 

4 foot candles required for the space, they will 

5 put in as many fixtures to meet that and also 

6 meet the, I'll say the ASHRAE lighting power 

7 density requirements in 90.1. And in the 

8 scenarios that you addressed, all of the system 

9 lighting outputs have lower lumens output in 

10 the system. So, therefore, there will be a 

11 need for more fixtures to maintain the same 

12 foot candles. 

13 MR. BROOKMAN: Joe? 

14 MR. HOWLEY: Yes. What's most 

15 likely to happen under the scenario where 

16 you're getting lamps, perhaps, that are newly 

17 available that you weren't expecting, if their 

18 lumen output is different, it's very unlikely 

19 that users would re-space their fixtures. If 

20 you look in this room, you see a standard two21 by-four grid that would be nearly impossible to 

22 re-space to take advantage of, you know, a one 
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1 or two-lumen per watt difference in the lamps.

2 What most likely would happen, if 

3 somebody wanted to take advantage, if they 

4 could, of any energy savings, they, perhaps, 

5 would consider a ballast change, the ballast 

6 factor. But more likely, the ballast would 

7 still be fine, so here we're still going down 

8 to they'll just replace one lamp for another. 

9 The lumen difference isn't that great, so they 

10 wouldn't really, I don't see any scenario where 

11 they'd consider re-spacing an existing 

12 building, which is where the majority of the 

13 products are used. 

14 MS. PIERCE: Thank you. 

15 MR. BROOKMAN: Other comments here? 

16

17 MS. PIERCE: Okay. DOE requests 

18 comment on the methodology and results of the 

19 LCC analysis. 

20 MR. BROOKMAN: Quite a bit of 

21 comments on the methodology so far. Alex? 

22 MR. BOESENBERG: Alex Boesenberg, 
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1 NEMA. I would just add, and we'll put it in 

2 our written comments, to amplify on Mr. 

3 Howley's statement, I hope the DOE and the 

4 analysts will bear in mind that spacing, it's 

5 not tied just to light fixture output, but 

6 we're talking about two-by-four ceiling grids 

7 and everything else. The idea that spacing 

8 will be adjusted -- if you're going to adjust 

9 it, it's got to be at least two feet, and then 

10 you've got to look at whether or not you can 

11 still meet lighting levels due to the changes 

12 in the fixture's performance. The spacing is 

13 where it is. You've hit this balance. There's 

14 a symbiosis between the manufactured ceiling 

15 materials, modular wire strings, and the 

16 fixtures and their performance. So it's all 

17 got to change. 

18 MR. BROOKMAN: Okay. Keith? 

19 MR. K. COOK: Keith Cook from 

20 Philips. The other thing that you need to also 

21 recognize is, in a lot of scenarios, if you're 

22 going to try and adjust spacing, that means 
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1 you're going to have to change the hangers for 

2 the lights, which means you're getting into the 

3 ceiling itself and there's still an awful lot 

4 of buildings with asbestos. They do not want 

5 to go there. 

6 MR. BROOKMAN: Charlie? 

7 MR. STEPHENS: Charlie Stephens. We 

8 must live in another planet or another market 

9 or something where we are because most of this 

10 stuff occurs during tenant improvement, and the 

11 ceiling is the first thing to go, all of it. 

12 And the lighting system is redesigned. It's 

13 brought in because the tenant changed, and the 

14 people who are in the space are no longer the 

15 same people.

16 Also, all the office furniture gets

17 changed out. And sometimes the space is 

18 gutted. All the walls are knocked down, open 

19 floor plan. Lots of things get changed when 

20 the lighting system changes. Most of these 

21 things occur in the office-type occupancy where 

22 the bulk of this stuff goes and a renovation is 
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1 occurring as part of a much larger renovation. 

2 And not just the ceiling goes, everything 

3 goes, including the people, the fixtures that 

4 are on the floor, the places where you're 

5 measuring your foot candles. Everything 

6 changes. And so you're starting all over in a 

7 lot of cases, and so what you're looking at 

8 here is a brand new ballast and a brand new 

9 lamp that will last X number of years when it 

10 comes to renovation. And I doubt there's very 

11 much changed unless, or saved, I should say, 

12 unless you're bringing in T8 lamps and you can 

13 still use the same T8 lamps in a new T8 fixture 

14 with a different ballast.

15 But other than that, I don't see 

16 much preserved when it comes to renovation. 

17 It's pretty much everything. 

18 MR. BROOKMAN: Pekka?

19 MR. HAKKARAINEN: Pekka Hakkarainen, 

20 Lutron. Charlie, in your scenario there, the 

21 end result is, as far as I can judge, is not 

22 going to be any different whether you have an 
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1 89-lumen per watt lamp or a 90-lumen per watt 

2 lamp. You're going to have the same number of 

3 lamps and the same load.

4 MR. STEPHENS: Except that you may 

5 have daylighting that you didn't have and you 

6 may have dimming fixtures and you have a whole 

7 different control system. And you probably 

8 will have a different spacing of fixtures 

9 because there's a different number of people in 

10 a different office configuration living in the 

11 place. So there's going to be, everything is 

12 going to be redesigned, so I guess what I'm 

13 saying is it's like new construction.

14 MR. HAKKARAINEN: Absolutely. And 

15 all of those other things are the result of 

16 those other design and technical changes and 

17 have nothing to do with the lamp standard. 

18 MR. BROOKMAN: Steve? Okay. Keith? 

19

20 MR. K. COOK: The other thing that 

21 you've got to recognize, too, is, even if you 

22 do have daylighting, you still have to be able 
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1 to provide lighting when there is no daylight.

2 MR. BROOKMAN: Okay, or very little. 

3 Have we finished this segment? 

4 MS. PIERCE: I think so. Thank you. 

5 MR. BROOKMAN: Then we're moving on.

6 MS. PIERCE: All right. I'll pass 

7 it on to Brian Gerke for the shipments and NIA 

8 analysis. Thank you. 

9 DR. GERKE: Hi, I'm Brian Gerke from 

10 Lawrence Berkeley National Lab. I'll be 

11 telling you about the shipments and the 

12 National Impacts Analyses for this rulemaking.

13 So in the shipments analysis, DOE 

14 estimates the shipments of GSFLs and IRLs that 

15 will occur during the 30-year analysis period 

16 for this rulemaking, which runs from 2017 to 

17 2046. The NIA then estimates the nationwide 

18 impact of the potential new standards over that 

19 period. 

20 In particular, we compute the 

21 national energy savings, or NES, potential 

22 standards achieved for products shipped during 
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1 the analysis period. A positive NES, in this 

2 case, indicates a positive net savings of 

3 energy. We also compute the net present value, 

4 or NPV, of those savings, less any additional 

5 consumer expenditures that accompany the new 

6 standards. A positive NPV represents a net 

7 savings to U.S. consumers.

8 To summarize the main results of the 

9 NIA, as shown here, the preliminary analysis 

10 for GSFLs projects that both of the candidate 

11 standard levels will lead to a positive total 

12 national energy savings in the range of several 

13 quads of energy savings over the 30-year 

14 analysis period and a positive NPV in the range 

15 of several billion dollars of savings to 

16 consumers.

17 For IRLs, the preliminary analysis 

18 indicates that any candidate standard will have 

19 positive energy savings but, depending on the 

20 discount rate assumed, may have a negative NPV, 

21 implying a net cost to consumers. 

22 MR. BROOKMAN: Steve? 
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1 MR. ROSENSTOCK: Steve Rosenstock, 

2 EEI. For the GSFLs, that also incorporates the 

3 assumption that there is no lamp replacement 

4 for CSL 1? 

5 DR. GERKE: No, all options are 

6 available in the NIA.

7 MR. ROSENSTOCK: But how could you 

8 do it if it already said that there was no 

9 calculation of it or no estimate of the --

10 MS. MCDONALD: This is Ali McDonald. 

11 The LCC was looking at energy-saving 

12 replacements, and the NIA considers situations 

13 where consumers may not save energy. 

14 MR. ROSENSTOCK: Okay, thank you. 

15 DR. GERKE: So the shipments 

16 analysis and the NIA consider the following 

17 candidate standards cases because there is only 

18 one CSL for most of the product classes and two 

19 CSLs for the four-foot medium bi-pins. We have 

20 an all CSL 1 standard case where everything is 

21 held at a CSL 1 standard level and a max CSL 

22 standard in which everything is taken to its 
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1 maximum CSL which, in this case, in practice, 

2 means that you take four-foot medium bi-pins to 

3 CSL 2 and hold everything else at CSL 1.

4 Moving on to the details of the 

5 shipments analysis. It's made up of three 

6 interacting modules. The lighting demand 

7 module estimates the total demand for lighting 

8 service to be filled by new shipments in each 

9 year of the analysis period, so the total 

10 lumens that you need in new lighting shipments. 

11 The consumer choice module estimates the 

12 market shares of the different product classes 

13 and efficacy levels in each year of the 

14 analysis period. And the price learning module 

15 projects future prices of lamps and ballasts. 

16 It interacts very closely with the other two 

17 because the prices impact the consumer choice 

18 model, and the shipments impact the price 

19 trends.

20 And I should point out, at this 

21 point, that in the price learning module, the 

22 price learning is not applied to the portion of 
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1 the GSFL price that comes from rare earth 

2 elements. And I'll talk a little bit more 

3 about how we incorporated the rare earth 

4 elements later.

5 MR. BROOKMAN: Charlie Stephens? 

6 MR. STEPHENS: Charlie Stephens. 

7 Did you, could you or did you or would you 

8 account for technology shifts in your shipments 

9 model for IRLs?

10 DR. GERKE: How do you mean?

11 MR. STEPHENS: Well, for instance, 

12 when the cost curve for LED, you know, for 

13 solid-state lighting and for incandescent IRLs 

14 cross, does your shipment model account for 

15 that possibility?

16 DR. GERKE: Right now -- I'll get to 

17 LEDs in a minute. Right now, they're included 

18 as sort of an external envelope based on other 

19 estimates of the LED because the LED is not 

20 part of the scope of this rulemaking, so we 

21 just used an external estimate of what the LED 

22 shipments will do. But they are allowed to eat
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1 into the demand for IRLs and GSFLs.

2 MR. STEPHENS: Okay. That's what I 

3 was curious about. Thank you. 

4 DR. GERKE: So this is a schematic 

5 diagram showing the elements of the shipments 

6 analysis. It takes inputs from the engineering 

7 analysis, the product price determination, and 

8 the energy use characterization. There is some 

9 summarization of those inputs to make the 

10 modeling more tractable. The three modules I 

11 just discussed are then used in concert to 

12 project the shipments of products over the 2017 

13 to 2046 period.

14 Getting to the answer to the last 

15 question, this shows the projection from a 

16 recent solid-state lighting report from DOE of 

17 the lumen capacity that will be needed or that 

18 is expected to be fulfilled by LEDs. So the 

19 overall curve here shows the total projected 

20 lumen capacity that will be needed for 

21 applications that are currently fulfilled by 

22 GSFLs and IRLs based on projected growth in 
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1 commercial and residential floor space. 

