UNITED STATES OF AMERICA

DEPARTMENT OF ENERGY 

PUBLIC MEETING 

ON

ENERGY CONSERVATION STANDARD

PRELIMINARY ANALYSIS FOR METAL HALIDE LAMP FIXTURES

U.S. Department of Energy

1000 Independence Avenue, SW

Washington, DC 20585

Room 8E-089

Monday

April 18, 2011

Chair:

Tina Kaarsberg, PhD

Facilitator:
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Doug Brookman

Public Solutions

Baltimore, MD

Participants Identified: 

Susan Anderson

OSRAM SYLVANIA

100 Endicott Street

Danvers, MA 01923

Jennifer Amann

ACEEE

529 14th Street NW, Suite 600

Washington, DC 20045

Timothy Ballo

EarthJustice

1625 Massachusetts Avenue

Suite 702

Washington, DC 20036

Brian Boyd

Pacific Northwest National Laboratory

902 Battelle Boulevard

P.O. Box 999

Richland, WA 99532

Keith Cook

Philips

1050 K Street, NW

Washington, DC 20001

Ku’uipo Curry

ICF International

1725 Eye Street NW

Suite 1000

Washington, DC 20008

Tom Eckman

Northwest Power and Conservation Council

851 SW Sixth Avenue

Suite 1100

Portland, OR 97204-1348
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Cheryl English

Acuity Brands Lighting

One Lithonia Way

Conyers, GA 30012

Bob Erhardt

Philips Lighting and Electronics

John Green

Cooper Lighting

1121 Highway 74 South

Peachtree City, GA 30269

Tom Harding

Venture Lighting

32000 Aurora Road

Solon, OH 44139

Thomas Hirt

Hubbell Lighting, Inc.

701 Millenium Blvd.

Greenville, SC 29607

Joseph Howley

GE Lighting

1975 Noble Road

Bldg. 307E

Cleveland, OH 44112

Kate Jensen

Steptoe & Johnson

1330 Connecticut Avenue NW

Washington, DC 20036-1795

Elizabeth Joyce

Energy Solutions

1810 Harrison Street

Oakland, CA 94612

Andrew Johnson

OSRAM SYLVANIA

54 Cherry Hill Dr.

Danvers, MA 01923

Rebecca Lancaster
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General Electric

3010 Spartansburg Hwy

East Flat Rock, NC 28792

Joanna Mauer

Appliance Standards Awareness Project (ASAP)

529 14th Street NW, Suite 600

Washington, DC 20045

Justin Neumann

National Electrical Manufacturer’s Association (NEMA)

1300 North 17th Street, Suite 1752

Rosslyn, VA 22209

Rebecca Rainer

Cooper Lighting

5035 Highway 61 South

Vicksburg, MS 39180

Charlie Stephens

Northwest Energy Efficiency Alliance

421 SW Sixth Avenue, Suite 600/ Portland, OR 97204

Mike Stevens

Georgia Power

1790 Montreal Circle

Tucker, Georgia 30084

Meg Waltner

Natural Resources Defense Council

1200 New York Avenue., NW

Suite 400

Washington, DC 20005

Rachel Dickenson

Navigant Consulting

1801 K Street NW

Suite 500

Washington, DC 20006

Mahima “Mimi” Gupta

Associate Director

Navigant Consulting

1801 K Street NW
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Suite 500

Washington, DC 20006

Merry Walker

Navigant Consulting

1801 K Street NW

Suite 500

Washington, DC 20006

Ashley Armstrong

Participants from DOE:

Department of Energy

Eric Stas

Department of Energy General Counsel’s Office

Brian Coffey

Presenters:

Navigant Consulting

1801 K Street NW

Suite 500

Washington, DC 20006

Hayden Cook

Navigant Consulting

1801 K Street NW

Suite 500

Washington, DC 20006

Scott Morris

Pacific Northwest National Laboratory

902 Battelle Boulevard

P.O. Box 999

Richland, WA 99532

Michael Myer

PNNL

57 Bedford Street

Suite 101

Lexington, MA 01760

Matthew Walker

Navigant Consulting
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1801 K Street NW

Suite 500

Washington, DC 20006
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AGENDA

 ITEM PAGE

Welcome, Doug Brookman 9

Introductions 9

Agenda Review, Doug Brookman 11

Opening Statements 14

Introduction

Dr. Kaarsberg 18

Regulatory History

Brian Coffey 19

Rulemaking Overview 

Brian Coffey 20

Market Assessment 

Brian Coffey 21

Test Procedure

Brian Coffey 25

Options for Standards

Brian Coffey 29

Scope of Coverage

Brian Coffey 43

Technology Options 

Brian Coffey 47

Screening Analysis

Brian Coffey 49

Engineering Analysis

Matthew Walker 51

Energy Use and Markups Analysis 

Michael Myer 84
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Life-Cycle Cost and Payback Period Analysis

Scott Morris 94

National Impacts Analysis

Scott Morris 110

Preliminary Manufacturer Impact Analysis

Hayden Cook 126

NOPR Analyses

Michael Myer 133

Closing Remarks 140
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2 MR. BROOKMAN: Good morning and welcome to 

3 public meeting on Energy Conservation Standards for 

4 Preliminary Analysis for Metal Halide Lamp Fixtures. 

5 Today is Monday, April 18, 2011. My name is Doug 

6 Brookman from Public Solutions in Baltimore. 

7 Welcome. We’re glad you’re here. We’re going to 

8 have welcoming remarks first thing this morning. 

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

9 You can turn these microphones on and off, 

10 the little green LED button needs to be glowing for 

11 them to be on. If you’ll say your name and your 

12 organizational affiliation, please. 

13 Introductions

14 MS. RAINER: Rebecca Rainer, Cooper 

15 Lighting, and Vice Chair of the Lighting Institute.

16 MR. BROOKMAN: Thank you.

17 MR. ERHARDT: Bob Erhardt,Philips

18 Electronics.

19 MR. HIRT: Tom Hirt, Hubbell Lighting.

20 MS. JENSEN: Kate Jensen, Steptoe & 

21 Johnson.

22 MR. BROOKMAN: You have to grab one, get 

23 used to that. 

24 MS. JENSEN: Kate Jensen, Steptoe & 

25 Johnson. We represent Acuity Brands Lighting.
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1 MR. BROOKMAN: Thank you.

2 MR. HARDING: Tom Harding, Venture 

3 Lighting.

4 MR. COOK: Keith Cook, Philips Lighting.

5 MR. NEUMANN: Justin Neumann with the 

6 National Electrical Manufacturers Association.

7 MR. STEVENS: Mike Stevens, Georgia Power.

8 MR. HOWLEY: Joe Howley with GE Lighting 

9 and Chairman of the NEMALamp Section.

10 MS ANDERSON: Susan Anderson, OSRAM 

11 SYLVANIA.

12 MS. MAUER: Joanna Mauer, Appliance 

13 Standards Awareness Project.

14 MR. STAS: Eric Stas, DOE General 

15 Counsel’s office.

16 MS. ARMSTRONG: Ashley Armstrong, 

17 Department of Energy.

18 MS. KAARSBERG: Tina Kaarsberg, DOE.

19 MR. BROOKMAN: Why don’t you guys stand 

20 up.

21 MR. WALKER: Matthew Walker, Navigant.

22 MR. COFFEY: Brian Coffey, Navigant.

23 MR. MORRIS: Scott Morris, Pacific 

24 Northwest National Laboratory.

25 MR. GREEN: John Green, Cooper Lighting 
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1 and Chair of the NEMA Ballast Section.

2 MR. BROOKMAN: Why don’t you just leave it 

3 on. Please.

4 MR. JOHNSON: Andrew Johnson, OSRAM 

5 SYLVANIA.

6 MR. STEPHENS: Charlie Stephens, Northwest 

7 Energy Efficiency Alliance.

8 MS. JOYCE: Elizabeth Joyce, Energy 

9 Solutions on behalf of Pacific Gas and Electric 

10 Company.

11 MS. LANCASTER: Rebecca Lancaster, GE.

12 MR. BOYD: Brian Boyd, Pacific Northwest 

13 National Lab.

14 MR. COOK: Hayden Cook, Navigant.

15 MR. BALLO: Tim Ballo, Earth Justice.

16 MR. BROOKMAN: Again, welcome and thanks 

17 for being here for an early start on this day.

18 Agenda Review

19 MR. BROOKMAN: I think all of you received 

20 a packet of information as you checked in this 

21 morning. That includes both the PowerPoint slides 

22 that we’ll be going through one by one as the day 

23 proceeds, an executive summary of the preliminary 

24 analysis and also a copy of the Federal Register

25 Notice. We’ll be referring to these as we go along 
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1 today. 

2 I’m going to do a very quick agenda 

3 review, and then we’re going to go into the 

4 substantive material. You can see as you look at 

5 the agenda, immediately following this agenda 

6 review, there’s an opportunity for opening remarks, 

7 key issues that any of you wish to raise that you 

8 think are especially relevant for today’s 

9 proceeding. 

10 Immediately following that we’re going to 

11 have an overview of the statute and context, market 

12 assessment, Technology Assessment and the Screening 

13 Analysis. We’ll take a break mid-morning around 

14 about 10:15 or so. Following that, Engineering 

15 Analysis, and continuing on, Energy Use and End-Use 

16 Load Characterization, and Mark-ups for Equipment. 

17 Price Determination. We’ll take lunch mid-day, 

18 round about noonish.

19 Immediately following lunch, Life-Cycle 

20 Cost and Payback Period, Shipments and National 

21 Impacts Analysis. Then Preliminary Manufacturer 

22 Impact Analysis, NOPR Analyses, and then closing 

23 remarks this afternoon, perhaps round about 2:00 or 

24 so.

25 There’s -- typically, the Department 
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1 provides another opportunity for anybody that wishes 

2 to make closing remarks, supplemental issues that 

3 weren’t covered sufficiently, so there’s another 

4 opportunity then at the end of the day to do that. 

5 Questions and comments on the agenda?

6 Then I’d ask for your consideration, you 

7 can see, written up here in what I think are 

8 courtesies if you will. Please speak one at a time. 

9 Please say your name for the record. You don’t need 

10 to say your organizational affiliation every time

11 unless you’re in the habit of doing so, that’s okay. 

12 But if you say your name each time you speak. There 

13 will be a complete transcript of this proceeding 

14 that will be posted on the EERE website -- yes? 

15 They keep kind of changing that up a little bit. 

16 I’m going to be queuing each person to 

17 speak by name as best I can. It’s also useful for 

18 the Department to have follow-on comments. 

19 Sometimes the back and forth is very beneficial for 

20 the Department as they build their record of comment 

21 for this proceeding. If you can try to be concise, 

22 please share the air time with your colleagues here,

23 and keep the focus here. 

24 If you haven’t already done so, please 

25 turn your cell phones on silent mode, and limit the
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1 sidebar conversations. I think everybody’s already 

2 gotten used to turning these microphones on and off. 

3 If you’re going to speak quite a bit, you might as 

4 well just leave it on, if not, you can turn it on 

5 and off. 

6 So that is, I think, everything I intended 

7 to cover at the outset. Questions before I turn it 

8 back to Tina? Okay. Thank you. Tina Kaarsberg.

9 MS. KAARSBERG: Yeah, I actually had one 

10 comment on the agenda. Sorry I didn’t bring it up 

11 before. We are going to try -- we’re still new to 

12 the webinar -- but we’re going to try and address 

13 the webinar posted questions right before the first 

14 break, right before lunch, and right before we 

15 adjourn. So if you have -- not you in the room, but 

16 those of you who are on the webinar.

17 Opening Statements

18 DR. KAARSBERG: Okay. The purpose of the 

19 meeting is, I guess it’s a two-way street. We 

20 present the preliminary analysis to you for the 

21 energy conservation standard. We get comments back 

22 from you, and then we talk about the next steps. 