2 And the blue region is the portion 

3 of that demand that's projected to be fulfilled 

4 by LEDs in each year of the modeling period. 

5 In this preliminary analysis, as I said, we 

6 treat that as an exogenous envelope on the 

7 total shipments of GSFLs and IRLs. 

8 We then considered the remaining 

9 demand, which is the two green wedges there, to 

10 determine the total new shipments that were 

11 necessary to fill demand for GSFLs and IRLs.

12 MR. K. COOK: Why do you show a 

13 continuation of GSFLs and IRLs? Why wouldn't 

14 the LEDs eventually take over the entire 

15 market? 

16 DR. GERKE: The projection from the 

17 recent solid-state lighting report is they get 

18 up to something like 70 to 80 percent of the 

19 market shares, so we use that as the envelope. 

20 I can't speak to the details of that.

21 MR. K. COOK: You can't forecast 

22 without that part of it, do you think? 
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1 MR. BROOKMAN: That was Keith.

2 DR. GERKE: Yes, so we had to fit a 

3 curve to that, a market adoption curve, but it 

4 does seem, from the trends that were in that 

5 forecast, that it's maxing at about 80 percent. 

6 We can certainly --

7 MR. K. COOK: Without the 2030 in 

8 their forecast.

9 DR. GERKE: Yes, it's true. It only 

10 goes out to 2030 in the forecast, as you 

11 mentioned. It is flattening out by that 

12 period, though, and so we fitted a logistic 

13 curve. 

14 MR. K. COOK: So it's not their 

15 assumption, it's your assumption as to why it 

16 continues. And I guess I'm trying to 

17 understand that. 

18 DR. GERKE: Right. So we fitted a 

19 logistic curve to it, which is a standard curve 

20 for adoption of new technologies in the market. 

21 And the best fit that we had to the best 

22 forecast that we had showed it flattening it 
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1 off at 80 percent. We don't really have, we're 

2 not in a position to do a better forecast than 

3 that. 

4 MR. BROOKMAN: Steve? 

5 MR. ROSENSTOCK: Steve Rosenstock, 

6 EEI. Again, I'm going to ask questions about 

7 the graph. I didn't look for the numbers in 

8 the technical support document. Again, I'm 

9 looking at this -- so, basically, again, if I'm 

10 looking at this graph correctly, I'll take the 

11 two technologies separately, for IRLs, it 

12 basically, if I'm reading this correctly, it 

13 appears that, I'll say by 2031 the LEDs have 

14 pretty much displaced the IRLs. Is that --

15 DR. GERKE: The overwhelming 

16 majority. There's a little bit still hanging 

17 around in --

18 MR. ROSENSTOCK: For both new and, 

19 that's new and existing construction, correct? 

20 New buildings and --

21 DR. GERKE: Yes. 

22 MR. ROSENSTOCK: -- existing? And 
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1 then for the, again, same question for the 

2 fluorescent lamps, and I'll say it by 2031. 

3 I'll say 15 years in the future after a 

4 standard or NOPR that the LEDs have replaced 

5 almost like two-thirds of the fluorescent lamp 

6 fixtures in new and existing construction?

7 DR. GERKE: It's a bit more than 70 

8 percent.

9 MR. ROSENSTOCK: Seventy percent.

10 DR. GERKE: So this is a fraction of 

11 the shipments in each year.

12 MR. ROSENSTOCK: Right. But the 

13 shipments go to new and existing buildings?

14 DR. GERKE: Yes, right. But it's 

15 not necessarily, this is not necessarily a 

16 fraction of the total stock of fixtures that 

17 are installed.

18 MR. ROSENSTOCK: Okay.

19 DR. GERKE: Things get installed, 

20 and they stay around for a long time. This is 

21 the fraction of the shipments in each year.

22 MR. ROSENSTOCK: So you're saying 
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1 that people will replace the GSFL shipments 

2 with the LED shipments?

3 DR. GERKE: Yes.

4 MR. ROSENSTOCK: Okay. For --

5 DR. GERKE: That's the projection --

6 MR. ROSENSTOCK: -- both existing 

7 and -- okay. Again, I'm just trying to, you 

8 know, because this graph is saying, you know, 

9 quite a few things. So in all the analyses, so 

10 in, I'll say the life-cycle cost analysis and 

11 the National Impact Analysis and the NPVs, 

12 then, basically, the savings are basically zero 

13 for IRLs by 2031? 

14 DR. GERKE: It's not quote zero, but 

15 it's quite low.

16 MR. ROSENSTOCK: The graph shows 

17 zero IRLs, if I'm reading it correctly. 

18 DR. GERKE: This graph? It's very 

19 small. It's very small compared to GSFLs, so 

20 you can't really see it. But there's still 

21 something there. It's not zero.

22 MR. ROSENSTOCK: Okay.
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1 DR. GERKE: Yes, that wedge doesn't 

2 go to zero.

3 MR. ROSENSTOCK: But do the other 

4 impacts assume that the standard will, any 

5 impact of the standard is reduced by, I'll say 

6 90 percent by 2031? 

7 DR. GERKE: In the main analysis, 

8 that's true. I'll get into this in more detail 

9 later on. We do consider a scenario in which 

10 there's no LED growth to see how that large 

11 that impact is. 

12 MR. ROSENSTOCK: Okay. And then, 

13 again, the same question for the fluorescent. 

14 You're assuming that, basically, whatever the 

15 standard is going to be, that 70 percent of the 

16 savings are pretty much, I'll say disappear 

17 because the LED incursion by 2031.

18 DR. GERKE: We believe that's the 

19 best estimate of future trends.

20 MR. ROSENSTOCK: Okay. Again, I'm 

21 trying to get a sense for my comments. Thank 

22 you very much.
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1 MR. BROOKMAN: Charlie Stephens?

2 MR. STEPHENS: Charlie. I just, 

3 mathematically, I would remind people that, at 

4 a seven-percent discount rate especially, 

5 anything after year 20 is nearly meaningless 

6 anyway. So it doesn't have much of a dollar 

7 impact on any of the NPV. Nothing does at a 

8 seven-percent discount rate after year 20.

9 MR. BROOKMAN: Okay, thank you. Did 

10 you wish to comment now? Okay. So yes, Mike? 

11 MR. MCGARAGHAN: Just real quickly, 

12 what is the name of this report that this came 

13 from and do you know if there's numbers behind 

14 it? Apart from this graph, can you see the 

15 detail? 

16 DR. GERKE: Yes, it's DOE's solid17 state lighting report. I'm not sure what the 

18 actual title of it was. It was, I think, the 

19 most recent SSL report or, perhaps, two years 

20 ago. Karina, do you know exactly which one? 

21 DR. GARBESI: It's cited in the TSD 

22 in Chapters 9 and 10, so you'll find it. It's 
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1 prominent. 

2 MR. MCGARAGHAN: Thank you. 

3 MR. BROOKMAN: Okay. 

4 DR. GERKE: So with the demand for 

5 GSFLs and IRLs determined in each year, we then 

6 used this consumer choice model to project the 

7 market shares of the different product classes 

8 and efficacy levels and apportion those 

9 shipments among the different options. 

10 We use an econometric logit model to 

11 compute the probability that a consumer will 

12 select a particular product based on its price 

13 and its operating and maintenance costs. The 

14 O&M costs in this case include both the energy 

15 costs and, in the case of IRL, the cost of 

16 purchasing additional lamps for shorter17 lifetime products.

18 In the case of relatively new 

19 technologies -- so the logit model is shown on 

20 the right of, on your left. In the case of 

21 relatively new technologies, like T5s and the 

22 more advanced IRLs, we also incorporate a Bass 
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1 adoption curve which is a standard model for 

2 consumer adoption of new and unfamiliar 

3 technologies. This is just to ensure that 

4 these new technologies aren't forecast to reach 

5 higher market shares than is actually 

6 realistic, given typical consumer behavior in 

7 adopting new technologies.

8 Oh, importantly, although it's not 

9 shown in this diagram, we also include some 

10 factors that limit the maximum market share 

11 that certain options can attain, such as low12 wattage lamps, which we understand have limited 

13 utility in certain applications. So there's 

14 what's called an acceptance factor that sort of 

15 puts a cap on the total market share that some 

16 of these technologies can achieve.

17 There's also this price learning 

18 module. The plot shows the inflation-adjusted 

19 price of GSFLs, historic GSFLs, historically, 

20 as a function of cumulative production. So 

21 cumulative shipments on the horizontal axis, 

22 value per unit on the vertical axis. This is 
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1 from the Census Bureau.

2 In the shipments analysis, we fit a 

3 smooth power law curve to this data. That's 

4 called, by economists, either a learning curve 

5 or an experience curve. And we use that to 

6 project the future price declines that we 

7 expect to occur as shipments, cumulative 

8 shipment production continues to rise. As I 

9 mentioned earlier, that sets aside the question 

10 of the rare earth elements, which we consider 

11 later on.

12 MR. BROOKMAN: Steve Rosenstock?

13 MR. ROSENSTOCK: Steve Rosenstock, 

14 EEI. I've made comments in this area before. 

15 Are you assuming that GSFL, after its new 

16 standard, will be on the left side of the curve 

17 or the right side of that curve? 

18 DR. GERKE: It will continue to 

19 decline as --

20 MR. ROSENSTOCK: No, your starting 

21 point, though. Are you assuming that it's the 

22 left side of the curve or the right side of the 
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1 curve for your analysis?

2 DR. GERKE: Your right.

3 MR. ROSENSTOCK: The right side?

4 DR. GERKE: Yes.

5 MR. ROSENSTOCK: Okay. The reason I 

6 mention that is because I've seen other 

7 documents from DOE that, even with mature 

8 products, that the price declines keep going on 

9 forever, that they never reach a minimum cost, 

10 which is totally not true, especially in the 

11 case of fluorescent lamps. 

12 And a thing I really worry about is, 

13 you know, your GSFL is a separate analysis. 

14 Why isn't it incorporated into the lack of a 

15 learning curve? In other words, the price is 

16 going up, even though GSFLs have been around 

17 for 70 years. I think that, I think there's a 

18 presumption that the cost of manufacturing and 

19 the cost to the consumer always go down. Well, 

20 that's just not true, especially for this 

21 product when the price has been going up, 

22 especially if a regulation forces rare earth 
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1 materials which dramatically increase the 

2 price. 

3 So, again, this is just, I think 

4 there's some issues here where there's always a 

5 presumption that cost will always go down, and 

6 that's just not true, especially in this case. 

7 MR. BROOKMAN: Okay. Joe? 

8 MR. HOWLEY: My comments are in a 

9 similar vein in that the rare earth analysis 

10 should not be set aside and done later. The 

11 rare earth analysis should be part and parcel 

12 and key to this because, as we're learning more 

13 about critical materials, when a material goes 

14 critical, in other words there's a supply and 

15 demand imbalance, it tends to stay critical for 

16 a long period of time, which means that we're 

17 not done with the rare earth issue, certainly 

18 not over this analysis period. And you should 

19 assume continued price spikes throughout this 

20 analysis period where the cost will potentially 

21 go higher and higher, not lower and lower. So 

22 this is exactly the wrong analysis.
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1 MR. BROOKMAN: Thank you. Keith?

2 MR. K. COOK: Yes, I was going to 

3 say the same thing. But the other factor is 

4 the fact that this also is assuming business as 

5 usual and, in reality, with the new 

6 technologies, like LEDs, coming onboard, we're 

7 no longer focusing on price and cost reduction 

8 of these activities. Those resources are 

9 devoted now towards reducing the cost of LED 

10 products, and so it's no longer business as 

11 usual. So price declines will not be 

12 happening. 

13 MR. BROOKMAN: Okay, thanks. Joe? 

14 MR. HOWLEY: Yes. One other comment 

15 is that the projection is for the volumes of 

16 these products to go down as they're supplanted 

17 by LED technology, which means that we're not 

18 going into an increasing cumulative shipment 

19 pattern, we're actually going into a regressive

20 pattern, which will also further increase 

21 prices as volumes go down and economies of 

22 scale are lost in this product line.
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1 MR. BROOKMAN: Okay. Charlie? 

2 MR. STEPHENS: Charlie Stephens. I 

3 mean, personally, I'm not overly concerned 

4 about it since, as I see that curve, for GSFLs 

5 anyway, it's nearly flat as it is. I mean, 

6 it's so flat as to figure it will be horizontal 

7 by the time you hit 14 billion or so shipments. 

8

9 So I think your assumptions are not 

10 terribly -- rare earth excepted. But, there, 

11 volatility, I think, is a word, but there's 

12 also disruptive things that can happen in that 

13 market where a manufacturing plant is uprooted 

14 and moved to where the rare earth materials are 

15 and the problem changes a little bit. It may 

16 not go away, but it changes. That's already 

17 been done for a number of manufacturers.

18 So I think, based on what I see 

19 here, something nearly flat for GSFLs is 

20 appropriate, which is where you are at this 

21 point as you project out. So I'm comfortable 

22 with that for now. 
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1 MR. BROOKMAN: Keith and then to 

2 Karina.

3 MR. K. COOK: Yes, we'd like to 

4 recommend maybe that DOE talk to Dr. Alexander 

5 King at the Critical Materials Institute at the 

6 Ames Laboratory, Ames, Iowa. He's got all 

7 sorts of excellent data that shows what happens 

8 with these critical materials historically, if 

9 you want to use historical information. And 

10 that even if you see prices coming down, don't 

11 trust it. It's not going to stay that way. 

12 MR. BROOKMAN: Thank you. Karina? 

13 DR. GARBESI: I just wanted to say -

14 - it's Karina Garbesi from LBL -- that the 

15 model does account for volume changes in 

16 shipments as it goes forward. So it doesn't 

17 just track forward as a trend on time. It 

18 actually accounts for greatly reduced shipments 

19 volume. So if it's flat there, it gets a lot 

20 flatter as a result of LED penetration in the 

21 market. 

22 DR. GERKE: Yes, that's true. I 
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1 also just want to clarify that this is only 

2 applied to the portion of the price that does 

3 not come from rare earth elements, and those 

4 are treated as a separate component of the 

5 price to account for exactly what you're 

6 talking about.

7 If anyone has any data apart from 

8 what was just mentioned in support of some of 

9 the comments you just made, we'd be very happy 

10 to look at it.

11 MR. BROOKMAN: Okay. 

12 DR. GERKE: Okay. Moving on to how 

13 the model actually works for shipments. In the 

14 product turnover portion of the shipments 

15 model, we consider various possibilities for 

16 product substitution. Essentially, we allow 

17 consumers to switch between product classes and 

18 lamp options at appropriate decision points in 

19 the model.

20 For the IRLs, the consumers may 

21 choose any of the available lamp options each 

22 time they replace a lamp because it's just 
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1 screwing it into the same fixture they already 

2 have. For GSFLs, consumers may only choose to 

3 switch to a new product class or subclass when 

4 they're doing a renovation or in the case of 

5 new construction, which isn't really switching, 

6 I suppose, but then the decision is triggered 

7 since product switching actually requires 

8 replacing the entire lamp and ballast system in 

9 that case.

10 We also assumed that the choice is 

11 constrained by the particular lighting 

12 application. So, for example, if you have a 

13 four-foot medium bi-pin T8 system, you're not 

14 going to go to a T5 high-output system and so 

15 on. It's application-specific.

16 The allowed product substitution, as 

17 shown here, include T12s as starting points 

18 because many people have them in the stock 

19 today. But you can't switch to T12s, you can 

20 only switch from T12s in the model.

21 So we have two questions, two issues 

22 for comment here. DOE believes that the 
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1 overall fluorescent lamp market will 

2 increasingly shift away from T12 products and 

3 toward other products. We request comment on 

4 the future availability of standards-compliant 

5 T12 lamps to be used for replacement. In this 

6 analysis, we assumed that there were such lamps 

7 available, as long as there were ballasts 

8 available to be lamped by them.

9 For IRLs, also, we noticed limited 

10 product offerings for modified spectrum lamps 

11 and small lamps and lamps with voltages greater 

12 than 130. Some of these have been covered, but 

13 this is the request for comment on all those.

14 MR. BROOKMAN: Joe? 

15 MR. HOWLEY: Yes, Joe from GE 

16 Lighting. We, as you mentioned, we did comment 

17 before that the reason there's limited, there 

18 are limited offerings for modified spectrum due 

19 to the difficulty in meeting the current 

20 levels. There's also limited offerings in 

21 PAR20 again and the difficulty in meeting those 

22 levels. And there are literally no products 
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1 that we're aware of that are 130-volt lamps 

2 anymore, given the near impossibility of 

3 meeting those standards and still creating a 

4 practical lamp. We would suggest that no 

5 changes at all would be needed to any of those 

6 product classes, as they've either nearly wiped 

7 out or wiped out the technology as we know it 

8 today. 

9 Your comment about T5s in the 

10 residential market is correct. They're of very 

11 limited use in the products we're talking 

12 about, the four-foot T5 lamps or the nearly 

13 four-foot T5 lamps, and unlikely to be a large 

14 use of these products in homes in the future.

15 MR. BROOKMAN: Okay, thank you. 

16 Charlie? 

17 MR. STEPHENS: Charlie Stephens. 

18 I'd support your issue 28 assumption, as well. 

19 From what we can tell, LEDs will probably take 

20 over a lot of that market before the T5s ever 

21 really get very far.

22 MR. BROOKMAN: Residential or 
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1 commercial? Commercial sector only, it says.

2 MR. STEPHENS: Commercial only, yes.

3 MR. BROOKMAN: Okay, got you. Other 

4 comments on these two issue boxes? Okay.

5 DR. GERKE: So this is a schematic 

6 diagram showing the operation of the turnover 

7 portion of the shipments model and the consumer 

8 choice model. So this shows the turnover model 

9 for IRLs and for fluorescent ballasts, and then

10 we consider installing fluorescent lamps on 

11 those fluorescent ballasts in the next step 

12 that I'll discuss in a moment.

13 So in each year in the model, for 

14 each of the product options we consider, some 

15 fraction of the installed stock fails or is 

16 removed for renovation. This amount of 

17 lighting demand is input to the consumer choice 

18 model, along with lighting demand for new 

19 construction and lighting demand from failures 

20 and renovations within the available substitute 

21 product options. The module then apportions 

22 this demand among the available product options 
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1 that are substitutes for the incoming products. 

2 In the case of fluorescent ballasts, we do 

3 assume that failed ballasts are replaced in 

4 kind with the ballasts of the same type and 

5 only allow product switching in the case of 

6 renovation.

7 MR. BROOKMAN: Steve Rosenstock? 

8 MR. ROSENSTOCK: Steve Rosenstock, 

9 EEI. I appreciate this diagram, and I think it 

10 does a nice job. But I think, in terms of the 

11 ballast turnover, I don't know if there's a way 

12 to do it in the model but I think you might 

13 want to break out the commercial from the 

14 residential, especially for the next X years, 

15 I'll say the next 10 or 15 years, because of 

16 existing residential fixtures. I think it's 

17 probably a better assumption to assume that a 

18 failed ballast in a residential home will be 

19 replaced with a different ballast type, I'll 

20 just say magnetic to electronic as the best way 

21 to say it, for X years after the standard takes 

22 effect because that's what's going to happen, 
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1 that's the choice that consumers are going to 

2 have to make just because of existing 

3 technologies.

4 DR. GERKE: Thanks. Just to clarify, 

5 we do consider those separately, and we'll 

6 definitely take that into account. 

7 So once we have figured out how many 

8 shipments we have, in the next year, with the 

9 consumer choice model, that's when some 

10 fraction of that demand is siphoned off and 

11 apportioned to LEDs, and that's how our 

12 exogenous LED envelope is implemented in the 

13 model. The remaining demand after that 

14 determines the number of new shipments for the 

15 product options under consideration. In 

16 particular, this allows us to determine the 

17 fraction of consumers who are going to switch 

18 from one product class to another product class 

19 in the base case and in the standards cases of 

20 the model, say from T8s to T5s, naturally, for 

21 purely economic conditions.

22 So that determines the shipments of 
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1 IRLs and the shipments of fluorescent ballasts. 

2 To determine the shipments of fluorescent 

3 lamps, we developed a relamping probability 

4 distribution shown here that gives you the 

5 likelihood that a ballast will need to have a 

6 new lamp installed as a function of the 

7 ballast's age. We assume that all the new 

8 ballasts are installed with new lamps in this 

9 case, so the relamping probability is equal to 

10 one at age zero. And then the rest of the 

11 distribution is determined by the typical lamp 

12 lifetime in hours and by the usage patterns in 

13 the population, which translates into a typical 

14 lamp lifetime in years, so there's some 

15 fluctuation here with the peaks corresponding 

16 to the sort of typical lamp lifetime in years.

17 Then to determine the ages of the 

18 shipments of the GSFLs, we tracked the ages of 

19 the ballasts in the stock and we applied this 

20 probability distribution to determine the 

21 number of ballasts that need to have new lamps 

22 installed in each year of the model. 
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1 MR. BROOKMAN: Steve? 

2 MR. ROSENSTOCK: Steve Rosenstock, 

3 EEI. So just looking at some of these, I'm 

4 just surprised that they look relatively flat, 

5 especially after year 15. I thought there 

6 would be kind of a general decline in all of 

7 those just because of the, you know -- again, I 

8 don't know what the distribution curve is, but 

9 for some of these technologies it kind of looks 

10 like the probability is about the same in year 

11 17 as year 35 --

12 DR. GERKE: This is the probability 

13 assuming -- this is the conditional probability 

14 assuming that the ballast survives that long. 

15 So you'd multiply this by the probability that 

16 the ballast fails over that period, so if the 

17 ballast lived forever it would get relamped, 

18 and it smooths out over time because you're 

19 just repeating the same curve over and over 

20 again. 

21 MR. BROOKMAN: Joe? 

22 MR. HOWLEY: Just to mention, this 
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1 is a typical spot relamping curve for lighting 

2 systems. They all look like this. 