23 That’s sort of the three principles. Someone once 

24 told me in DC you always have to have three of 

25 everything, so -- and we’d really like you to 
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1 provide comments, statements on the standard, and 

2 now is a time for people to make, you know, like an 

3 overarching comment or any kind of comment in the 

4 agenda. If anyone has any?

5 MR. BROOKMAN: Yes, opening statements 

6 here at the outset? Yes, Justin.

7 MR. NEUMANN: Justin Neumann with NEMA. I 

8 won’t say that again. We appreciate the opportunity 

9 to make opening comments here for this rulemaking. 

10 NEMA is initially -- we’re worried [that] the energy 

11 savings in this rulemaking [will] be missed, partly 

12 because of two separate rulemakings going on and 

13 who’s handling those rulemakings. Be it with this 

14 one on metal halide luminaries and Navigant as the 

15 third party outside group handling that, and then on 

16 HID lamps with PNNL. Those two products are 

17 essentially intertwined and with two separate 

18 rulemakings going on, we’re [worried] that energy 

19 savings may be missed by handling it this way. 

20 And also it appears to us, based on the 

21 Federal Register document, that the analysis, as the 

22 current rules in place already do a good job in 

23 creating energy savings for the consumers, and NEMA 

24 feels that there are no big gains to be had 

25 currently in this rulemaking. Industry has been 
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1 working towards achieving much higher energy savings 

2 down other avenues and we fear that this rulemaking 

3 could be counterproductive to that. The markets, 

4 for the NEMA manufacturers are already driven 

5 towards energy efficient appliances, that’s what 

6 their customers are asking for, and we fear that 

7 this rulemaking could potentially hinder that as the 

8 market is already going in that direction.

9 We’re also worried that ENERGY STAR is 

10 also developing standards for the same luminaires 

11 and with two different standards in place, this also 

12 could adversely affect the marketplace. There are 

13 also some concerns about the liabilities of 

14 electronics at high ambient temperatures, and how 

15 that could affect the product.

16 We’d like to thank you for conducting the 

17 manufacturer interviews that have been done so far 

18 and encourage you to continue to do so with the 

19 various NEMA members. And we also appreciate our 

20 previous comments, both written and verbal, that 

21 have been taken into consideration so far in this 

22 rulemaking process. Thank you.

23 MR. BROOKMAN: Thank you. Other comments 

24 here? Introductory comments at the outset? Bob.

25 MR. ERHARDT: Bob Erhardt, Philips
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1 Lighting and Electronics. One comment with respect 

2 to Justin’s introduction. When industry met on 

3 Thursday, there was a completely different payback 

4 analysis [posted on the DOE website] from what there 

5 was on Friday and we have not had the opportunity to 

6 review the new payback analysis, and we’re going to 

7 find it difficult to comment on it. We wish that 

8 the DOE had been consistent or at least given us 

9 better lead time if they were going to make such a 

10 dramatic change.

11 MR. BROOKMAN: Okay. And of course, I 

12 think most of you in this room are familiar that 

13 these oral comments will be captured for the record, 

14 but the Department really appreciates your written 

15 comments as well, extensive detailed written 

16 comments is what they appreciate most.

17 Other comments here at the outset? Okay. 

18 And let me echo Tina’s sentiments, welcoming those 

19 on the webinar. And as she said, we’ll be trying to 

20 find a way to insert your questions where 

21 appropriate as the day goes along.

22 So we’re going to proceed then, and we’re 

23 going to hear from Brian Coffey first. 

24 MR. COFFEY: I think we still have Tina 

25 first, a slide or two, actually.
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1 MR. BROOKMAN: Okay.

2 INTRODUCTION

3 DR. KAARSBERG: I wanted to talk a little 

4 bit about these boxes that you see everywhere. My 

5 understanding is that these boxes have been around 

6 for a long time so it shouldn’t surprise most of 

7 you, but I just wanted to note that boxes are issues 

8 that are, in large part, drawn from the material 

9 posted on the Web in the third section of the 

10 Executive Summary of the preliminary analysis and 

11 it’s also on the URL on your screen. Those boxes 

12 that come from the executive summary have an “ES” in 

13 front of them, and they are not necessarily 

14 sequential because we wanted you to be able to cross 

15 reference, because the information in the written 

16 material is a little bit longer, has a little bit 

17 more background in general. And then there’s a 

18 couple that aren’t in the Executive Summary. Just a 

19 little housekeeping type thing there.

20 Of course, those are things that we 

21 especially would like to have comments on, but of 

22 course, you’re welcome to comment on anything. 

23 And speaking of comments, I just want to 

24 quickly remind you that public comments -- we have a 

25 process, and the process enables us to address 
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1 everyone’s comments and there are several ways: e2 mail, post, courier, that you can provide us 

3 comments for the record in addition to verbal 

4 comments or posted comments for the webinar folks. 

5 And we would encourage you, especially on the 

6 written comments, to -- any kind of process 

7 questions, especially on the webinar, which we’re 

8 still sort of new to, but in general if it could run 

9 better, we’re constantly trying to streamline and 

10 improve what we’re doing. And with that, I’ll turn 

11 it over to Brian Coffey of Navigant.

12 Regulatory History

13 MR. COFFEY: Thanks, Tina.

14 DR. KAARSBERG: Oh, there he is.

15 MR. COFFEY: Here’s a little overview of 

16 what’s going to be in this presentation, content17 wise, so I’ll start with the overview and statutory 

18 context for the rulemaking. Here’s the regulatory 

19 background of the rulemaking. The Energy Policy 

20 Conservation Act of 1975, or EPCA, established the 

21 conservation standards and development for certain 

22 commercial equipment. The Energy Independence and 

23 Security Act of 2007, or EISA, prescribed standards

24 for metal halide lamp fixtures by requiring that 

25 they contain ballast meeting or exceeding defined 
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1 efficiency levels. It also directed DOE to develop 

2 at test procedure for those ballasts based on an 

3 ANSI standard, the 2005 revision of C82.6.

4 EISA also directed DOE to incorporate 

5 standby and off mode provisions in the standards

6 rulemaking. Finally, EISA directed DOE to amend 

7 standards for metal halide lamp fixtures and publish 

8 a final rule by January 1, 2012, and then publish a 

9 revision to that rule seven years later on January 

10 1, 2019.

11 Rulemaking Overview 

12 So now let’s take a look at the schedule 

13 for all that. Rulemaking has four main stages. DOE 

14 kicked off the metal halides rulemaking in December 

15 2009 with the publication of a framework document 

16 and on the first of this month, published a Federal

Register

20 Later this year, DOE will publish a Notice 

21 proposing a standard and hold another meeting to 

22 receive feedback on that proposal. 

17 notice announcing this preliminary analysis 

18 meeting wherein DOE presents its initial analytical 

19 results. 

23 The final rule arrives on the first of 

24 January 2012, as I mentioned, and will go into 

25 effect three years later, on January 2015.
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1 So those are the background details of the 

2 rulemaking and now I’ll move into the content. 

3 Here’s an expansion of the preliminary analysis 

4 stage, our current stage, and the analyses that 

5 comprise it. 

6 Market and Technology Assessment 

7 MR. COFFEY: Let’s start by talking about 

8 the market and technology assessment, which 

9 characterizes the metal halide fixture industry, 

10 determines the rulemaking’s proper scope of 

11 coverage, breaks down that scope of coverage into 

12 equipment classes, and identifies technology options 

13 that can be used to improve efficiency. We’ll also 

14 look at the Screening Analysis, which screens out 

15 those technology options on the basis of four 

16 criteria and relabels the remaining ones “design 

17 options” for consideration in the next analysis, the 

18 Engineering, which you can see in the next chevron 

19 right there.

20 Definitions. EISA 2007 defined the term 

21 metal halide lamp fixture. It means a light fixture 

22 for general lighting application designed to be 

23 operated with a metal halide lamp and for a metal 

24 halide lamp. EISA then went on to establish 

25 efficiency standards for ballast contained in a 
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1 subset of metal halide lamp fixtures. This is an 

2 important point. This action of EISA didn’t set 

3 standards for the lamp, or for the optical portion 

4 of the fixture. It set standards only for the 

5 ballast sold in new fixtures that match certain 

6 criteria. 

7 Let’s take a look at which ballasts had to 

8 meet which standards. Here’s the current statutory 

9 scope of coverage. Pulse-Start ballast from 150 to 

10 500 watts inclusive have to be 88 percent efficient. 

11 Magnetic pulse-start ballast from 150 to 500 watts 

12 inclusive have to be 94 percent efficient. Non13 pulse-start electronic ballasts have to 90 percent 

14 efficient if between 150 and 250 watts, and 92 

15 percent efficient if between 250 and 500 watts.

16 EISA also excluded fixtures with ballasts 

17 that met certain conditions, including regulated lag

18 ballast, 480 volt electronic ballast, and 150 watt 

19 ballast rated for both use in wet locations and for 

20 ambient temperatures above 50° Celsius. 

21 DOE is considering expanding the scope we 

22 just mentioned to cover new fixtures with lamp 

23 wattages 50 and above. DOE is not considering 

24 extending coverage below 50 watts, mainly because 

25 low wattage metal halide is often used to replace 
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1 less efficient lighting technologies like halogen. 

2 In contrast to EISA, DOE is considering covering the 

3 currently exempt 150 watt fixtures, based on 

4 feedback that they [had] become a serious loophole. 

5 In keeping with EISA, DOE has no plans to 

6 regulated lag ballasts, both because they are costly 

7 and unlikely to become a loophole, and because they 

8 account for such a tiny fraction of ballasts sold. 

9 DOE is not aware of any commercially available 

10 ballasts able to operate natively on 480 volts and 

11 is considering not covering those as well. 

12 DOE invites comment on this proposed scope 

13 of coverage.

14 MR. BROOKMAN: So there you can see the 

15 proposed possible expansion of scope. Comments on 

16 that? Joanna.

17 MS. MAUER: Joanna Mauer. We strongly

18 support the expansion of scope to the additional 

19 wattage range because I think the preliminary 

20 analysis shows there’s certainly potential for 

21 savings. We also support the coverage of the 150 

22 watt lamps for the reason that you noted, that seems 

23 like it may have become somewhat of a loophole. 

24 And for regulated lag ballasts, I think we 

25 encourage the Department to consider the possibility 
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1 of coverage and we understand the inherent -- that 

2 regulated lag ballasts may be inherently less 

3 efficient and a lower standard might be appropriate, 

4 but to consider potentially a separate product class 

5 for those ballasts. We don’t have much information 

6 about the market for those.

7 And I was wondering if you could comment 

8 on the rationale for the current exemption of the 

9 480 volt electronic ballast.

10 MR. COFFEY: Those ballasts were exempted 

11 by EISA, and the Department doesn’t know of any 

12 electronic ballast able to operate on 480 volts, but 

13 would certainly welcome comment with any information 

14 on that.

15 MR. BROOKMAN: Bob.

16 MR. ERHARDT: Bob Erhardt, Philips 

17 Lighting Electronics. Would like to point out that 

18 the allowance on the 150 watt ballast was because 

19 the 150 watt ballast was seen already as an energy 

20 savings for the 175 watt ballast that it replaces, 

21 and the 175 watt is a very popular outdoor ballast, 

22 and so this was not seen as a loophole, but rather 

23 as a way to realize energy savings to push people 

24 for a transfer from 175 to 150 watt.

25 MR. BROOKMAN: Okay. Thank you. 
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1 Additional comments on this possible expansion of 

2 scope and also the final bullet on this page, “No 

3 current plans to cover fixtures that use regulated 

4 lag ballasts.” Keith? No? Okay. 

5 Test Procedure

6 MR. COFFEY: So that brings us to the test 

7 procedure that I mentioned before, is based on the 

8 ANSI standard C82.6-2005. Manufacturers have 

9 suggested using an updated version of that once it’s 

10 available. Some commenters at the framework meeting 

11 had suggested it might become available in 2010, but 

12 as far as we know, it did not. The current C82.6 

13 has no provisions for testing high frequency 

14 ballasts, and there was a thought that the coming 

15 revision might address them.