3 MR. BROOKMAN: Okay. Thanks, Joe. 

4 Okay. 

5 DR. GERKE: Okay. Once we've 

6 determined the shipments of GSFLs, we then 

7 input that back into the consumer choice model 

8 to allocate them among the different candidate 

9 standard levels or the technology options 

10 determined in the upstream analyses. And so 

11 you can see in this table, for example, a 

12 slight shift in market shares between the first 

13 year of the analysis period in 2017 and the end 

14 of the analysis period in 2046, for the base 

15 case. That represents the fraction of consumers 

16 who would make that switch for purely economic 

17 reasons over that period in the absence of a 

18 standard.

19 These charts show the results of the 

20 shipments model, the shipments analysis for the 

21 base case and the two candidate standards 

22 cases. You can see that, for most product 
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1 classes, the shipments are declining, and this 

2 is because of the incursion of LEDs into the 

3 market, except for the T5 standard output, 

4 which continue to grow as some consumers shift 

5 away from T8s toward T5s for people who 

6 continue to have fluorescent lighting.

7 MR. BROOKMAN: Pekka? 

8 MR. HAKKARAINEN: So looking at 

9 these graphs, based on the data that you're 

10 showing here, the only rule that would possibly 

11 make sense is the T5 standard output. All the 

12 other ones the proposed rulemaking has no 

13 effect, including the IRL, which accelerates 

14 only slightly if we go to CSL 1. I see no 

15 point in this whole exercise.

16 MR. BROOKMAN: Thank you. 

17 DR. GERKE: I also want to point out 

18 in this case that, for the IRL shipments, 

19 there's a sharp decline in shipments in the 

20 early years of the rule. That's simply 

21 because, as has been mentioned earlier, the CSL 

22 1 lamp has a much longer lifetime than the 
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1 baseline lamps, and so there's a sudden drop in 

2 shipments as the turnover slows dramatically.

3 MR. BROOKMAN: Steve Rosenstock?

4 MR. ROSENSTOCK: Steve Rosenstock, 

5 EEI. For the eight-foot lamps in the bottom 

6 left quadrant there, you're assuming that -- is 

7 that the LED effect as well, that that's 

8 eliminating those products from the 

9 marketplace? 

10 DR. GERKE: At the moment, yes, I 

11 would consider the LED envelope to impact all 

12 the different product classes equally. If 

13 people have indications of how that should be 

14 divided up differently, we'd be happy to see 

15 them. 

16 MR. ROSENSTOCK: Steve Rosenstock, 

17 EEI. Again, I appreciate that. It just, you 

18 know, I'm just thinking about, I guess, all the 

19 existing buildings, especially where I've seen 

20 high output. I've seen a lot of those in, 

21 like, warehouses and high bay areas, and, 

22 again, please forgive me -- if the LEDs have 
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1 the same, I'll say light punch to serve those 

2 high bay areas, if they are, great. But I'm 

3 not necessarily familiar with them. 

4 DR. GERKE: If anyone has any data 

5 on that, I'd be happy to see it. Right now, we 

6 assume that it's equal across all product 

7 categories because we don't have better data 

8 than that. We'd be happy to see it.

9 MR. BROOKMAN: Joe? 

10 MR. HOWLEY: Joe Howley with GE. I 

11 don't have a comment on that, in particular, 

12 Steve, but, in looking at these curves, though, 

13 I notice you do project quads of energy 

14 savings, but it appears that most of your 

15 energy savings for this rule going forward are 

16 based on the fact that all of the shipments of 

17 these products are declining. Therefore, 

18 there's fewer of them. Therefore, they use 

19 less energy. Therefore, there's quad savings. 

20 But it doesn't appear, as Pekka mentioned, 

21 that there's much difference between doing a 

22 rulemaking and not doing a rulemaking because 
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1 if you did not do a rulemaking or did not move 

2 it forward you'd have, essentially, the same 

3 energy savings as the LEDs replace many of 

4 these technologies. 

5 So are you going to show or are you 

6 showing the difference in savings between just 

7 letting the market do what it's going to do 

8 anyway and passing a rule, as opposed to saying 

9 the rule is going to produce all these savings? 

10 DR. GERKE: The LED incursion is the 

11 same in the base case and the standards case in 

12 this analysis, so all the savings is relative 

13 to that baseline of LEDs coming into the 

14 market. 

15 MR. HOWLEY: Okay. So the other 

16 thing that I would ask as you're doing this 

17 analysis is that: assume a case where with CSL 

18 2 on fluorescent, there's no control or dimming 

19 savings possible because the standard has gone 

20 so far as to not allow lamps to be dimmed. CSL 

21 1, though, you may increase the savings in that 

22 scenario because of all the building codes, 
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1 requiring more and more dimming and controls to 

2 be used. 

3 It just seems your outcome, as I 

4 looked at the numbers in the beginning of this 

5 section, they seem to have a completely 

6 different analysis outcome than I would expect. 

7 I would expect that you'd probably get more 

8 savings from CSL 1 and then a negative savings 

9 for CSL 2 as you're eliminating the ability to 

10 control and dim these products going forward. 

11 You should at least do analysis assuming that 

12 you can't control or dim these products at this 

13 level and see what it does to your energy 

14 savings analysis. 

15 DR. GERKE: Thank you very much for 

16 that comment. That's very helpful.

17 MR. BROOKMAN: Keith?

18 MR. K. COOK: To address Steve's 

19 very insightful question, yes, I don't know of 

20 any products today that are for high bay 

21 applications with LEDs. But I see no reason 

22 why they can't be, and the reason I'm saying 
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1 that is if I look at outdoor lighting it's at 

2 the same height as the indoor applications. 

3 And so maybe we're not there yet, but there's 

4 no reason why, technically, it can't be done.

5 MR. BROOKMAN: Okay, thank you. 

6 Yes, Mike? 

7 MR. MCGARAGHAN: Mike McGaraghan, 

8 California Utilities. So Joe just asked about 

9 the national savings or I think he was asking 

10 about these graphs specifically, which show, in 

11 the standards case, fewer shipments of covered 

12 products. And your response was that your 

13 analysis currently doesn't, so I guess I want 

14 clarification for what you mean. The national 

15 savings values that you're going to show us in 

16 a moment, is that what you mean are not based 

17 on these slides? 

18 DR. GERKE: They are based -- so, in 

19 many cases, the standards case overlays the 

20 base case here, but this shows the base case on 

21 all of the standards cases. You can see it 

22 most easily on the T5 standard output where 
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1 there's a blue curve, which is the base case, 

2 and then the red and the green curve are the 

3 standards cases. For the four-foot medium bi4 pin, you can just barely see the blue curve up 

5 at the top and the red and the green curves are 

6 about the same. But all of these cases assume 

7 that LEDs come into the market, and the savings 

8 is the difference between the standards case 

9 and the base case. The base case is already 

10 accounting for all the LED incursion, and 

11 there's not more of it in the standards case in 

12 this particular model. 

13 MR. MCGARAGHAN: Okay. So I think 

14 the easiest one to see is the bottom right 

15 because you've got just two colors, and they're 

16 going down, and you see CSL 1 around 2020 

17 starts to plummet in the standards case, where 

18 it stays high in the base case, stays higher.

19 DR. GERKE: Right. In this case, 

20 that effect occurs because the IRL CSL 1 option 

21 has a very long lifetime relative to the 

22 baseline options. And so when you set the 
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1 standard, the turnover slows really 

2 dramatically by a factor of two or three. And 

3 so you get a sudden plummeting in shipments 

4 because of that. But the overall decline in 

5 IRLs, that envelope there is the LED envelope.

6 MR. MCGARAGHAN: Thank you. 

7 DR. GERKE: All right. So that 

8 completes the discussion of the shipments 

9 analysis. I'll move on to the, maybe I'll move 

10 on to the NIA. We seem to be frozen. There we 

11 go. So the NIA computes the national energy 

12 savings and the net present value of the rule. 

13 It starts with inputs from the shipments 

14 analysis and from the LCC and calculates the 

15 NES and the NPV for all the products shipped 

16 during the analysis period. This includes the 

17 energy savings realized for products shipped at 

18 the end of the analysis period. And because 

19 some of those products are residential GSFLs, 

20 we actually have to go out to about 2080 to 

21 capture all of those savings. But that's just 

22 the energy savings. We just considered the 
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1 energy savings from things shipped in 2046. 

2 There are some really long-lived fluorescents 

3 in the residential sector, right? 

4 So the national energy savings is 

5 calculated using the following equation. We 

6 take the difference between the annual energy 

7 consumption in the base case and the annual 

8 energy consumption in the standards case, and 

9 we then multiply that by a factor to account 

10 for the rebound effect, that is people using 

11 more of the lighting service in the presence of 

12 more efficient products, and also a full fuel 

13 cycle multiplier that accounts for the energy 

14 savings that are realized from energy resources 

15 that don't need to be extracted from the ground 

16 and transported to the power plant and burned.

17 The net present value is the 

18 difference between the present value of savings 

19 achieved under the standard minus the present 

20 value of the added cost the standard imposes. 

21 And as a standard in these analyses, we compute 

22 those NPVs with a three-percent discount rate 
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1 and a seven-percent discount rate, and I'll 

2 present results for both.

3 So here's the national impact 

4 analysis results for the IRLs in our reference 

5 case. And when I say reference case, I mean 

6 our sort of best estimate case. I'll discuss a 

7 little bit later some analyses of the impact of 

8 some of the assumptions that we made in this 

9 analysis. 

10 Because the shipments of IRLs are 

11 declining due to the LEDs, most of the energy 

12 savings occurs in the early years of the 

13 analysis period, but it is positive. The NPV, 

14 however, is significantly negative in the early 

15 years and then rises over time. This is 

16 because consumers pay high up-front costs for 

17 more efficient products, which then repay over 

18 time.

19 In the particular case of IRLs, the 

20 savings in the future don't necessarily offset 

21 the added expenditures, depending on the 

22 discount rate we assume. At three percent, 
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1 it's barely positive. At seven percent, it's 

2 significantly negative. And before we get to 

3 comments, I also want to point out that on the 

4 printed version there's a typo on this slide. 

5 The NPV at three percent is $0.04 billion, 

6 which is correct here, rather than $0.4 

7 billion.

8 MR. BROOKMAN: Steve? 

9 MR. ROSENSTOCK: Steve Rosenstock, 

10 EEI. You're showing the NPV over a 60-year 

11 period, and I know with other appliances it's 

12 basically been two lifetimes. Let's say a 

13 residential air conditioner, it's been 30 

14 years. IRLs, since they have a life of about 

15 1,500 hours and two lifetimes would be 3,000 

16 hours, how are you doing a 60-year analysis 

17 period for the net present value? 

18 DR. GERKE: As you can see, it's 

19 basically flat. We should have probably cut 

20 this off. But as I said, we're going out to 

21 2080 in all of our analyses to capture the 

22 energy savings from GSFLs shipped at the end of 
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1 the analysis period, which was 2046.

2 MR. ROSENSTOCK: But I was talking 

3 about IRLs.

4 DR. GERKE: That's right. And as 

5 you can see, it's flat after 2046 because all 

6 the IRLs go out of the market. So this is the 

7 cumulative NPV, so it maxes out at that level.

8 MR. ROSENSTOCK: I know, but you're 

9 talking about, I'll say, you know, possibly 30 

10 or, depending on commercial versus residential, 

11 you know, 10 or 20 product lifetimes. 

12 DR. GERKE: Yes, the standard 

13 analysis period for these is 30 years.

14 MR. ROSENSTOCK: All right. The 

15 second thing I had a question about, in your 

16 source energy savings, when I looked in the 

17 TSD, the numbers were significantly different 

18 from the source energy estimates that were used 

19 last year for other residential products. 

20 Could you explain why the change from last 

21 year's analysis of dishwashers and furnace fans 

22 compared to IRLs in GSFLs? 
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1 DR. GERKE: This is for the full 

2 fuel cycle --

3 MR. ROSENSTOCK: Yes. 

4 DR. GERKE: -- analysis?

5 MR. ROSENSTOCK: On the electric 

6 side, yes. There was significant change.

7 DR. GERKE: I don't have those 

8 numbers to hand. Karina, do you have any 

9 notions on that? All right. We'll look into 

10 it for the next phase.

11 MR. ROSENSTOCK: Steve Rosenstock, 

12 EEI. I don't see what -- the only thing that 

13 changed between last year and this year is 

14 record number of solar and wind installations. 

15 If anything, those numbers would go down. 

16 MR. STEPHENS: Charlie Stephens. I 

17 asked about this last year, and I think what 

18 was missing was natural gas. There was a whole 

19 segment of natural gas. They had not looked at 

20 shale gas at all. They had not finished the 

21 analysis for shale gas. And once the shale gas 

22 numbers were put in, I think it changed things 
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1 somewhat. 

2 MR. ROSENSTOCK: Steve Rosenstock, 

3 EEI. I appreciate that but, again, it didn't 

4 look like the natural gas numbers changed. It 

5 looked like the electric numbers changed. But 

6 in some of the analysis, the natural gas 

7 numbers did not change. So it can't change for 

8 one and not the other. 

9 MR. STEPHENS: Well, I think it did 

10 change on the natural gas side, which, since 25 

11 percent or so of the power is natural gas, it 

12 would change that, too.

13 MR. BROOKMAN: Moving on. Pekka?

14 MR. HAKKARAINEN: Pekka Hakkarainen, 

15 Lutron. What the graphs here are showing is 

16 that the effect of going to CSL 1 would be 

17 simply to kill a product class quickly, 

18 resulting in energy savings that are less than 

19 0.01 percent of national energy use. This is 

20 not going to be measurable anywhere, except on 

21 this particular graph that we're looking at 

22 here. If you think I'm annoyed, you're right. 
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1

2 DR. GERKE: All right. Thank you. 

3 This is a partial display of the results for 

4 GSFLs, which are more extensive and are covered 

5 in detail in the TSD. Again, the energy 

6 savings here is front-loaded because LEDs are 

7 eating into the market, so most of the savings 

8 is realized in the early part of the analysis 

9 period. Again, the cumulative NPV starts out 

10 negative, as people purchase more expensive 

11 products up front, and then grows into positive 

12 territory as those savings pay back over time. 

13

14 In this preliminary analysis, we 

15 found that the max CSL standards case achieves 

16 higher NES and higher NPV than the CSL 1 

17 standards case, regardless of the assumed 

18 discount rate. And both standards cases 

19 achieve positive NES and positive NPV.

20 MR. BROOKMAN: I'm going to ask you 

21 to pause right there. I think we should take a 

22 short break, just ten minutes, so people can 
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1 use the facilities. We still have a number of 

2 slides to get through, not that long but I'm 

3 guessing it's at least another half an hour. 

4 That would press several individuals; one or 

5 two have left the room already. Let's take a 

6 ten-minute break, which means we'll resume at 

7 ten after three. Good progress here. See you 

8 back here in ten minutes. 

9 (Whereupon, the above-entitled 

10 matter went off the record at 2:58 p.m. and 

11 resumed at 3:09 p.m.)

12 MR. BROOKMAN: Let's start back up. 

13 Okay. We're going to take it back to Brian. 

14 He's going to pick up where he left off.

15 DR. GERKE: Okay. As many of the 

16 assembled have noted, our analysis rests on a 

17 number of assumptions that do have some degree 

18 of uncertainty. In particular, changing our 

19 assumptions about available technologies, about 

20 the penetration of lighting controls in the 

21 market, and the penetration of LEDs in the 

22 market, and about the prices of rare earth 
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1 elements will have a significant effect or 

2 could have a significant effect on the results.

3 To gauge that impact, we performed a 

4 number of alternative analyses that varied our 

5 reference case assumptions as shown here: 

6 alternative technologies, different assumptions 

7 about lighting controls penetration, different 

8 assumptions about LED market incursion, and 

9 different assumptions about where the price of 

10 rare earth oxides will be in the future.

11 One means by which manufacturers 

12 could comply with the new IRL standards would 

13 be by simply shortening the lifetime of the 

14 baseline lamps that are currently commonplace, 

15 thus boosting their efficacy without reducing 

16 their energy consumption at all. If this were 

17 to occur, as shown in this model, you can see 

18 that the shipments no longer drop off because 

19 now you have these short lifetime lamps. In 

20 fact, the shipments are slightly higher in the 

21 standards case than they are in the base case. 

22 And in this case, it erases most of the energy 
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1 savings and makes the NPV of the rule 

2 significantly negative, regardless of assumed 

3 discount rate.

4 Our reference case analysis assumes 

5 growth in lighting controls that is consistent 

6 with commercial building codes as they build 

7 into the market, so the new ASHRAE 90.1 will be 

8 complied with over time as buildings are 

9 refurbished and renovated. And so the growth 

10 of lighting controls follows the trend of that.

11 If we instead assume that the 

12 penetration of lighting controls remains fixed 

13 at its current level, just to get a sense of 

14 the total impact, then the impact of a new GSFL 

15 standard is increased by a few tens of 

16 percentage points for both the NES and the NPV. 

17 At the moment, we don't assume growth in the 

18 IRL controls in our reference case, so there's 

19 no impact on the IRL rule.

20 One point to note here is that the 

21 impact of lighting controls coming into the 

22 market due to building codes depends on the 
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1 compliance rate with the state building codes 

2 that are out there. In this analysis, we 

3 assumed a 75-percent compliance rate. If it 

4 were to be higher or lower, then the impact of 

5 the controls on the rulemaking would obviously 

6 be different. So DOE seeks comment and 

7 relevant data on compliance rates with current 

8 state building code requirements, and we also 

9 seek comment on the validity and 

10 appropriateness of our assumption that the 

11 penetration of controls in the residential 

12 sector remains fixed at the current levels. 

13 MR. BROOKMAN: Charlie? 

14 MR. STEPHENS: Charlie Stephens. 

15 Yes, I think your assumptions are not terribly 

16 off the mark. We do code compliance studies. 

17 We just finished a residential one in 

18 Washington State. It was very high, but I 

19 don't think we see very much change in 

20 residential controls. They're all pretty much 

21 located in a predictable set of rooms, so I

22 wouldn't see any reason to change that. 
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1 And I don't think there's any point 

2 in adding 100 percent compliance rate in 

3 commercial buildings, code compliance, 

4 especially in lighting. I think when there is 

5 not compliance in commercial buildings, a lot 

6 of it seems to reside in the lighting area, 

7 lighting power densities. 

8 So I think, though it's interesting, 

9 the non-compliance would suggest that, you 

10 know, potentially, there's higher savings if 

11 the actual power consumption of the base case 

12 is higher than you assume it is, which it often 

13 is when there's non-compliance. But I don't 

14 think 75 percent is too far off the mark --

15 MR. BROOKMAN: Charlie, is your 

16 experience, is it confined to the Northwest or 

17 --

18 MR. STEPHENS: It is, as far as I 

19 know. We actually do studies. My organization 

20 is the one who does the studies in the four 

21 states, and we just finished one in Washington 

22 and one in Montana. 
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1 MR. BROOKMAN: Okay. Joe? 

2 MR. HOWLEY: So I also agree that 

3 your assumptions probably are fairly -- they're 

4 reasonable assumptions. However, what you 

5 should factor in is the fact that it's not so 

6 much the compliance with the building codes, 

7 it's just the building code requirements are 

8 increasing for the use of controls with 

9 lighting and that should be factored in. 

10 So it's not just that people are 

11 complying with the current controls, but you 

12 should assume a situation where you're going 

13 from something, you're starting with, I guess, 

14 five percent on commercial and you should have 

15 some model where that is increasing every year 

16 in the commercial sector as the requirements in 

17 these codes themselves keep increasing and the 

18 use keeps increasing.

19 DR. GERKE: Just to clarify, the 

20 five-percent number is the number of commercial 

21 IRLs on dimmers, which is not the same as the 

22 amount of commercial lighting on controls, 
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1 generally. And right now most of the buildings 

2 in the country are under some kind of building 

3 code that requires some amount of lighting 

4 control, and so we just assume that those are 

5 complied with as --

6 MR. HOWLEY: Yes, but most of those 

7 are on/off controls, and what I'm talking about 

8 are the new concepts where they're going to 

9 require sort of demand response systems or 

10 daylight response systems or even individual 

11 user control systems where they can decrease 

12 the lighting power use on an individual basis 

13 or based on some other response. That is 

14 increasing, and that is going to reduce the 

15 number of, the amount of power used by these 

16 fluorescent systems, as well. That should be 

17 factored into the analysis.

18 MR. BROOKMAN: Let's hear from 

19 Karina. 

20 DR. GARBESI: Thanks. Karina 

21 Garbesi from LBNL. We'd love some additional 

22 data on that. What we did -- you're absolutely 
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1 correct that the current codes require almost 

2 universal coverage of on/off, but there's 

3 alternative ways that you can meet it with more 

4 advanced controls, as well. And we also expect 

5 that there will be sort of this layering of 

6 more advanced controls as one goes along, but 

7 we don't have a way of predicting that well. 

8 What the assumption has been in the 

9 model is that we would save about 30 percent 

10 over no controls, and that's based on a meta 

11 study of savings that have been achieved to 

12 date in the field. But we realize that savings 

13 can go considerably higher if you start 

14 layering and you do it well. But right now we 

15 don't have data to be able to change that.

16 But, still, I think by 2046 you 

17 would have two-thirds of the commercial 

18 building area, essentially, covered by 

19 controls. 

20 MR. BROOKMAN: Charlie? 

21 MR. STEPHENS: I would agree with 

22 that end point. But what we're seeing right 
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1 now, as many as a third of the commercial 

2 building control systems don't work. They're 

3 there, but they don't work because they don't 

4 communicate with anything. There's 

5 miscommunication, and you can't program them, 

6 and they don't actually function the way they 

7 were designed, including our own space, I might 

8 add. We finally gave up on trying to make it 

9 work, and we've done workarounds, and we're not 

10 getting all the savings we thought we were 

11 going to get. 

12 But that's not uncommon, but we're 

13 also forecasting that fixture-level controls 

14 may change that, starting pretty much right 

15 about now. And so I wouldn't disagree with the 

16 trend, but for the reason that it will be 

17 simpler, not more complicated, not more 

18 layered, but actually down at the level of the 

19 fixture.