16 One other point is that the test procedure 

17 is non-specific with respect to which input voltage 

18 should be used for testing when a ballast is rated 

19 for more than one, which many are. DOE is 

20 considering amending the test procedure to require 

21 testing at all input voltages, and reporting an 

22 average of the results. That’s the way that DOE 

23 derived efficiency when conducting its own testing 

24 for the preliminary analysis.

25 In addition to active mode testing, DOE --
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1 I’m sorry, EISA directs DOE to amend test procedures 

2 to include standby and off mode energy consumption. 

3 Standby mode means that the ballast is providing 

4 certain secondary functions, but not its primary 

5 function, so that doesn’t include dimming. In 

6 theory metal halide ballasts can be designed with 

7 auxiliary control devices that could consume energy 

8 in standby mode.

9 Fluorescent ballasts sometimes use a 

10 protocol called DALI -- digital addressable lighting 

11 interface -- but DOE hasn’t found that to exist in 

12 metal halide ballasts. 

13 And then off mode refers to a ballast 

14 being connected to a main power source but providing 

15 neither active nor standby mode function. DOE 

16 believes that off mode too isn’t relevant to metal 

17 halide lighting, and has tentatively concluded that 

18 it cannot establish a standard that incorporates 

19 either a standby mode or an off mode energy use.

20 So here we have some test procedure 

21 related request for comment. DOE requests comment 

22 on expected changes to ANSI C82.6 (2005) and on the 

23 status of the revised version of the document. DOE 

24 requests comment on whether it should amend its 

25 current test procedure for metal halide lamp 
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1 ballasts to include specification of voltage when 

2 testing for efficiency. Of particular interest is 

3 whether efficiency is affected by the voltage or by 

4 the number of operating voltages. 

5 DOE also seeks comment on any other 

6 appropriate changes to the current test procedure 

7 for metal halide ballasts based on findings from its 

8 preliminary analysis for metal halide fixtures. 

9 And then finally, DOE invites comments on 

10 issues of standby mode and off mode.

11 MR. BROOKMAN: Yes, please. Say your name 

12 for the record.

13 MR. GREEN: John Green. I’m on the ANSI 

14 C82.6 committee. That update to that standard is 

15 being prepared for a final voting, and it should 

16 probably be released by the end of the year. That’s 

17 no guarantee, but that’s the target at the moment. 

18 As far as what’s included in that, 

19 obviously we can’t share a lot of details until it’s 

20 been finalized, but it will address -- its major 

21 change is it will address the electronic ballast 

22 testing, so that should solve some of your issues in 

23 that regard. Very little, if any, changes to the 

24 magnetic testing. So it’s primarily focused on 

25 electronic, and should provide the test procedure 
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1 that you need.

2 MR. BROOKMAN: Thank you. Bob.

3 MR. ERHARDT: Bob Erhardt, Philips 

4 Lighting Electronics on issue ES-2. While the 

5 industry will prepare a industry response at a later 

6 date concerning average versus highest voltage 

7 testing, I will comment that the number of voltages 

8 on a electromagnetic ballast is affected -- does 

9 affect efficiency, because you are not able to 

10 optimize the number -- the wire size on the primary 

11 when you need to have multiple input voltages. So 

12 more voltages on electromagnetic ballast do tend to 

13 lower efficiency on at least one or another voltage.

14 MR. BROOKMAN: Thank you. Yes, Keith.

15 MR. COOK: Keith Cook, Philips. Bob’s 

16 absolutely right, but we also need to recognize that 

17 the market has really driven us to multiple tap18 ballasts because of inventory concerns. They only 

19 want to be able to get one skew. If we do optimize 

20 for a single voltage, it significantly addresses the 

21 cost problem.

22 MR. BROOKMAN: Okay. Yes, please. Susan.

23 MS. ANDERSON: Susan Anderson, OSRAM 

24 SYLVANIA. We also have a precedent set with the 

25 fluorescent ballast standards where we only tested 
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1 the highest rated voltage, so that’s an established 

2 precedent. And in view of the additional work 

3 impact, it would be cost impact on industry, we 

4 would prefer to see it follow the same path and be 

5 at the highest rated voltage.

6 MR. BROOKMAN: The Department really would 

7 appreciate your detailed comments in writing on that 

8 subject. Okay. Other comments? Has anybody 

9 addressed ES-3 yet? Keith.

10 MR. COOK: Keith Cook. Right now, NEMA 

11 agrees with the proposal on ES-3. We’re in 

12 agreement.

13 MR. BROOKMAN: Okay. Thank you for that. 

14 Other additional comments on these three comment 

15 boxes? Okay. 

16 Options for Fixture Standards

17 MR. COFFEY: So now we’ll talk about some 

18 other choices DOE might have for setting fixture 

19 standards. Just to remind everybody, although a 

20 fixture includes a lamp, ballast and an optical 

21 portion, EISA 2007 addressed only the ballast.

22 DOE is considering now whether amended 

23 standards should address the ballast only, the 

24 ballast and the lamp, or the ballast, lamp, and 

25 optical portion of the fixture. 
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1 A lamp ballast metric, that’s without any 

2 fixture consideration, would have the advantage of 

3 allowing manufacturer to pursue efficiency gains 

4 where they were most economical and allow 

5 optimization at the systems level. A fixture metric 

6 might have the further benefit of encouraging 

7 fixtures that absorb less light and distribute it 

8 more effectively. So let’s explore those two 

9 options.

10 Here’s the lamp-ballast system approach, 

11 which would entail setting a standard in terms of 

12 lamp lumens and ballast input watts. It wouldn’t 

13 measure what the ballast is outputting, as a ballast 

14 standard does, only what goes into the ballast and 

15 out of the lamp. The potential benefits, as I 

16 mentioned, were that manufacturers would have some 

17 flexibility to optimize wherever it was most 

18 economical to do so. And that some of the highest 

19 efficacy lamps might not be compatible with all 

20 ballast types. 

21 One example of that could be with ceramic 

22 metal halide, which DOE understands may be more 

23 efficacious over the life of the lamp, but unable to 

24 reliably operate on high frequency ballasts. DOE 

25 hasn’t preliminarily found that high frequency is 
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1 the only path to higher ballast efficiency, but if 

2 it were, then this could be an example of 

3 compatibility problem. 

4 A lamp ballast approach might sidestep 

5 this issue. Drawback to the lamp ballast approach 

6 might be that many fixtures are shipped without 

7 lamps and that DOE would need to specify how to 

8 assess compliance in those cases. One option could 

9 be to publish a table of standard lamps that contain 

10 default lamp efficacy values.

11 A second issue is that DOE is currently 

12 conducting high-intensity discharge lamps rulemaking 

13 that has the potential to conflict with any lamp14 based standards that this rulemaking sets. Some 

15 commenters at the framework meeting noted that this 

16 could present a compliance burden for manufacturers.

17 DOE invites comment on 

18 1. The specific lamp efficacy values that 

19 could be included in a table of standard 

20 lamps; 

21 2. examples of systems that could benefit 

22 from this approach; 

23 3. the manufacturer impacts and feasibility 

24 of a lamp-ballast system standard in 

25 addition to a lamp-specific standard that 
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1 could result from an ongoing HID lamps 

2 rulemaking; and then 

3 4. Whether consumers could and would relamp 

4 fixtures with lamps efficacious than those 

5 with which they were sold.

6 MR. BROOKMAN: Bob Erhardt.

7 MR. ERHARDT: Bob Erhardt, Philips 

8 Lighting Electronics. Yes, NEMA agrees that lamps -

9 - the system approach is a preferred approach for 

10 any rulemaking. We do agree with the potential 

11 conflict and difficulties with having two separate 

12 rulemakings between lamps and ballasts. There are 

13 some areas where a ballast can be labeled for a 

14 specific lamp, in particular, some of the newer 

15 lamps that are coming out that have higher efficacy, 

16 but that will involve some complexity on keeping 

17 ballasts and lamps consistent.

18 MR. BROOKMAN: Before you go on, are you 

19 speaking on behalf of your company or on behalf of 

20 someone else?

21 MR. ERHARDT: I believe these are -- this 

22 is what we’ve agreed to with NEMA, I guess.

23 MR. BROOKMAN: Thank you.

24 MR. ERHARDT: I was looking for my bullet 

25 points, but I’m trying to speak from memory, and I’m 
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1 trying to keep this NEMA --

2 MR. BROOKMAN: That’s fine.

3 MR. ERHARDT: -- approved. And 

4 considering relamp of fixtures, if a ballast and a 

5 luminaire is labeled for a particular lamp, that 

6 luminaire is only keeps its UL listing if that lamp 

7 is used. So if you did have a luminaire, for 

8 instance, that was labeled with a C type lamp 

9 designation, then if someone were to put an M type 

10 designation in there, they would risk voiding their 

11 UL listing. So it is possible, within some 

12 limitations, to specify the lamp type.

13 MR. BROOKMAN: Okay. 

14 MR. ERHARDT: I’m sorry, I was looking at 

15 the earlier 3.4 that I was also supposed to comment 

16 on, and I wasn’t ready for the 3.5.

17 MR. BROOKMAN: You’re doing good here, you 

18 want to keep going?

19 MR. ERHARDT: Which one haven’t I -- oh, 

20 now something that NEMA has done with ENERGY STAR 

21 and with fluorescent lamps is they have maintained a 

22 table of ballast and lamp efficacies such that a 

23 manufacturer -- a luminaire manufacturer knows that 

24 they must meet a certain lamp-ballast efficacy, they 

25 could take one from the NEMA database. We don’t 
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1 know if something like this would be acceptable to 

2 DOE.

3 MR. BROOKMAN: Okay. You see several 

4 issues called out there in ES-5. Additional 

5 comments on these? Yes, Bob.

6 MR. ERHARDT: Yeah, one more comment. On 

7 number two, there are some lamp-ballast systems that 

8 are out on the market that only operate with one 

9 specific lamp and one specific ballast and they can 

10 be impacted by some of the considerations that DOE 

11 is doing such that -- for instance, Philips has a 

12 system which I believe is the highest system 

13 efficacy system on the market that cannot operate on 

14 an high frequency ballast, and would not meet some 

15 of the ballast requirements that DOE is considering.

16 MR. BROOKMAN: So the Department would 

17 appreciate any additional comments on this. Okay. 

18 MR. COFFEY: So in addition to a lamp19 ballast standard, DOE has the option of setting a 

20 fixture-based standard. Fixtures can absorb 

21 significant amounts of light and also distribute 

22 light to places that aren’t useful to the 

23 application. That can be considered a type of 

24 inefficiency because lumens that required energy to 

25 produce aren’t doing anything useful. DOE looked at 
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1 a few different fixture metrics that could be used 

2 for setting fixture-based standards. A fixture 

3 efficiency is the simplest, taking into account the 

4 amount of light leaving a fixture, but saying 

5 nothing of light distribution. The problem with 

6 using fixture efficiency alone is that different 

7 applications require different light patterns, some 

8 of which are inherently less efficacious to produce. 

9 A fitted-target efficacy is a metric that 

10 we had been developing, and it took into account 

11 both the amount of light leaving the fixture and the 

12 rectangularity of the light pattern. The thought 

13 there is that in applications where you’re trying to 

14 illuminate a large surface with several fixtures, 

15 maybe a roadway, rectangles tile together more 

16 neatly than circular patterns would. Circular 

17 patterns might have dark and overlit areas that 

18 correspond to wasted lumens.

19 The problem with this approach is probably 

20 obvious, it’s that not all metal halide applications 

21 call for tiling together light patterns to 

22 illuminate large open spaces from above. 