20 MR. BROOKMAN: Karina, go ahead. 

21 DR. GARBESI: Karina Garbesi again 

22 from LBNL. To clarify, the 30 percent number 
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1 that we used was based on cases where the 

2 savings were actually measured in the field. 

3 We did find that there was a significant over4 prediction of what the savings would be if you 

5 used the theoretical studies alone, so we 

6 attempted to account for it. 

7 MR. BROOKMAN: Steve? 

8 MR. ROSENSTOCK: Steve Rosenstock, 

9 EEI. I do recall that, under the stimulus 

10 program, that one of the incentives was that 

11 for all state governments to basically, all 

12 state governments -- a lot of state governors 

13 signed a document that said that they were 

14 going to go for 90 percent compliance in 

15 building codes by the year 2017, so there was 

16 money spent and they are kind of under the gun 

17 to report to the federal government. Again, 

18 the actual results may vary, but, again, that 

19 is out there, in terms of that.

20 I guess the other thing I was going 

21 to say was, you know, there's building codes 

22 and then there's green building codes. And in 
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1 many jurisdictions, even ASHRAE 90.1 isn't the 

2 minimum code. It's actually, it's LEED or the 

3 IGCC or ASHRAE 189.1 for certain commercial 

4 buildings, especially if they're above, I'll 

5 say 50,000 square feet in certain jurisdictions 

6 -- did I say something? Is everything okay? 

7 Okay. That they have to meet the green code, 

8 which has even more incentives for more 

9 controls on lighting within the building. 

10 Thank you. 

11 MR. BROOKMAN: Thank you. Karina, 

12 go ahead. 

13 DR. GARBESI: Sorry. Karina Garbesi 

14 again from LBNL. So another point of 

15 clarification. The model includes, on the top 

16 of what is going to be obtained solely from the 

17 state-required code implementation over time, 

18 as you get new buildings and retrofits, it also 

19 includes an amount above that, which is 

20 currently not explained by the codes, and that 

21 is carried forward. 

22 MR. BROOKMAN: Okay. Joe? 
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1 MR. HOWLEY: You know, it's just a 

2 final comment wrapping all these comments up. 

3 If you're assuming 5 percent commercial use of 

4 controls today are, you know, get you up to 30-

5 percent savings, what we would suggest in the 

6 analysis going forward is that 5 percent 

7 getting 30 percent savings is going to increase 

8 slowly over the next 20 or 30 years for all of 

9 these reasons. So maybe six or seven percent 

10 next year. So it's going to keep increasing by 

11 some estimated percentage over the analysis 

12 period. 

13 DR. GERKE: Thank you. That is what 

14 our analysis does, although it starts at a 

15 higher level. The five percent again is the 

16 fraction of IRLs that are on dimmers.

17 MR. BROOKMAN: Okay. So let's press 

18 on. 

19 DR. GERKE: Okay. Obviously, the 

20 incursion of LEDs, as we have noted, has a 

21 large impact on our analysis. So we performed 

22 an alternative analysis in which there was no 
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1 further LED incursion into the market just to 

2 gauge the size of that impact. And, obviously, 

3 the impact of that is quite substantial. It 

4 significantly increases the NES for each of the 

5 potential standards cases simply because 

6 there's substantially more lamps out there in 

7 the market that are subject to the standard. 

8 It also significantly increases the NPV of the 

9 GSFL standard, but it actually leads to a more 

10 negative NPV for the IRL standard.

11 MR. BROOKMAN: Steve? 

12 MR. ROSENSTOCK: Steve Rosenstock, 

13 EEI. So does this no LED also include the, 

14 I'll say the current competition from, I'll say 

15 HID reflector lamps that are used and also 

16 maybe some compact fluorescents? Again, I'm 

17 just -- there's no LEDs, which I understand are 

18 the newest technology, but what about the other 

19 competing technologies? 

20 DR. GERKE: That's not currently in 

21 the analysis.

22 MR. ROSENSTOCK: Okay, thank you. 
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1 DR. GERKE: All right. And, 

2 finally, rare earth element prices. As we're 

3 all aware, recent years have seen significant 

4 volatility in the price of rare earth elements. 

5 This chart shows a price index that we 

6 developed for the rare earth oxides that are 

7 used in the GSFL. It's weighed by their 

8 presence in those phosphors. Following a price 

9 spike in 2011, rare earth prices have retreated 

10 somewhat but have not returned to their 

11 previous levels.

12 We used the most recent prices in 

13 this chart to develop our reference case 

14 analysis. There's no reliable way to forecast 

15 future volatility in the market for rare 

16 earths; but, to capture the range of possible 

17 impacts represented historically, we also ran 

18 the model assuming that rare earth prices 

19 remained at their peak levels from 2011 over 

20 the entire analysis period or that they 

21 returned to their lower levels over the 

22 analysis period.
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1 In both cases, because we assumed 

2 that people continue to light their space, the 

3 impact on the NES and NPV of potential new GSFL 

4 standard is small, on the order of a few 

5 percent, in this analysis. 

6 And we'll move on to the comment 

7 box. DOE requests comments on the specific 

8 impacts of an increase in rare earth phosphor 

9 prices due to the decreased supply or an impact 

10 on the price due to the rulemaking.

11 MR. BROOKMAN: Joe?

12 MR. HOWLEY: So I think it's very 

13 unlikely we're ever going to see the low REO 

14 again. That level which existed prior was due 

15 to a lot of factors that don't exist anymore, 

16 and we expect this to remain at a higher level 

17 and also to continue to spike from time to 

18 time. Again, if you analyze some of the other 

19 types of critical materials that have gone 

20 critical, you'll see the pattern that is going 

21 to start to exist for rare earth materials. So 

22 it's going to be closer to the high rare earth 
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1 scenario, which I note for the maximum CSL 

2 produces a negative NPV in all scenarios. 

3 DR. GERKE: That's a negative change in 

4 the NPV from the reference case.

5 MR. HOWLEY: Oh, is that what that 

6 is? 

7 DR. GERKE: Yes.

8 MR. HOWLEY: Okay. Thank you for -

9 -

10 MR. BROOKMAN: Steve? 

11 MR. ROSENSTOCK: Steve Rosenstock, 

12 EEI. So if I'm reading this chart right, you 

13 know, everything else is kind of locked except 

14 for the rare earth materials. If it's a low 

15 price, the NPV goes down from the reference 

16 case, but if it's a high price the NPV goes up, 

17 even though the prices are higher? That's what 

18 this table says. 

19 DR. GERKE: In the CSL 1 case but --

20 MR. ROSENSTOCK: CSL 1.

21 DR. GERKE: -- not in the max CSL 

22 case.
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1 MR. ROSENSTOCK: What?

2 DR. GERKE: In one of the cases but 

3 not in the other.

4 MR. ROSENSTOCK: Okay. I'm just --

5 DR. GERKE: And the reason for that 

6 is likely because fewer people in the CSL 1 

7 case end up shifting to, naturally shifting to 

8 CSL 2 on their own because the prices are 

9 higher. 

10 MR. ROSENSTOCK: But there's only 

11 one CSL for IRLs, isn't there? Oh, the GSFL. 

12 I'm sorry. Sorry, GSFL. But there's only, 

13 only for the one lamp there's a second CSL. 

14 Okay. It just seemed counterintuitive to me. 

15 Okay, thank you. 

16 MR. BROOKMAN: Additional comments 

17 on rare earth phosphor availability in these 

18 scenarios? We're moving on. 

19 DR. GERKE: DOE did a few additional 

20 alternative analyses to assess uncertainties 

21 arising from uncertainty in the future price of 

22 electricity due to different assumptions about 
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1 economic growth in the annual energy outlook 

2 and also different assumptions about the 

3 rebound rate. 

4 As shown here, these are generally 

5 small compared to the impact of LEDs and 

6 controls on the rulemaking on the order of a 

7 few percent in most cases, except for the case 

8 of a 15-percent rebound rate, which has a 15-

9 percent factor. 

10 And at this stage, I'd like to open 

11 it up for general comments on the assumptions 

12 and methodology used in the shipments and NIA 

13 model. 

14 MR. BROOKMAN: Any additional 

15 comments here? We've been covering it as we've 

16 been going. Steve? 

17 MR. ROSENSTOCK: Steve Rosenstock, 

18 EEI. Why would the rebound rate only affect 

19 the NES? Because if they're using the product 

20 more that would cut into the economic savings, 

21 as well, right? 

22 MR. BROOKMAN: Karina? 
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1 DR. GARBESI: Karina Garbesi from 

2 LBNL. This is an approach that's been taken in 

3 some prior rulemakings as well. The feeling is 

4 is that the economic savings that are derived 

5 from energy efficiency savings are used 

6 productively somewhere else to get consumer 

7 utility, and so there's a tradeoff there and 

8 there's no change in net consumer utility as a 

9 result but there is a change in the energy 

10 savings. 

11 MR. ROSENSTOCK: Steve Rosenstock, 

12 EEI. Thank you. But I'm just saying, for this 

13 particular analysis, if you're assuming more 

14 usage of the lighting product, if you're, 

15 again, trying to bound the analysis to say, 

16 okay, you're doing the economic analysis 

17 without the extra utility. Then if a product 

18 is being used 15 percent, that reduces your 

19 energy savings by 15 percent and that reduces 

20 your cost savings by 15 percent.

21 DR. GERKE: Right. The assumption 

22 is that the additional utility that consumers 
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1 achieve from that remains within the analysis, 

2 so there's no net offset. That's been standard 

3 in recent rulemakings. 

4 DR. GARBESI: You can also see it in 

5 the TSD. If you look, it will direct you to 

6 the prior rulemaking that discussed that at 

7 more length. 

8 MR. ROSENSTOCK: Okay. Steve 

9 Rosenstock, EEI. So, again, I'm still, I think 

10 it still might be useful to see economically 

11 what the change in NPV is from a rebound effect 

12 because I know it's not used for the analysis 

13 or the end result but, again, if people are 

14 incorporating that type of analysis, I know 

15 that, you know, especially some utilities might 

16 try to, if there is a rebound effect, that will 

17 have an impact on their analysis of future DSM 

18 programs.

19 DR. GARBESI: Karina Garbesi again 

20 from LBNL. Actually, in this rulemaking we 

21 were unable to find any evidence of a current 

22 rebound on lighting. The data that were 
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1 originally cited went back to before 1992. 

2 There is a, you can find a discussion of this 

3 in one of the appendixes, either in Chapter 9 

4 or 10. And so we went to find current data 

5 that would get us as close to being able to 

6 quantify a rebound currently, and we could find 

7 no evidence thereof. 

8 MR. ROSENSTOCK: Steve Rosenstock, 

9 EEI. Again, I appreciate that, but, again, I 

10 think maybe, just from an analytical point of 

11 view, you know, if some people want or need to 

12 incorporate the financial or energy impact of a 

13 rebound effect and if they are required to do 

14 some sort of net present value analysis, it 

15 might be useful for some parties. Again --

16 MR. BROOKMAN: We're moving on.

17 DR. GERKE: Thanks for the comment.

18 MR. BROOKMAN: Preliminary MIA.

19 DR. GERKE: So Aisha Husain will be 

20 taking over for me now. 