23 The next one, unlike fitted-target 

24 efficacy -- target efficacy rating, TER, is a metric 

25 that NEMA had been developing that did have 
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1 different metrics for different applications. It 

2 was fairly complex, however, and the application 

3 definitions could be ambiguous. DOE doesn’t set 

4 standards by application, only by features of the 

5 equipment and given the huge variety of fixture 

6 types out there, it can be difficult to draw up 

7 definitions with the level of clarity and rigor that 

8 the government rulemaking requires.

9 So DOE explored some options for setting 

10 fixture-level standards, but ultimately found none 

11 of them satisfactory and decided to set standards --

12 or preliminarily decided to set standards for only 

13 the ballast, just as EISA did. DOE is aware that 

14 there could be some other metrics being developed 

15 and DOE welcomes comment on the details of those and 

16 generally on its decision not to use a fixture 

17 system approach.

18 MR. BROOKMAN: Keith.

19 MR. COOK: Keith Cook. As you’re well 

20 aware, this is an extremely complex issue and 

21 there’s other metrics beyond even the ones you’ve 

22 listed here that are under consideration. Due to 

23 the complexity of this nature, we’d like to just 

24 respond in written comments on this one.

25 MR. BROOKMAN: Okay. Additional comments 
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1 on this preliminary decision? No additional 

2 comments, okay, let’s proceed.

3 MR. COFFEY: So moving on. In addition to 

4 performance standards, DOE has the authority to set 

5 design standards that prohibit or mandate certain 

6 features on metal halide lamp fixtures. 

7 California’s Title 20 did this when it prohibited 

8 probe-start for its covered wattage range, and 

9 presented some pathways to compliance that called 

10 for sensors on fixtures. DOE is considering setting 

11 standards -- setting similar standards, particularly 

12 in the case of prohibiting probe-start. 

13 Although probe-start ballasts are fairly 

14 similar to pulse-start ballasts in efficiency, they 

15 operate lamps that are generally less efficacious, 

16 at least for some wattage levels. A consumer might 

17 opt to save energy while maintaining similar light 

18 levels by replacing probe-start fixtures of a 

19 certain wattage with either fewer pulse-start 

20 fixtures of the same wattage, or with the same 

21 number of pulse-start fixtures of a lower wattage.

22 DOE is not aware of probe-start ballasts 

23 having any advantageous features and views their 

24 prohibition as a possible path to energy savings.

25 So here’s some comment requests on this 
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1 design standard topic before we talk about how DOE 

2 breaks down its proposed scope of coverage into 

3 equipment classes. I’ll just read these.

4 DOE may consider a federal design standard 

5 similar to California’s Title 20 and requests 

6 comment on the feasibility of this action and the 

7 expected consumer preferences for occupancy sensors, 

8 dimming or reduced lamp -- reduced-wattage lamp 

9 pairings.

10 DOE also seeks comment on the expected 

11 change in lumen output and the initial efficacy when 

12 moving from regular to reduced wattage versions of 

13 lamps. Next one --

14 MR. BROOKMAN: Let’s pause.

15 MR. COFFEY: Sure.

16 MR. BROOKMAN: Let’s take comment on ES-6 

17 here, Keith.

18 MR. COOK: We really appreciate the DOE 

19 taking a look at this from a systems perspective. 

20 This is definitely headed in the right direction, we 

21 believe, but it is still a very, very complex issue 

22 and it’s something that is very difficult to really 

23 get our arms around, as again, you’re aware of. So 

24 we’d like to reserve comment on this one in our 

25 written comments, just due to everything this 
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1 encompasses, but we agree, it is the right 

2 direction.

3 MR. BROOKMAN: That’s helpful. Okay. 

4 Thank you. Yes, your name, please.

5 MS. JOYCE: Elizabeth Joyce, Pacific Gas 

6 and Electric. Just want to reiterate our support 

7 for DOE’s consideration of the Title 20 or Title 20-

8 type metric. We are reviewing information on the 

9 popular compliance pathways in California, in 

10 response to this standard and just general other 

11 feedback in responses to the standard, and we will 

12 be submitting that to DOE in our written comments.

13 MR. BROOKMAN: You’re gathering data and 

14 when will you have it?

15 MS. JOYCE: Hopefully by the time we 

16 submit our written comments for this, at least some 

17 preliminary information. The preliminary 

18 information that we’ve collected so far indicates 

19 that most fixtures that have gone through CEC 

20 Appliance database -- of those that do list their 

21 compliance pathway, which is only about a quarter of 

22 the total fixtures in the database, most prefer or 

23 are listed under either the reduced wattage 

24 requirement or under just a simple ballast 

25 efficiency metric. Not as many that are going for 
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1 the controls compliance pathway. We’ll look at that 

2 in more detail.

3 MR. BROOKMAN: Thank you. Bob Erhardt.

4 MR. ERHARDT: One comment concerning the 

5 California Title 20 controls requirement. There is 

6 a difficulty involved for the luminaire 

7 manufacturers the way the Title 20 is implemented, 

8 where it says that all pieces of the control system 

9 must be integral to the luminaire. And I believe 

10 that is one of the reasons that it is not being 

11 embraced. Our company would ask the DOE to consider 

12 that a simplified approach, having controllable 

13 luminaires, for instance, can account -- would allow 

14 -- encourage more dimming systems out there.

15 MR. BROOKMAN: Yes, Rebecca.

16 MS. RAINER: We do believe that this is 

17 going in the right direction, but I would as that 

18 DOE considers street lighting in its analysis and 

19 may treat it a little differently. There may be 

20 additional studies that need to be done with street 

21 lighting and dimming.

22 MR. BROOKMAN: Okay. Yes, please. It’s 

23 Cheryl, is it not? Yes.

24 MS. ENGLISH: Thank you, Cheryl English, 

25 Acuity Brands Lighting. The Title 20 approach has 
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1 pros and cons. Pros on it, it does add a lot of 

2 flexibility for manufacturers and designers. On the 

3 con side, that also adds complexity to the 

4 enforcement and reporting associated with it.

5 I also want to note that we have been 

6 working with CEC on something that was an error in 

7 the rulemaking, or in the standard. It has not been 

8 corrected, but the 336 to 500 watt reduced lumen 

9 lamp of 80 mean lumens per watt is something that is 

10 not achievable with products today, and so we’ve 

11 been working with CEC to try to get that corrected 

12 in the next rulemaking, so please do not keep that 

13 80 lumens per watt in the back of your mind as you 

14 proceed.

15 MR. BROOKMAN: Thank you. We’re still on 

16 ES-6. These are good comments. You want to lay out 

17 the other two comment boxes?

18 MR. COFFEY: Sure. It sounded like people 

19 started to address some of those topics, but here’s 

20 the second comment. DOE understands that metal 

21 halide lamps are often dimmed using bi-level 

22 capacitors in conjunction with relays, motion 

23 sensors or photocells. DOE requests comment on the 

24 cost of employing these methods to save energy, and 

25 on usage patterns that would allow DOE to estimate 
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1 the energy they could save.

2 And then the last issue is that DOE 

3 requests comment on mean lumen differences between 

4 probe and pulse-start lamps at 70, 250, 400, and 

5 1000 watts, and on any other information that would 

6 help it assess potential energy savings of 

7 prohibiting probe start.

8 DOE also requests comment on a design 

9 standard that prohibits probe start ballasts.

10 MR. BROOKMAN: Justin.

11 MR. NEUMANN: Yes, as it relates to the 

12 issue ES-10, as Keith stated previously, NEMA will 

13 be, because of the complexity of this, NEMA will be 

14 addressing this in the written comments.

15 MR. BROOKMAN: Thank you. And yes, 

16 please, Tom.

17 MR. HIRT: Tom Hirt, Hubbell Lighting. As 

18 far as ES-22 is concerned, you list four 

19 representative wattages, 70 watt and you’re 

20 comparing probe and pulse. There are no probe-start 

21 70 watt ballasts to consider at this point, so there 

22 are no differences. 250 and 400 are similar probe 

23 starts versus pulse-starts, probably in the range of 

24 eight to 15 percent energy savings of mean lumen 

25 outputs today. The 1000 watt probe versus pulse, 
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1 anywhere from zero to about eight percent, depending 

2 on the manufacturer. Small amount. 

3 As far as requests on design standards 

4 that prohibit probe-start, first of all, the EISA 

5 bill already bans probe-start between 150 and 500. 

6 There are virtually none -- very few that I know 

7 probe start ballasts 150 and below, or below 150, so 

8 that won’t do any good there. So the only place 

9 that’s open is above 500, and those ballasts by your 

10 own documents are pretty efficient anyway. The lamp 

11 performance is hardly any different, zero to maybe

12 eight percent for some people.

13 MR. BROOKMAN: Okay. Thank you. Other 

14 comments on these three boxes? Okay. 

15 MR. COFFEY: So we’ve overviewed the 

16 different options that DOE has for setting energy 

17 conservations standards, now we’ll discuss how DOE 

18 breaks down its scope of coverage.

19 Scope of Coverage

20 MR. COFFEY: DOE may establish separate 

21 equipment classes and evaluate separate standards 

22 for each equipment class. DOE divides covered 

23 equipment into classes by the type of energy used, 

24 the capacity of the equipment or other performance25 related features that justify different standard 
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1 levels, such as those affecting consumer utility.

2 EISA 2007’s set standards for metal halide 

3 lamp fixtures both by rated lamp wattage and by 

4 ballast type. There were separate standards for 

5 pulse-start, probe-start, and non-pulse start 

6 electronic. 

7 Here’s a summary of the different factors 

8 DOE considered using to establish equipment classes. 

9 Currently, DOE is considering setting standards only 

10 by wattage. DOE did consider input voltage, 

11 starting method, number of lamps per ballast, 

12 electronic configuration and circuit type, and any 

13 features related to fixture application, but is 

14 currently considering establishing equipment classes 

15 by wattage only. We won’t go through all the 

16 factors, but let’s look specifically at input 

17 voltage and wattage.

18 Here’s voltage. Most ballasts can operate 

19 at more than one. DOE explored setting equipment 

20 classes by input voltage, but found that there was 

21 no prevailing relationship between voltage and 

22 efficiency, and so preliminarily decided to include 

23 all voltages in a single equipment class. 

24 The one possible exception to the 

25 efficiency conclusion might be in the case of 
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1 ballasts that operate only at 480 volts, which 

2 commenters at the framework meeting had suggested 

3 might be a little bit less efficient, and which DOE 

4 found in testing to be very slightly so. If DOE did 

5 establish a separate equipment class for input 

6 voltages above 300, it would also need to specify 

7 how to consider ballasts that were operated at 480 

8 volts and at least one other voltage. There are a 

9 fair number of what we’ve been calling quint-input10 voltage ballasts that can operate at 120, 208, 240, 

11 277, and 480 volts. 

12 DOE is interested in information about 

13 efficiency variation with voltage and whether DOE’s 

14 test results are representative of the market. 

15 DOE also seeks comment on whether it would 

16 be appropriate to establish a separate equipment 

17 class for ballasts operating above 300 volts, and if 

18 so, why quint-input-voltage ballasts should belong 

19 in one class or the other.

20 MR. BROOKMAN: Justin.

21 MR. NEUMANN: Again, NEMA will address 

22 this in their written comments.

23 MR. BROOKMAN: Okay. Other comments on 

24 this one before we move on? Okay. 

25 MR. COFFEY: So here’s wattage. As I 
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1 mentioned earlier, DOE used only wattage to set 

2 equipment classes. Different applications require 

3 different light output, so [application has] an 

4 impact to consumer utility. Also ballast efficiency 

5 tends to increase with higher lamp wattages, and so 

6 DOE preliminarily decided to set classes by rated 

7 lamp wattage.

8 Here there on the table there are 50 to 

9 150, 150 to 250, 250 to 500, and above 500 watt 

10 classes. DOE seeks comment on the outlined metal 

11 halide lamp fixture equipment classes and on the 

12 different features of fixtures that may affect 

13 efficiency or utility -- I’m sorry -- and utility, 

14 including, but not limited to wattage, voltage, 

15 number of lamps per ballast, electronic 

16 configuration, and circuit type, starting method and 

17 features related to application. 

18 MR. BROOKMAN: Please.

19 MS. JOYCE: Elizabeth Joyce. Just wanted 

20 to ask DOE for a little more clarification on its 

21 decision to not separate product classes according 

22 to indoor versus outdoor use, since we understand 

23 that there’s some pretty big design differences that 

24 are necessitated by, for example, designing a 

25 fixture for outdoor use.
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1 MR. COFFEY: DOE doesn’t set standards by 

2 application, only by physical features related to 

3 the application. So if there are any, in the case 

4 of indoor and outdoor, DOE would certainly be 

5 interested in hearing comment on that.

6 MR. BROOKMAN: Eric Stas. Oh, sorry, I 

7 thought you were giving additional comment. Bob, 

8 please.

9 MR. ERHARDT: Yes. While NEMA will be 

10 supplying a more detailed response in written 

11 comments, there have been some comments from the 

12 industry that the 150 to 250 may require -- could 

13 benefit from further delineation, and perhaps even a 

14 formula approach I think was suggested somewhere 

15 else in the document.

16 MR. COFFEY: Sure. And we’ll actually 

17 present a little bit on that approach later today.

18 MR. BROOKMAN: Other comments on this 

19 specific issue related to wattage? Okay. Nothing 

20 additional?

21 Technology Options

22 MR. COFFEY: DOE identified a number of 

23 technology options that could be used to improve

24 efficiency. The left-most table corresponds to 

25 magnetic ballasts, where you can increase efficiency 
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1 by using better cores field, copper in place of 

2 aluminum wiring, increase core stock height to a 

3 point, and increase conductor cross-section to a 

4 point, or simply by substituting an electronic 

5 ballast.

6 The right-most table corresponds to 

7 electronic ballasts, and here we can either use 

8 lower loss componentry -- so that’s diodes, 

9 capacitors, transistors, et cetera -- or we can have 

10 optimization at the systems level with better 

11 integrated circuit designs.

12 DOE requests comment on the feasibility, 

13 performance improvement, and cost of these 

14 technology options, as well as on any recent 

15 developments in their maturity. DOE considers these 

16 technology options further in the screening analysis

17 MR. BROOKMAN: Bob Erhardt.

18 MR. ERHARDT: Bob Erhardt, Philips 

19 Lighting Electronics. Concerning improved core 

20 steel, many of the designs already are using the 

21 best laminated steel. There’s been some discussion 

22 in the document, and we had it within the industry, 

23 on amorphous materials, those involve a completely 

24 different manufacturing process and would be not 

25 practicable to implement. 
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1 The increased stack height and increased 

2 conductor cross-section have limitations as the 

3 current luminaires are designed for a given form 

4 factor, and increasing the size of the ballast may 

5 render it no longer useful.

6 And there’s a similar issue with 

7 electronic ballast. Electronic ballasts are not 

8 direct-to-replacements for electromagnetic ballasts. 

9 They do not have the same form factor, and almost 

10 always require a luminaire redesign.

11 MR. BROOKMAN: Thank you. So you see 

12 there the two different options that DOE requests 

13 comment on. Additional comments? No additional 

14 comments? Okay. 

15 MR. COFFEY: So DOE identifies those 

16 technology options in the Market and Technology 

17 Assessment. 

18 Screening Analysis

19 MR. COFFEY: And then in the Screening 

20 Analysis, the technology options are screened on the 

21 basis of four criteria:

22 • technological feasibility;

23 • practicability to manufacture, install and 

24 service;
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1 • adverse impacts on product utility or 

2 availability to consumers; and

3 • adverse impacts to health and safety.

4 DOE is not aware of amorphous steel being 

5 used in ballast commercially, however it’s been used 

6 in prototypes and used widely in other products. 

7 Distribution transformers is one example, and 

8 therefore DOE did not screen out amorphous steel.

9 To summarize, DOE didn’t screen out any of 

10 the technology options we’ve discussed, and invites 

11 comment on whether amorphous steels and electrical 

12 components more efficient than those currently used 

13 in ballasts are technologically feasible and 

14 practicable to manufacture.

15 MR. BROOKMAN: Bob Erhardt. Unless --

16 Justin, you want to speak first?

17 MR. ERHARDT: Yeah, Bob Erhardt. NEMA 

18 will be supplying detailed written analysis, but 

19 again, amorphous steels require completely different 

20 manufacturing process and most electronic ballast do 

21 use some of the highest levels of components already 

22 in order to handle temperatures, et cetera.

23 MR. BROOKMAN: Anything additional, 

24 Justin?
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1 MR. NEUMANN: No.

2 MR. BROOKMAN: So -- okay. Thank you.

3 MR. COFFEY: That concludes the screening 

4 analysis, and I’ll invite my colleague, Matthew 

5 Walker up to discuss the engineering.

6 MR. BROOKMAN: So let me invite again, 

7 those that are joining us via the Web, please do 

8 submit your questions if you have any. Great.

9 Engineering Analysis

10 MR. WALKER: Hi everyone. My name is 

11 Matthew Walker, and let’s get started with the 

12 engineering analysis. Engineering analysis uses the 

13 design options and market information we’ve just 

14 talked about from the screening analysis and market 

15 technology assessment to develop a cost-efficiency 

16 relationship for each equipment class. This cost17 efficiency information is then passed to subsequent 

18 life-cycle costs and national impacts analyses.

19 This slide goes over the basic methodology 

20 used for an engineering analysis. DOE begins by 

21 choosing representative wattages and fixtures to 

22 serve as characteristic of the entire equipment 

23 class. Then DOE looks and defines characteristics

24 of models in each equipment class which will serve 

25 as baseline references to assess changes due to 
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1 energy conservation standards. Then DOE identified 

2 more efficient substitutes from a database of 

3 commercially available metal halide ballasts, then 

4 develops candidate standard levels, or CSLs that 

5 span the range of efficiency from the baseline to 

6 the max tech -- the maximum technologically 

7 feasible. And finally, DOE determines 

8 manufacturer’s selling prices for the baseline 

9 fixtures and their more efficient substitutes. 

10 So we’ll move to the first step, which is 

11 selecting the representative wattages and fixtures. 

12 So within each equipment class DOE identified a 

13 ballast that operated a particular rated lamp 

14 wattage to analyze as the representative wattage. 

15 This wattage was used to characterize the cost and 

16 efficiencies associated with the entire equipment 

17 class. 

18 The representative wattage was selected 

19 based on it being the most commonly sold, and this 

20 was also based on availability in catalogs as well 

21 kind of confirming conversations with manufacturers 

22 during interviews. You can see these wattages in 

23 the third column from the left on the table on this 

24 slide. 

25 Then, in addition, based on comments we 
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1 received in response to the framework document, DOE 

2 also chose representative fixtures to be able to 

3 account for any changes in fixture cost with 

4 efficiency. For each equipment class, DOE 

5 identified commonly used fixture types based on the 

6 applications commonly served by the wattage range.

7 The fixture types identified are not meant 

8 to be an exhaustive list, but rather a 

9 representative group to take into account variation 

10 in fixture costs among the different fixtures used 

11 in that particular group. And so you can see these 

12 representative fixture types on the fourth column of 

13 the table.

14 And this brings us to our first request 

15 for comment in the engineering section, DOE is 

16 requesting comment on its selection of 

17 representative wattages, as well as the fixtures 

18 used for these equipment classes.

19 MR. BROOKMAN: Justin.

20 MR. NEUMANN: Again, NEMA will address 

21 this in the written comments. Susan has something 

22 to add. 

23 MR. BROOKMAN: Okay. Susan first.

24 MR. NEUMANN: We’ll go in depth in the 

25 written comments.
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1 MR. BROOKMAN: Thank you.

2 MS. ANDERSON: We do have one thing we 

3 want to point out to you is that in your second 

4 equipment class you chose the 250 watt, and the 250 

5 watt lamp is not a popular lamp because of its short 

6 life. The 175 is the much more popular one, and 

7 then once again, that’s one we’ve tried to drive 

8 toward the 150 watt and the reason we had the 

9 exception for the 150 watt ballast in the EISA.

10 MR. BROOKMAN: So noting that NEMA will 

11 supply detailed comments, you’re suggesting that 250 

12 be more like --

13 MS. ANDERSON: 175.

14 MR. BROOKMAN: Thank you. Okay. 175. So 

15 this is important, this early differentiating the 

16 equipment classes. Additional comments at this 

17 point?

18 MR. WALKER: I think Mimi has a -- your 

19 mic is on, I think.

20 MR. BROOKMAN: Mimi Gupta.

21 MS. GUPTA: Mimi Gupta, Navigant 

22 Consulting. So is there a significant efficiency 

23 difference between the 175 watt and the 250 watt?

24 MR. BROOKMAN: I guess I’ll -- Bob is 

25 going to try to answer that, and if not I’ll turn to 
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1 Susan if needed. Go ahead, Bob.

2 MR. ERHARDT: Bob Erhardt, Philips 

3 Lighting Electronics. As commented earlier, well, 

4 we as a company anyway, and I think industry in 

5 general, feel that there is significant -- there is 

6 a significant change in the efficiency -- ballast 

7 efficiency throughout that range from 150 to 250, 

8 and it’s worth looking at to have some further 

9 delineation and perhaps a formula type approach.

10 MS. GUPTA: Okay. 

11 MR. BROOKMAN: Okay Mimi? Yes. Okay. 

12 Any additional comments on this comment box. Susan, 

13 you’re okay? Okay. 

14 MR. WALKER: All right. We’ll move on to 

15 the next step, the second step, which is defining 

16 the baseline models. 

17 The baseline model will either just meet 

18 the current federal energy conservation standards 

19 and provide basic consumer utility, or it will 

20 represent the least efficient, commonly sold ballast 

21 where no standard exists.

22 DOE uses these baseline ballasts as 

23 reference points for measuring changes in life-cycle 

24 costs, energy savings associated with the adoption 

25 of standards.
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1 If you look at the table, you can see that 

2 all the baseline ballasts are of the magnetic, CWA 

3 circuit type. You can note that the 70 and 1000 watt 

4 representative wattages have no standard currently, 

5 so for those equipment classes DOE based the 

6 baseline efficiency on tested data. By contrast, 

7 for the 250 and 400 watt representative groups, DOE 

8 set the baseline efficiency equal to the federal 

9 standard that came from EISA 2007. 

10 In addition, each baseline ballast is a 

11 pulse-start unit. As Brian mentioned earlier, both 

12 probe and pulse-start magnetic ballasts can achieve 

13 about the same ballast efficiencies, but the pulse14 start ballast is sometimes hard -- can sometimes be 

15 part of a more efficacious system. So based on this 

16 observation, DOE is considering a probe-start 

17 baseline.

18 So again, like Brian was talking about 

19 earlier, a probe-start baseline will allow DOE to 

20 account for life-cycle cost changes and energy 

21 savings associated with the consumer making a 

22 transition from a higher wattage probe-start system 

23 to a lower wattage pulse or reducing the number of 

24 fixtures at the same wattage. 

25 DOE is only considering this additional 
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1 baseline for the 70 and 1000 watt groups because the 

2 existing EISA standards have effectively eliminated 

3 probe-start ballasts in the two middle wattage 

4 ranges.

5 MR. BROOKMAN: Tom first, then Susan.

6 MR. HIRT: Yeah, we commented a few 

7 moments ago that there are no 70 watt probe-start 

8 ballast systems out there, so we can’t -- there is 

9 no baseline for probe start, it’s all pulse start. 

10 1000 watt, there is a probe-start baseline. There 

11 isn’t much to be gained in efficiency because as 

12 you’ve noted that the 1000 probe-start ballasts are 

13 already a good 92 percent efficient anyway, and the 

14 ballasts are so similar, there’s very little to be 

15 gained, maybe a slight amount on mean lumens, but 

16 that’s about it.