21 MS. HUSAIN: Hi. This is Aisha 

22 Husain from Navigant. So these are the last 
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1 few slides. We will now discuss the 

2 methodology for the manufacturer impact 

3 analysis and some preliminary results that were 

4 provided from this analysis, and we will also 

5 go over upcoming NOPR analyses.

6 The purpose of the manufacturer 

7 impact analysis, or MIA, is to identify impacts 

8 of amended energy conservation standards on 

9 manufacturers. The MIA is conducted in three 

10 phases. In the first phase, an industry 

11 profile is developed that identifies key issues 

12 for the industry. An initial industry profile 

13 was presented in this preliminary analysis TSD. 

14

15 In the second phase, DOE develops an 

16 industry cash flow model called the government 

17 regulatory impact model, or GRIM, to forecast 

18 industry cash flows. In this phase, DOE also 

19 develops an interview guide for manufacturers 

20 to facilitate discussions during manufacturer 

21 interviews. In the third phase, the 

22 manufacturer interviews are conducted. 
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1 Information from the interviews and 

2 the GRIM are used to conduct a quantitative 

3 assessment of impacts due to standards. 

4 Manufacturer interviews are also used to make a 

5 qualitative assessment of impacts due to 

6 standards, including impacts on competition, 

7 manufacturing capacity, direct employment, and 

8 regulatory burden. Results from the second and 

9 third phase will be presented in the NOPR 

10 notice and TSD. 

11 In this preliminary analysis, 

12 manufacturers identified six key issues in 

13 relation to GSFL and IRL standards. GSFL 

14 manufacturers noted the availability of rare 

15 earth phosphors as a key issue. Because a 

16 majority of rare earth phosphor mines are in 

17 China, which imposes a quota on their export, a 

18 manufacturer outside of China may be left at a 

19 disadvantage.

20 Another key issue identified was 

21 that amended GSFL and IRL standards may be 

22 developed without knowing the full impact of 
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1 the July 2012 standards on sales, shipments, 

2 and consumer preferences. Manufacturers also 

3 noted that regulation of additional products 

4 may add to the existing burden of testing GSFL 

5 and IRLs for standards compliance.

6 Shift to other technologies was also 

7 cited as an issue. Manufacturers stated that a 

8 potential increase in GSFL and IRL prices due 

9 to amended standards could further drive 

10 consumers to alternative technologies, such as 

11 LEDs. There are also concerns that amended 

12 GSFL and IRL standards could cause 

13 manufacturers to shift R&D resources away from 

14 more efficient lighting technologies.

15 Another key issue was the potential 

16 impact on the residential sector. Amended IRL 

17 standards may cause residential consumers to 

18 purchase cheaper, less efficient IRLs with 

19 shorter lifetimes. For GSFLs, in order to 

20 comply with amended standards, residential 

21 consumers may have to switch out entire GSFL 

22 systems for minimal energy savings.
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1 So we have a few comment boxes here. 

2 In the NOPR stage, DOE plans to assess impacts 

3 on manufacturer subgroups. These are groups 

4 that have cost structures that differ largely 

5 from the industry average or are bound by a 

6 different regulatory framework than normally 

7 found in the industry. DOE requests comments 

8 on subgroups to analyze, as well as 

9 characteristics it should examine for this 

10 analysis. 

11 MR. BROOKMAN: No comments here? 

12 Okay. 

13 MS. HUSAIN: Okay. So leading into 

14 that, one of the subgroups DOE looks at are 

15 small business manufacturers. If DOE finds 

16 that small business manufacturers are impacted 

17 by this rulemaking, it will conduct a 

18 regulatory flexibility analysis to identify 

19 ways to reduce negative impacts. 

20 MR. BROOKMAN: Alex? 

21 MR. BOESENBERG: Alex Boesenberg, 

22 NEMA. Regarding small business impacts, how 
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1 closely or does the DOE work with the Small 

2 Business Administration on this point? 

3 MS. deBUTTS: I don't think we 

4 actually coordinate with them at this point, 

5 correct? 

6 MS. HUSAIN: We're not coordinating 

7 with them at this point, but I think maybe --

8 MR. STAS: Eric Stas, DOE. I mean, 

9 in a typical rulemaking, if we make a 

10 certification that there won't be a substantial 

11 impact on small businesses, we'll send a 

12 certification analysis to SBA for review. And 

13 SBA, presumably, is following DOE's 

14 rulemakings, and they're free to comment like 

15 any other party. And we also, you know, when 

16 we do the Regulatory Flexibility Act analysis, 

17 we'll look to the SBA's classifications under 

18 the codes to get the numbers, and they populate 

19 it with the financial information and all. 

20 MR. BROOKMAN: Steve? 

21 MR. ROSENSTOCK: Steve Rosenstock, 

22 EEI. I'm going to go back to the 2009/2012 
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1 rule where the Department of Justice said that 

2 there would be anti-competitive impacts of the 

3 IRL standard that was put in place, and I'm 

4 just, I'm kind of curious, when DOE received 

5 that information from the Department of 

6 Justice, what did DOE do with that information? 

7 When the Department of Justice specifically 

8 stated and it was put in the final rule that 

9 the standard was going to be anti-competitive 

10 and raise prices, what was DOE's response and 

11 what action did DOE take to address the 

12 Department of Justice's issues? 

13 MR. STAS: Okay. Eric Stas, DOE. I 

14 mean, I don't recall the specifics of it at 

15 this time, but I know, in the final rule, DOE 

16 addressed the DOJ's comments. And it's in the 

17 preamble of the final rule, and so DOE 

18 addressed the comments and was able to move 

19 forward with the final rule that was published.

20 MR. ROSENSTOCK: Well, Steve 

21 Rosenstock. Yes, I think kind of the 

22 addressing was to say DOE did not, basically, 
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1 well, I don't want to put words in anyone's 

2 mouth, but it's like, well, that DOE did not 

3 agree with the analysis of the Department of 

4 Justice it seemed like. It seemed to me to be 

5 a brush-off of what Department of Justice was 

6 saying, and it concerned me a lot, especially 

7 because it seemed, you know, when the 

8 Department of Justice says something is anti9 competitive and the standard is in place, it's 

10 not ease to alleviate those concerns with 

11 impacts on both manufacturers and consumers. I 

12 think that was a very -- it raised a lot of 

13 concerns.

14 MR. BROOKMAN: Charlie? 

15 MR. STEPHENS: Charlie Stephens. On 

16 the other hand, my experience from doing 

17 shopping regularly on this and in our own work 

18 in the manufacturers and distributors that we 

19 get to work with, which is quite a few, we have 

20 a lot more choices of who we get to work with 

21 these days on most of these products. There 

22 actually has been, I think, an increase in the 
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1 number of brand names that are available in our 

2 marketplace, and we get to work with more 

3 companies that five to ten years ago weren't 

4 even in the market, at least not in our market. 

5 So I'm not sure whose predictions actually 

6 were borne out here. 

7 MR. BROOKMAN: Look at these comment 

8 boxes. Let's get additional comments on 

9 Regulatory Flexibility Act and manufacturer 

10 impact analysis. No additional comments at 

11 this time? Yes, Alex? 

12 MR. BOESENBERG: Alex Boesenberg, 

13 NEMA. On issue 33 regarding manufacturer 

14 impact, I'm still trying to understand GRIM and 

15 how it works. But I'm curious if you could 

16 explain how GRIM or how the analysis you're 

17 doing, regardless of the tool, affects the 

18 cumulative burden and adjust the rule, as 

19 necessary. 

20 We've commented in numerous previous 

21 rulemakings as to the cumulative effects of you 

22 make lamps, you make ballasts, and now you're 
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1 conforming to a ballast rule that hits you with 

2 a 37 1/2 percent industry net present value 

3 over 20 to 30 years and then to do the same 

4 thing to the lamp side. How does the tool, how 

5 do the analyses factor in the limitations of 

6 just how many loans you can take out or how 

7 many, how much internal company resource you 

8 can funnel from one thing to the next? 

9 On a consumer note, to put it on a 

10 personal thing, if I want to take out a loan 

11 and buy a car, I can probably get one. If I 

12 want to take out a loan and buy a motorcycle, I 

13 might be able to get one. If I want to take 

14 out another loan for something, home 

15 improvement, I might not be able to get it. So 

16 at what point, how does the analysis factor in 

17 that companies can only adjust to so many rules 

18 that are, theoretically, now all being paid 

19 back at once in some sort of messy thing? 

20 MR. BROOKMAN: Keith? 

21 MR. K. COOK: Maybe another way to 

22 put what Alex is saying is at what point do 
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1 the, does the impact on manufacturers become 

2 over-burdensome? What is the criteria that 

3 determines that we've gone too far? How is 

4 that established? 

5 MR. BOESENBERG: And the statement -

6 - Alex Boesenberg -- to say that because, as 

7 I've been tracking rules for two and a half 

8 years, I haven't seen anything indicate when I 

9 read the final rule but because it would have 

10 been overly burdensome, we dropped it at CSL, 

11 for instance. 

12 MR. BROOKMAN: Please.

13 MR. H. COOK: Hi. This is Hayden 

14 Cook from Navigant. The GRIM itself does not 

15 look at the cumulative regulatory impact. The 

16 cumulative regulatory impact is a separate 

17 analysis, and it does look at either three- or 

18 four-year periods before the rule and after the 

19 rule goes into effect, and it looks at the 

20 conversion costs from previous rules. And then 

21 that information is given to DOE and is one of 

22 the criteria for selecting a standard, similar 
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1 to -- we already talked about small business, 

2 so the small business Regulatory Flexibility 

3 Act is a separate analysis that's conducted, 

4 and that information is then given to DOE, and 

5 that's one of the weights that is used to, 

6 ultimately, determine the final rule that gets 

7 set. So there's no number threshold or 

8 something like that. 

9 MR. BROOKMAN: Additional comments -

10 - thank you -- on these three items: 

11 manufacturer subgroup, Regulatory Flexibility, 

12 and manufacturer impact analysis? Okay. So 

13 then on to NOPR analyses. 

14 MS. HUSAIN: All right. Now we will 

15 briefly discuss the NOPR stage of this 

16 rulemaking. The following chart outlines the 

17 analyses that will take place during this 

18 stage. DOE will begin by revising analyses 

19 conducted at the preliminary stage, as 

20 appropriate, based on comments received. DOE 

21 will then conduct additional set of analyses 

22 that will further inform the rulemaking. 
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1 These additional analyses include 

2 the LCC subgroup analysis which conducts an LCC 

3 assessment for specific consumer subgroups. 

4 Phases two and three of the MIA which were just 

5 discussed previously will be conducted in the 

6 NOPR stage. The employment impacts analysis 

7 looks at the indirect effects of national 

8 employment, which are impacts on net jobs as 

9 results of changes in expenditures and incomes 

10 due to amended standards. This employment 

11 impact analysis is different from the 

12 employment analysis conducted in the MIA which 

13 looks at direct employment impacts. 