17 MR. WALKER: Yeah, I think that would be 

18 the idea here with the baseline is to account for 

19 the difference in the lamp efficacy, because like 

20 you’re saying, I think we agree that the ballast 

21 efficiency is about the same.

22 MR. HIRT: And like I said, there are no 

23 70 watt probe-start.

24 MR. BROOKMAN: Susan.

25 MS. ANDERSON: No 70 watt probe-start 
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1 lamps or ballasts.

2 MR. BROOKMAN: Say it again. No 70 watt?

3 MS. ANDERSON: Probe-start lamps or 

4 ballasts.

5 MR. BROOKMAN: Thank you.

6 MR. WALKER: This is good to know because 

7 I had thought we had identified a few, but we’ll 

8 have to double check that.

9 MR. BROOKMAN: What is the lower end if 

10 it’s not 70 for probes?

11 MR. HIRT: The 150 is the true transition. 

12 There are a few 150 watt probe-start lamps and 

13 ballasts, but below that there are no probe start 

14 lamps or ballasts.

15 MR. BROOKMAN: Okay. Thank you. That’s 

16 good education. Additional comments on this comment 

17 box?

18 MS. GUPTA: Can I just ask a question, 

19 Doug?

20 MR. BROOKMAN: Yes, please, Mimi.

21 MS. GUPTA: Mimi Gupta. Is there like a 

22 technical reason for that or is it just an 

23 application related reason?

24 MR. HIRT: Yeah, there is a -- there is 

25 technical reason for that. Probe-start lamps, as 
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1 you know, have three terminals in the arc tubes, 

2 three electrodes, and frankly, as you get the arc 

3 tubes that small, there’s no room to put the third 

4 probe-start starting electrode into the seal, so 

5 they just go away. Plus your efficiency of the size 

6 of the seal that you need to put the extra electrode 

7 in there kills the efficiency of that lamp anyway, 

8 or the efficacy of that lamp. Ballasts could be 

9 built, but there’s no lamp that runs very well down 

10 there below 150.

11 MR. BROOKMAN: Susan, please.

12 MS. ANDERSON: Susan Anderson. When that 

13 whole family of the medium screw-base, low wattage 

14 metal halide lamps were introduced from the very 

15 beginning, they have always been pulse start. We 

16 never went down the probe start path.

17 MR. BROOKMAN: Okay. Good comments. 

18 Additional comments before we move on? 

19 MR. MYER: Sorry, I can’t see color. 

20 Michael Myer, Pacific Northwest National Laboratory. 

21 I’ll be working on the HID lamps so I’m just trying 

22 to understand. Are you saying there’s no low 

23 wattage, under 150 watt probe-start lamps at all?

24 MR. HIRT: Correct.

25 MS. ANDERSON: Yes.
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1 MR. BROOKMAN: I see four heads nodding 

2 yes among manufacturers around the table.

3 MR. MYER: Thank you.

4 MR. BROOKMAN: Thanks for that 

5 clarification. Additional comments or questions? 

6 Your name please.

7 MS. LANCASTER: Rebecca Lancaster with GE. 

8 One thing that might be confusing people is that in 

9 the catalogs for the fixture manufacturers, a lot of 

10 times the lamp designation for these lower wattages 

11 is M, for metal halide, instead of P for probe, but 

12 they’ve always had an igniter. So they’ve always 

13 been pulse, but if you look in a fixture 

14 manufacturer’s catalog for 100 watt, it’ll say 100 

15 watt metal halide, that is a pulse start.

16 MR. BROOKMAN: I guess maybe for the 

17 record we should note that in answering Michael’s 

18 question, Tom said yes, also the other Tom said yes, 

19 and Rebecca, maybe you did as well. Okay. Thank 

20 you. I just want to be clear. 

21 MR. WALKER: All right. So we’ll move to 

22 the next step, selecting more efficient substitutes. 

23 DOE tested about 50 metal halide ballasts to 

24 identify more efficient substitutes for the baseline 

25 products. They tested about four samples of each 
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1 ballast, and averaged measured efficiency at each 

2 input voltage, as well as averaging the test results 

3 for each sample to come up with a representative 

4 value for that particular model. 

5 So as you can see in the plot, we have the 

6 blue diamonds are the electronic ballasts, the green 

7 diamonds are magnetic ballast, and there is bit of a 

8 gap between the most efficient magnetic ballast that 

9 we tested and the least efficient electronic 

10 ballast. During interviews, manufacturers provided 

11 some information regarding the types of changes that 

12 could be required to increase efficiency of these 

13 magnetic ballasts. This involved inputs such as 

14 changes to the magnetic core types, that sort of 

15 thing.

16 This information allowed DOE to model the 

17 cost and efficiency of magnetic ballast within this 

18 gap to be able to create a full spectrum of cost and 

19 efficiency information for the engineering analysis. 

20 And one final thing that I want to note on 

21 this diagram is that we did not find any electronic 

22 ballasts at the 1000 watt level, and just want to 

23 point this out. 

24 This brings us to two issues for comment. 

25 So the first is the CSL-4 representative units for 
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1 the 250 to 500 watt group is a high frequency 

2 electronic ballast. The CSL-4 is the most efficient 

3 level that DOE looked at in the preliminary 

4 analysis. And we request comment on the 

5 appropriateness of using this high frequency 

6 electronic ballast as representative, particularly 

7 with respect to the compatibility concerns brought 

8 up earlier. And maybe someone can speak to the idea 

9 that perhaps a lower frequency electronic ballast 

10 could also achieve that level, and it just happened 

11 that we identified one that was high frequency. 

12 And I’ll just go ahead and bring up the 

13 second issue also, which is that DOE requests 

14 comment on its observation that electronic ballasts 

15 are not were not at the 1000 watt level and whether

16 or not this is technologically feasible, if it’s in 

17 development and maybe will come out some time soon? 

18 So, open up the floor.

19 MR. BROOKMAN: Bob Erhardt.

20 MR. ERHARDT: Bob Erhardt, Philips 

21 Lighting Electronics. NEMA feels that it is 

22 inappropriate to use a high frequency electronic 

23 ballast as a reference for rulemaking. Many of the 

24 more -- many lamps are not operable on high 

25 frequency. It’s not just a matter of finding 
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1 compatibility. Manufacturers have determined that 

2 many ceramic metal halide and some of the new 

3 highest efficacy lamps cannot be operated on high 

4 frequency.

5 Low frequency square wave in some 

6 instances can approach the efficiency of high 

7 frequency, but not in all cases. It’s a matter of 

8 the VAs input and the Vas output, so NEMA will have 

9 to supply a more detailed written response in this 

10 area, and if the DOE wishes to get more into 

11 specifics, we can comment further.

12 Concerning 1000 watt electronic metal 

13 halide ballasts, there are some very small niche 

14 markets where electronic ballasts have hand holds

15 (ph) but nothing in general lighting or area 

16 lighting.

17 MR. BROOKMAN: Okay. Thank you. Cheryl 

18 English.

19 MS. ENGLISH: Cheryl English, Acuity 

20 Brands. Another issue with regard to using high 

21 frequency ones as baseline is because in outdoor 

22 applications, temperature ambience and power quality 

23 may make those types of ballasts less reliable or 

24 unreliable in their application.

25 MR. BROOKMAN: Thank you. Keith.
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1 MR. COOK: Keith Cook. Even though you 

2 can find electronic at the 1000 watt, it does not 

3 show any efficiency improvement over the magnetic 

4 that’s already out there. It’s done for other 

5 reasons. It may be due to high definition TVs as an 

6 example, but it has nothing to do with efficiency.

7 MR. BROOKMAN: Okay. Yes, Rebecca.

8 MS. RAINER: Rebecca Rainer. I just want 

9 to emphasize, we said this before, but I do want to 

10 emphasize that electronic ballasts are not direct 

11 replacements for magnetic ballasts in the luminaire.

12 MR. BROOKMAN: Thank you. Yes, Bob 

13 Erhardt.

14 MR. ERHARDT: One more comment. As I 

15 indicated and just want to reiterate it, electronic 

16 ballasts are not a direct replacement due to form 

17 factor. There’s also the issue of reliability. Now 

18 the DOE did cite that there have been some cases of 

19 electronic ballast, and electronic ballasts are 

20 starting to make some inroads, but it is my 

21 understanding it is one with using additional 

22 circuitry that is not included in the cost price of 

23 the electronic ballast. Installations that I am 

24 aware of include an additional transient suppression 

25 unit that is not part of the cost of the electronic 
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1 ballast.

2 MR. BROOKMAN: Have we covered those two? 

3 I guess so. Okay. 

4 MR. WALKER: So let’s go to the 

5 development of CSLs. We kind of hit on this a 

6 little bit, but I’ll go ahead and go over the three 

7 main methods that DOE looks at.

8 The first is a bin approach, which you can 

9 see on the left-most plot, where a constant 

10 efficiency requirement is set for a specific bin or 

11 range of lamp wattages.

12 The second, which is seen on the far 

13 right, is develop a continuous equation across the 

14 entire wattage range that would relate output power 

15 of the ballast or lamp power to efficiency. 

16 And the third can be a hybrid of the two 

17 in which each equipment class is assigned its own 

18 equation.

19 So while bins could encourage production 

20 of products of the upper or lower bounds of the 

21 range, DOE preliminarily found that efficiency did 

22 not vary substantially within the equipment classes 

23 under consideration. Of course I think we have 

24 already heard a little bit of feedback on that 

25 already, that perhaps the 150 to 250 watt range 
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1 could benefit from an equation approach. We’re also 

2 thinking that another exception could be the 50 to 

3 150 watt range, the very low wattage ballasts.

4 So I guess at this time we would like to 

5 request specific comment on the different approaches 

6 that could be taken for setting standards across the 

7 wattage range.

8 MR. BROOKMAN: Bob Erhardt.

9 MR. ERHARDT: Bob Erhardt, Philips 

10 Lighting Electronics, speaking for NEMA. NEMA will 

11 be supplying more detailed analysis. Generally 

12 speaking, there is up to 500 watt level or so, there 

13 is always some variation -- there is a definite 

14 trend for higher efficiency as the wattage gets 

15 higher, but NEMA will go into this in more detail in 

16 its comments.

17 MR. BROOKMAN: Okay. Even though this is 

18 preliminary analysis, the Department appreciates 

19 when you can give them a sense of if they’re headed 

20 in the right direction. So that kind of a comment 

21 is helpful, even though we know that NEMA and others 

22 will supply detailed comments as well. Other 

23 comments on this issue box? 

24 MR. WALKER: All right. So this slide 

25 gives us a summary of efficiencies assigned to each
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1 CSL. DOE is requesting comment on these CSLs, in 

2 particular, whether they capture the full range of 

3 efficiency from the least efficient to the max tech, 

4 and whether any significant intermediate levels are 

5 missing or should be added. 

6 And then in addition, DOE believes that no 

7 CSL in this rulemaking requires the use of 

8 proprietary technology, and we are requesting 

9 comment on this conclusion.

10 MR. BROOKMAN: Bob Erhardt. 

11 MR. ERHARDT: Bob Erhardt, Philips 

12 Lighting Electronics. A comment would be that yes, 

13 these efficiency levels do represent the range of 

14 efficiency that could be expected, however, I would 

15 also comment that within a given range, there are 

16 certain, I’ll almost say “sweet spots,” where a 

17 certain lamp-ballast combination can have a higher 

18 system efficacy than others in the same class. It 

19 has to do with the factors of the lamp current and 

20 voltage, for instance, matching the total VAs of the 

21 system, how well -- how much step up or step down 

22 you need in your system. These will all influence 

23 the efficiency of the ballast.

24 So while one ballast in the 250 to 500 

25 watt range may be able to hit 93.9, that probably is 
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1 a high that may only be for the highest wattage 

2 ballast in that range, and would not be 

3 representative of what could be accomplished at 250, 

4 for instance. So the DOE should take this into 

5 consideration.

6 MR. BROOKMAN: Thank you.

7 MR. WALKER: Bob, do you think NEMA will 

8 be able to provide specific feedback on the sweet 

9 spots that you mentioned in the written comments?

10 MR. ERHARDT: I think that’s one of the 

11 things we’re going to attempt. This comes back a 

12 bit to the -- this is also part of the lamp-ballast 

13 system considerations, and it’s not easy. In fact, 

14 we’re very hesitant to make general comments on 

15 this, but NEMA will be making an attempt in the next 

16 week or two to come up with the best that we can in 

17 a detailed response.

18 MR. BROOKMAN: Okay. Joanna Mauer.

19 MS. MAUER: Just a question. Are the CSLs 

20 that represent the most efficient magnetic ballasts, 

21 are those based on conventional steel cores?

22 MR. WALKER: That’s a good question. In 

23 our analysis the most efficient magnetic ballast 

24 that represents -- that’s in these CSLs would be 

25 what we would call like a model ballast, so that 
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1 would be where we’ve taken input from the 

2 manufacturers on a change in the core material to 

3 improve the efficiency of a commercially available 

4 ballast. Does that clarify anything for you?

5 MS. MAUER: I guess the question is 

6 whether some of them are based on amorphous steel 

7 and whether DOE has evaluated the efficiency 

8 potential for using amorphous?

9 MR. BROOKMAN: Go ahead, Bob.

10 MR. ERHARDT: Yeah, I’ll make a couple 

11 general comments, speaking from my own company. For 

12 instance, in the 150 to 250 watt range, we have no 

13 electromagnetic ballast that can meet 88 percent --

14 I’m sorry, in the 110-150. At 175 we must -- we use 

15 M6, which is the best steel we can manufacture with. 

16 As you go up to the 500 watt range, you may not need 

17 M6 anymore, but this gets back into the fundamental 

18 VAs, the Volt-Amp ratings of the systems and how 

19 much you have to step up voltage et cetera, and what 

20 the current is with respect to the open circuit 

21 voltage. And so there is, you know, when you 

22 consider what materials are used in what ballast, 

23 well to make a 175 meet 88 percent, -- actually, 

24 when I addressed the California Energy Commission 

25 six years ago, I didn’t even think you could make a 
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1 88 percent magnetic -- electromagnetic ballast at 

2 175 watt. And well, when they went to the highest 

3 grade steel, and they just about doubled the size of 

4 the ballast, you could meet 88 percent. Of course 

5 it doesn’t fit into all applications then either. 

6 So, I was right and I was wrong, because what was 

7 considered to be the drop in -- at the time for 175 

8 -- you couldn’t make an 88 percent, but if you made 

9 it quite as bit, some luminaires, not all, could use 

10 that product.

11 Eighty-eight percent is -- I’ll stick my 

12 neck out again -- I’ll say that’s the limit for 

13 electromagnetic product at 175, and it cannot be 

14 accomplished at 150. Materials can have some impact 

15 at other wattages. 

16 MR. BROOKMAN: Tom, please.

17 MR. HIRT: Just the other part of all this 

18 efficiency is going back to all copper windings, and 

19 as you know if you follow the markets at all, copper 

20 has gotten extremely expensive and hard to get, so 

21 we’re heading in the direction that’s bad for 

22 industry by forcing thick copper back into these 

23 things to make the ballast more efficient. 

24 MR. BROOKMAN: Keith Cook.

25 MR. COOK: Two comments. One is --
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1 MR. BROOKMAN: Are you on?

2 MR. COOK: Yes. Sorry, need to get 

3 closer, I guess. The M6 that Bob referred to is 

4 also very, very expensive steel and is no longer 

5 produced in the United States. It’s mostly coming 

6 from China these days and so we have import 

7 problems. 

8 Second comment I have is I’d like to 

9 caution that this chart implies an accuracy due to 

10 the fact that it’s to a tenth of a percent, that may 

11 not be achievable. Repeatability and measurement 

12 accuracy will say that it may not make sense, and 

13 we’ve got classes that are less than one percent 

14 difference, and I really question that. It’s just 

15 not possible.

16 MR. BROOKMAN: What would you suggest that 

17 the Department do with respect to granularity?

18 MR. COOK: We’ll come back with some 

19 recommendations on that.

20 MR. BROOKMAN: Okay. Thank you. 

21 Additional comments on these candidate standard 

22 levels, both -- as you see both the specified or the 

23 possible equipment classes and the CSLs? No 

24 additional comments? Okay. 

25 MR. WALKER: So now we’re moving into the 
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1 final step of the engineering analysis, which is 

2 developing a manufacturer’s selling price. So first 

3 DOE has developed some manufacturer production costs 

4 based on its analysis of material, labor, factory 

5 overhead, and appreciation. The material and labor 

6 are determined using a tear down analysis that 

7 involves disassembling a unit, costing out 

8 individual components, and estimating appropriate 

9 labor costs for automatic versus manual insertion of 

10 components.

11 And then public information, such as 10-Ks 

12 and other information is used to estimate the 

13 overhead and appreciation. So that gives us a 

14 manufacturer’s production cost, or the MPC. Then a 

15 manufacturer markup is applied to bring the MPC to a 

16 manufacturer’s selling price.

17 The manufacturer markup was developed 

18 using publicly available financial information like 

19 the 10-Ks and input from manufacturer interviews to 

20 kind of -- to refine that number. There could be 

21 two main methods of applying this manufacturer 

22 markup, which was determined to be 1.47. 

23 First would be to assume that the ballast 

24 and empty fixture are manufactured by a single 

25 company. In this case, DOE would apply the markup 
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1 to both the production cost of the ballast and the 

2 production cost of the empty fixture, and together 

3 create a total MSP for that entire fixture.

4 The second situation could be where there 

5 are two companies, one company manufactures the 

6 ballast and the other company manufactures the empty 

7 fixture. In this situation, DOE could apply a 

8 markup to the ballast one time from the ballast 

9 manufacturer to the fixture manufacturer, and then a 

10 second markup would be applied to that ballast from 

11 the fixture manufacturer to the person they’re 

12 selling it to.

13 In the preliminary analysis, DOE modeled 

14 its markups on the first approach, which is applying 

15 a single markup of 1.47 to the ballast, and not 

16 doing it the second time.

17 There is no comment box on this slide. I 

18 think it’s a good time to seek comment on the 

19 methodology used, and the preliminary determination 

20 to just mark up the ballasts one time. I know this 

21 is a little complicated to talk about in words, I’ll 

22 be glad to clarify if it didn’t make sense.

23 MR. BROOKMAN: Tom? Question? Comment? 

24 Bob Erhardt.

25 MR. ERHARDT: NEMA will supply written 
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1 comments. This is just a -- I’ll almost make this a 

2 personal observation. I was involved in supply3 based management in my company for some time, and 

4 the DOE should consider that no manufacturer is 

5 going to carry the overhead of manufacturing their 

6 own ballasts if they could realize the same overall 

7 margin by buying one from the outside. So I do 

8 think it’s unreasonable to use a single markup on 

9 the ballast.

10 MR. BROOKMAN: Your comment suggests that 

11 this structure may not reflect the complexity of 

12 pricing decisions that a company might make?

13 MR. ERHARDT: Yes.

14 MR. BROOKMAN: Okay. Just please, your 

15 name.

16 MR. JOHNSON: Andrew Johnson. Just a 

17 comment. I heard several times, as you know, with 

18 magnetic ballasts we always have transient 

19 protection. But it’s really application related, so 

20 if it’s outdoor application, you need some transient 

21 protection; indoor application, it wouldn’t be 

22 required. And the other part, some of the newer 

23 ballasts have the integral transient protection 

24 built into them, so it wouldn’t add extra 

25 protection as it’s defined in the product.
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1 MR. BROOKMAN: Thank you. Did you say 

2 your name?

3 MR. JOHNSON: Andrew Johnson.

4 MR. BROOKMAN: Thank you. So this is 

5 important how the Department derives the 

6 manufacturer’s selling price, and these models, 

7 these representations, they matter to them. 

8 Additional comments on these -- this structure, 

9 these features? Okay. 

10 MR. WALKER: Okay. So now we’ll move to 

11 another slide on costing. We’ve gotten into this a 

12 little bit already, how electronic ballasts may need 

13 some modifications to the active replacements for a 

14 magnetic system.

15 So DOE considered a few of these 

16 additional cost adders, estimating that for 

17 transient protection, the end user cost could be 

18 somewhere between $30 and $70 dollars. We also are 

19 recognizing that thermal protection could be 

20 required for the electronic ballast as well as the 

21 idea that 120 volt taps are not available in all 

22 electronic ballasts and these 120 volt taps can be 

23 used to power auxiliary equipment, so again, there 

24 could be additional cost to adding this to an 

25 electronic ballast.
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1 So DOE is requesting comment on the 

2 thermal issues and other reliability concerns 

3 associated with electronic ballasts when used as 

4 replacements for existing magnetic systems.

5 It is also seeking comment on the cost of 

6 these additional items and the applications in which 

7 the measures would be necessary. We didn’t have --

8 we don’t have estimates of the heat sinking costs 

9 and the 120 volt tap cost to share right now, but 

10 we’d be interested in hearing some feedback as well 

11 as on the different applications in which they’re 

12 needed, maybe some where it’s not needed, that sort 

13 of thing.

14 MR. BROOKMAN: Justin.

15 MR. NEUMANN: Again, NEMA as an industry, 

16 will just address this in their written comments.

17 MR. BROOKMAN: Okay. Thank you. Rebecca.

18 MS. RAINER: Rebecca Rainer. Just a 

19 general comment. The items that you have listed do 

20 indeed impact our cost. One that you don’t list is 

21 UL certification when you switch from magnetic to 

22 electronic, you will have to recertify all your 

23 product. That is a very extensive cost on the 

24 manufacturer also.

25 MR. BROOKMAN: You see the comment box. 
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1 Thermal issues, reliability cost and applications, 

2 all of which the Department requests comment. Bob 

3 Erhardt.

4 MR. ERHARDT: Yeah, I just wanted to 

5 reiterate. There was a comment that some electronic 

6 ballasts already have transient protection for 

7 outdoor. Speaking for my company, I disagree with 

8 that.

9 MR. BROOKMAN: Sorry. Okay. So Susan, 

10 you want to say that for the record, or do you --

11 MS. ANDERSON: Andrew was speaking for the 

12 position of OSRAM SYLVANIA.

13 MR. BROOKMAN: Okay. Thank you. Andrew, 

14 yes, go ahead.

15 MR. JOHNSON: Yes, I thought that there’s 

16 a Philips outdoor ballast for street lighting that 

17 has transient protection built into it, so 10,000 

18 volts.

19 MR. BROOKMAN: So then, Bob Erhardt, go 

20 ahead.

21 MR. ERHARDT: There are -- in order to 

22 avoid issues in the field, most applications are 

23 employing additional transient protection.

24 MR. BROOKMAN: Okay. So it seems like 

25 we’re talking about a smaller subset of this. 
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1 Rebecca, go ahead.

2 MS. RAINER: Just a comment for the 

3 record. I am the Chairman of ANSI 136 which writes 

4 standards for the area and roadway lighting in the 

5 utility division. The requirement in ANSI 136 is 

6 10KV for outdoor lighting.

7 MR. BROOKMAN: Okay. 

8 MR. WALKER: Mimi has a comment or a 

9 question?

10 MR. BROOKMAN: Mimi.

11 MS. GUPTA: Mimi Gupta, Navigant. I have 

12 a question for you, Rebecca, related to the UL 

13 certification. If you’re switching from a lower 

14 efficiency magnetic ballast to a higher efficiency 

15 magnetic ballast, does that require new UL 

16 certification?