14 The utility impact analysis looks at 

15 impact on generation capacity of utilities. The 

16 emissions analysis focuses on impact on impact 

17 on airborne pollutant emissions. Monetization 

18 of emission reduction benefits analysis 

19 estimates the monetary benefits from emission 

20 reductions, and the regulatory impact analysis 

21 identifies potential non-regulatory 

22 alternatives to standards. 
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1 DOE would welcome comments on these 

2 planned analyses for the NOPR stage. For the 

3 emissions analysis, DOE will assess the impact 

4 on emissions of carbon dioxide, sulfur dioxide, 

5 nitrogen oxides, and mercury, and monetize the 

6 emission reductions due to amended standards. 

7 DOE welcomes comments on the methodology for 

8 this analysis. 

9 MR. BROOKMAN: Yes, Steve? 

10 MR. ROSENSTOCK: Steve Rosenstock, 

11 EEI. A few thoughts on this, and I'll go by 

12 emission. For sulfur dioxide, as I recall the 

13 TSD, there was a value in there based on a 2001 

14 study of, like, I'll say $2,000 per ton, or I 

15 forget what the exact amount was. But it was 

16 based on a study that's 12 years old that's 

17 been, basically, adjusted for inflation. And 

18 to me, that number is totally way overstated 

19 because of the fact that, because of the 

20 federal Clean Air Act, the emissions of sulfur 

21 dioxide, since about 2001, they've gone down 

22 about 60 percent for SO2, since 1990 about 80 
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1 percent. If you look at the AEO projections, 

2 it's going to go down another 40 percent by the 

3 year 2015. So I don't see how those values can 

4 be so high when the amount of emissions keep 

5 going down and down and down. So I'm pretty 

6 concerned about that.

7 I also note that, with certain 

8 emissions, that wherever there is a federal or 

9 regional cap, like the eastern 28 states, DOE 

10 has correctly said that efficiency standards 

11 will not affect, there will be no physical 

12 reduction in emissions based on appliance 

13 efficiency standard because they're capped 

14 upstream and they are regulated. Well, that's 

15 about to happen with mercury, under the mercury 

16 and air toxic standard rule that was finalized 

17 by EPA just a couple of months ago. 

18 And in terms of carbon dioxide, 

19 there's no national standard, but there are 

20 regional standards. There's a regional 

21 standard in New England, and there's now the 

22 California standard. CO2 emissions are capped 
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1 in those states. 

2 So I'm wondering: will DOE treat CO2 

3 standards the way they've treated other 

4 standards in terms of that they will not show 

5 any emissions reductions and, therefore, no 

6 dollar savings because they're already capped 

7 in those regions. And I have a couple of other 

8 comments. 

9 MR. BROOKMAN: Yes. Steve, I'm sure 

10 the Department will welcome your comments on 

11 this. 

12 MR. ROSENSTOCK: I know, but I'd 

13 like some feedback from the Department now. 

14 MR. BROOKMAN: Lucy? 

15 MS. deBUTTS: We'll take a look at 

16 the data.

17 MR. ROSENSTOCK: Okay, thank you. 

18 And the other thing I was going to say, in 

19 terms of CO2 emissions, and I've said this 

20 other times before, in New England and 

21 California they already have dollar values. In 

22 New England it's about $2.00 per ton, which is 
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1 down from $3.00 a ton a few years ago. In 

2 California, the most recent auction, I believe, 

3 was $13.00 a ton and the first one was $10.00 a 

4 ton. These values are significantly below what 

5 DOE is using, and those dollars are going to be 

6 put into the electric rates already. So in a 

7 way, when DOE uses these numbers in its final 

8 analysis, I know they do it in the LCC but I 

9 know they do it in the final analysis for the 

10 final rule, you're double-counting the CO2 

11 dollar savings for those regions. And I would 

12 hope that adjustment would be made because when 

13 you double-count, you're overinflating what the 

14 estimated, I'll say, monetized savings are 

15 going to be for those, for that emission. 

16 The last thing I also want to say is 

17 that, in many states, there are renewable 

18 portfolio standards. There's record amounts of 

19 zero-emissions electricity being produced 

20 throughout the United States. So, again, in 

21 fact, CO2 emissions from the electric sector 

22 are below 1996 levels, even though production 
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1 has increased 16 percent. Thank you. 

2 MR. BROOKMAN: Thank you. Comments 

3 on regulatory impact analysis? Okay. And also 

4 you want to queue up LCC subgroups and trial 

5 standards? Yes, Keith? 

6 MR. K. COOK: Yes, I'm sorry. On 

7 the regulatory impact analysis, it's very 

8 similar to our previous comment, and that is 

9 every year we go through this exercise of these 

10 rulemakings and every year we provide all sorts 

11 of data explaining what the regulatory impact 

12 analysis is doing for us, but we don't see 

13 anything coming out of it. Again, the same 

14 question I had before is what is going to be 

15 the determining factor saying enough is enough? 

16 What is that criteria that says -- otherwise, 

17 you know, why bother? If there isn't something 

18 that triggers action, then why do you even ask 

19 the questions? 

20 MR. BROOKMAN: Okay. Yes, Alex? 

21 MR. BOESENBERG: This is Alex 

22 Boesenberg, NEMA. Since Keith clarified my 
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1 last big long statement, and his is short so 

2 I'll make a short clarification, will the DOE 

3 provide greater transparency into that decision 

4 cycle so that we can better understand how the 

5 decision is weighed? And I have a follow-on. 

6 MS. deBUTTS: I'm not sure what you 

7 mean by greater transparency. 

8 MR. BOESENBERG: As was explained 

9 there, that regulatory burden is factored in 

10 with all the other choices and, therefore, a 

11 CSL is chosen. And it, logically, would help 

12 folks understand why, hey, it could have been 

13 worse if you can see that somehow something was 

14 knocked down in certain areas. 

15 MS. MCDONALD: This is Ali McDonald. 

16 In the NOPR notice, there's a section called a 

17 walkdown which, essentially, starts with the 

18 highest possible standard, looks at all the 

19 results for those levels, like all the 

20 benefits, any burdens identified, and it comes 

21 to a conclusion as to whether the benefits 

22 outweigh the burdens. And if they don't, then 
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1 they evaluate the next lowest level and they, 

2 essentially, walk down until they find a level 

3 at which the benefits do outweigh the burdens. 

4 And there's a discussion in the notice about 

5 that. 

6 MR. BOESENBERG: All right. Thank 

7 you for that. This is Alex Boesenberg again. 

8 Thank you for that clarification. We do have a 

9 perception that, once it hits the NOPR, it's 

10 pretty much a done deal, at which point it's 

11 hard to affect the change. 

12 MS. deBUTTS: Not necessarily 

13 because, as you know, there were rules, I'm not 

14 sure, you know, if we had any lighting standard 

15 rules, but we come up with supplementary 

16 notices. So if there are changes, significant 

17 changes that need to be addressed, the 

18 Department has the discretion of providing that 

19 or publishing that notice.

20 MR. BOESENBERG: Okay. And if I can 

21 ask my follow-on. That same explanation said, 

22 so we get this in and then you choose the CSL, 
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1 and so it could be a lower CSL due to 

2 cumulative burden and other effects. We have a 

3 lot of stuff here where there's only one CSL, 

4 and so the option is zero or one, and the 

5 practice is to not say zero. 

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

7 typically, there are, you know, more CSLs. And 

8 usually there's some level where there's energy 

9 savings and economic justification to adopt a 

10 standard. But in the past, DOE, on some 

11 occasions, has adopted a no-standard standard 

12 because that's all that was justified. 

13 MR. BOESENBERG: Could I get a list 

14 of those? I haven't experienced one myself.

15 MS. deBUTTS: We can come back to 

16 you on that one. We'll look into it. 

17 MR. BOESENBERG: I'd appreciate it.

18 MR. BROOKMAN: Go ahead, Steve.

19 MR. ROSENSTOCK: Steve Rosenstock. 

20 Yes, the only product I'm aware of is microwave 

21 ovens, at least off the top of my head. But 

22 that was for the full standard. Now they're 
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1 about to do a standard on just the standby 

2 energy use of microwave ovens, so even that's -

3 - I have to caveat that statement. 

4 MR. BROOKMAN: Okay. Do you want to 

5 cue these last two? 

6 MS. HUSAIN: Sure. So DOE, as I 

7 mentioned, will assess the LCC impacts from 

8 standards on specific consumer subgroups that 

9 might be adversely impacted by amended 

10 standards. DOE is planning to assess low11 income consumers defined as residential 

12 consumers with incomes at or below the poverty 

13 line, per the U.S. Census Bureau. It's also 

14 planning to assess institutions of religious 

15 worship and institutions serving low-income 

16 consumers. DOE welcomes comments on the LCC 

17 subgroups it's considering and any additional 

18 ones it should consider. 

19 MR. BROOKMAN: Cue up trial standards 

20 also. 

21 MS. HUSAIN: For the NOPR, DOE is 

22 considering developing trial standard levels, 
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1 or TSLs, from the CSLs using minimum LCC, 

2 maximum NPV, and max tech efficiency as 

3 criteria. From these TSLs, DOE will select one 

4 proposed standard, and DOE requests comments on 

5 the criteria it is considering that should be 

6 used to develop TSLs.

7 MR. BROOKMAN: Final comments on 

8 these two issues? Steve? 

9 MR. ROSENSTOCK: Steve Rosenstock, 

10 EEI. On the LCC subgroups, I mean, I think 

11 that looks fine. My only question was, since 

12 you're using RECS data, I can't remember, I'd 

13 have to take a look if the RECS data -- there 

14 are areas of RECS that show differences, energy 

15 consumption or energy usage or energy 

16 expenditures, by income. I can't remember if 

17 they have a specific breakout at the poverty 

18 level. I don't recall if they do. 

19 So I think -- in concept, I like 

20 your idea. I'm just thinking, with the current 

21 RECS data, the way it's structured right now, I 

22 don't know if they break it out that way. So 
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1 that might make it a little trickier for you in 

2 terms of some of your analysis. 

3 MR. BROOKMAN: Comments on trial 

4 standard levels? No comments here. As we 

5 promised you first thing this morning, now 

6 there's an opportunity for anybody that wishes 

7 to to make a concluding remark, a final 

8 statement, issues that haven't been covered 

9 sufficiently as we move towards closure. 

10 Nothing additional at this time, it seems.

11 Then I'll turn it back to Lucy and, 

12 as I do, I'll thank you personally for a very 

13 productive meeting. There's an evaluation form 

14 that's at the bottom of your packet of 

15 information. Please take a minute and fill it 

16 out, and back to Lucy deButts. 

17 MS. deBUTTS: I just wanted to say 

18 thank you for everyone who contributed today. 

19 Again, we are welcoming all written remarks. 

20 We're going to be waiting for those, as 

21 promised, by May the 13th. And if you have any 

22 data, as I said, we would appreciate if the 
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1 Department could take a look at it.

2 Other than that, I think we had a 

3 very productive discussion today. That's why 

4 we ran a little over. So thanks again. 

5 (Whereupon, the meeting was 

6 concluded at 3:52 p.m.)