17 MS. RAINER: Any change to the ballast or 

18 the electricals of a product, if it has any bearing 

19 on the thermal issues, yes, it will require 

20 additional testing.

21 MR. BROOKMAN: Is it -- a full 

22 recertification or is it a nudge, for lack of a 

23 technical term?

24 MS. RAINER: It would depend on the 

25 product. Sometimes it could very well be a full 
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1 recertification. Sometimes it will be simply 

2 opening the file, retesting and recertifying the 

3 data.

4 MR. BROOKMAN: Okay. Bob.

5 MR. ERHARDT: Just one comment again on 

6 transient protection. Ten KV is an outdoor 

7 requirement. Electromagnetic ballasts can withstand 

8 anywhere from -- at least some product -- some of 

9 our product has been tested from 15 to 20 KV 

10 transient protection, transient capability, and so I 

11 still am speaking for our company, of the opinion 

12 that electromagnetic product, even when electronic 

13 product has ten KV capability, electromagnetic 

14 product is still more robust.

15 MR. BROOKMAN: Okay. So yes, Cheryl 

16 English.

17 MS. ENGLISH: Cheryl English, Acuity 

18 Brands. On the UL recertification question, I think 

19 it’s also important to note that we’ve mentioned a 

20 lot of extras are not just drop-ins, so there’s the 

21 engineering time associated with redesigning a 

22 ballast housing, the testing associated with that, 

23 the in-house engineering, the extra cost of the 

24 fixture. And then UL is not one of the fastest 

25 certifying organizations or CSAs, so there is 
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1 certainly a lag to market in our ability to get 

2 those products out quickly to the marketplace.

3 MR. BROOKMAN: Thanks. Okay.

4 MS. GUPTA: Doug, can I just make a quick 

5 note? 

6 MR. BROOKMAN: Mimi, please.

7 MS. GUPTA: Mimi Gupta, Navigant. So for 

8 this comment I think what’s most important for us is 

9 -- we’re aware that there are some of these issues, 

10 but getting the actual costs to these issues so that 

11 they can be taken into account in the analysis 

12 appropriately is what we’d really like comments on. 

13 So I know you guys are going to be submitting 

14 written comments later, but if that’s something you 

15 could provide to the Department of Energy, I think 

16 that would be really useful.

17 MR. BROOKMAN: Keith, go ahead.

18 MR. COOK: We understand that, but due to 

19 antitrust laws, it’s very, very difficult for us to 

20 address those issues.

21 MR. BROOKMAN: Even aggregated at NEMA, 

22 huh?

23 MR. COOK: We’ll take a look at it, but 

24 it’s still very difficult because in order to 

25 aggregate it, we have to discuss it, and we’re not 
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1 allowed to do that, so --

2 MR. BROOKMAN: It can be disclosed, though 

3 -- I mean it can be -- well, it would be good if you 

4 could do it.. Bob.

5 MR. ERHARDT: Bob Erhardt, Philips

6 Lighting and Electronics. Also a general comment. 

7 If one looks at the industry in general, given that 

8 to implement electronic ballast luminaires need to 

9 be redesigned, if you go to Lightfair you’ll see 

10 that many, if not most luminaire manufacturers are 

11 dedicating their engineering resources to 

12 implementing other technologies rather than 

13 redesigning mature ones. And if you’re going to put 

14 a requirement that luminaire manufacturers redesign 

15 their mature technologies, you may be precluding 

16 them from developing new products using SSL and 

17 dimming systems and other areas where the industry 

18 has been concentrating its effort.

19 MR. BROOKMAN: Okay. All productive 

20 comments. Additional comments before we move on? 

21 MR. WALKER: All right. So this last 

22 slide of engineering summarizes the manufacture 

23 production costs of the ballast component and the 

24 empty fixture component, as well as the overall 

25 fixture MSP. This is done as an example with the 
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1 equipment class for the 250 to 500 watt group. 

2 Notice that the ballast price has a fairly large 

3 increase from CSL-2 to CSL-3, and this represents 

4 the transition from magnetic to electronic ballast. 

5 You can also see that the MP fixture cost does not 

6 change with efficiency in the preliminary analysis. 

7 Now we’ve received a lot of comments today 

8 about how that may not be the case in electronic

9 [?], but the fixtures for electronic ballasts may 

10 need to be redesigned. 

11 DOE based this preliminary determination 

12 on its analysis where it was able to insert a ... in 

13 which an electronic ballast could fit in a fixture 

14 that it tore down, and it found that there was ample 

15 space. It also found that there was a variety of 

16 weights involved with magnetic and electronic 

17 ballast and some electronic ballasts actually tended 

18 to be of a smaller mass than the magnetic ballast.

19 So based on this, the empty fixture cost 

20 is kept the same for all of the CSLs, and it was 

21 based on a tear down of the representative fixtures 

22 that we talked about earlier, and all those costs 

23 were averaged together. 

24 So at this time we would request comments 

25 on these costs and prices as well as in particular, 
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1 the maximum technologically feasible ballast 

2 efficiency and its associated MSP, especially if 

3 it’s not listed here on this table or on other 

4 tables. That’s all.

5 MR. BROOKMAN: Justin.

6 MR. NEUMANN: Again, we’ll address this in 

7 our written comments to go more in depth here.

8 MR. BROOKMAN: Thank you. Additional 

9 comments on this table, a lot of content here. No 

10 additional comments at this time. Okay. 

11 So then let’s take a break. It’s now 

12 10:33 by my watch, so let’s call it 10:30. Let’s 

13 try for 15 minutes, which means we’ll resume at 

14 10:45.

15 While you’re here in the Forrestal 

16 Building you need to wear this visitor’s badge and 

17 you need to have it visible, so please make sure you 

18 do that. There are restrooms at both ends of the 

19 hall. There is a coffee shop on the ground floor, 

20 almost directly beneath us. If you go to the 

21 elevator bank and down to the ground floor. Please 

22 don’t wander far. And they’re not very efficient 

23 down there now. They changed over the service 

24 orientation and so go quickly if you want coffee.

25 (Whereupon, the meeting was recessed for a 
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1 16 minute period.)

2 MR. BROOKMAN: We’ll resume here. We are 

3 on the -- in the printed version, on slide 42. Are 

4 the Web [participants] ready to go? Let me 

5 encourage those that are joining us via the Web, 

6 we’re prepared today to try to answer questions 

7 coming over the web, so please feel free to do so.

8 We’re going to move directly into energy 

9 use, mark-ups analysis, and hear from Michael Myer.

10 Energy Use and Mark-ups Analysis

11 MR. MYER: Great, I’ll wait one second 

12 just to finish sitting. 

13 (Pause.)

14 MR. MYER: Great, looks like everyone is 

15 sufficiently hydrated, and if someone comes in late, 

16 we’ll see how efficient the coffee shop is as Doug 

17 professes. We’re starting energy use, mark-ups 

18 analysis, which will feed into the life cycle and 

19 payback analyses.

20 This graphic shows the relationship to 

21 each other, where the energy use -- how often a 

22 fixture is used and the energy consumed, multiplied 

23 by electricity price will feed into life cycle cost. 

24 The markup of the equipment will also factor into 

25 both the life-cycle cost and the payback analyses.
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1 Energy is pretty straight forward. It’s 

2 power multiplied by operating hours. DOE developed 

3 this input power -- you’ve seen these values earlier 

4 in the slides, but here they’re all presented 

5 together. On the left hand side you have the 

6 representative wattage class, and on the right hand 

7 side, you have the baseline and corresponding CSL 

8 and the ballast input power. I think too new at 

9 this point in the presentation.

10 Moving to the next slide. DOE developed 

11 average annual operating hours by looking at a 

12 variety of sources. One is the LMC, which is the 

13 Lighting Market Characterization, which is a survey 

14 of installed equipment and fixtures. CBECS, which 

15 is the Commercial Building Energy Consumption 

16 Survey, which is how buildings use -- how buildings 

17 are operated and energy usage of those buildings. 

18 And then MECS, which is the Manufacturing Energy 

19 Consumption Survey, which just dictates -- helps 

20 determine the probability of a certain building type 

21 existing.

22 DOE then takes those data sources and 

23 aggregates it, along with census data, to take care 

24 of regional differences in population, and DOE 

25 developed average annual operating hours shown in 
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1 the table below by sector on the left, and average 

2 annual operating hours on the right, in hours.

3 Moving into the next slide, that data in 

4 the last two tables multiplied together, so you have 

5 the power I showed two slides ago, and the average 

6 annual operating hours shown in the previous slide 

7 multiplied together, and you get the annual energy 

8 usage. 

9 So, on the left hand side again, we have 

10 the representative wattage and the baseline CSL on 

11 the right hand side. All values here are in 

12 kilowatt hours. Pretty straightforward.

13 And moving into the next slide. This 

14 brings up issue ES-27, DOE is requesting comment on 

15 the methodology and the assignment that we used, 

16 using Lighting Characterization as a data source, 

17 using Commercial Building Energy Consumption Survey 

18 as a source, using the Manufacturing Energy 

19 Consumption Survey as a source. DOE welcomes 

20 comment on the basis and assignment of the end user 

21 operating profiles for the fixtures covered in this 

22 rulemaking.

23 MR. BROOKMAN: Justin.

24 MR. NEUMANN: It’s my favorite response, 

25 we will address this in our written comments.
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1 MR. BROOKMAN: I know the Department’s 

2 looking forward to that.

3 MR. NEUMANN: You just record it and every 

4 time I raise my hand, you play it, that’d be good.

5 MR. BROOKMAN: Just to elaborate on that, 

6 I’m certain the Department would like those comments 

7 sooner rather than later.

8 MR. NEUMANN: Yeah, we’ll work on it. To 

9 be frank, the short timeframe between the publishing 

of the Federal Register

13 MR. BROOKMAN: But they’re on a tight 

14 timeline as well, as you know. Bob.

10 document and this meeting 

11 gave us very little time to prepare our comments for 

12 the public meeting.

15 MR. ERHARDT: Yeah, the other comment is 

16 we are also just a little bit occupied with the 

17 fluorescent rulemaking happening at the same time.

18 MR. BROOKMAN: Yeah.

19 MR. ERHARDT: And the California Energy 

20 Commission Title 24 revisions, so this is -- we had 

21 three major sets of documents released within one 

22 week, and we’re trying to address them all.

23 MR. BROOKMAN: We appreciate that, and in 

24 fact we appreciate your diligence here as well. So 

25 then you see the comment box, and let’s see if we 
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1 can get any additional comments or early lead as to 

2 how the Department is doing with these tables, if 

3 there are any at this time. No additional comments. 

4 Okay. Great.

5 MR. MYER: Continuing on into the markup 

6 analysis. So DOE developed a markup analysis to 

7 relate the manufacturer’s selling price, which is in 

8 the lower left hand -- represented in this diagram 

9 in the lower left hand side, MSP. Of course it 

10 moves through the distribution channel, first to a 

11 wholesaler, then to a contractor, then sales tax 

12 added, and then you get the final product price. 

13 To determine the wholesaler markup, DOE 

14 used publicly available data from the Securities and 

15 Exchange Commission for 10K as we’ve discussed 

16 beforehand, and that’s how we determined the 

17 wholesaler markup which we’ll discuss in the next 

18 slide, as well as the other two markups.

19 So this slide shows the relationship 

20 between the baseline markup and the incremental 

21 markup. Let me first define those terms. The 

22 baseline markup is the markup associated with just 

23 the baseline equipment. The incremental markup is 

24 the additional markup applied to a more efficient 

25 version. So, for instance, if the fixture costs 
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1 $100 and a more efficient version costs $120, the 

2 first hundred dollars is applied the baseline, the 

3 additional $20 is applied to the incremental markup 

4 -- the incremental markup applies to the additional 

5 $20 dollars. 

6 Other information on this slide. Of 

7 course, sales tax is the same in both columns 

8 because it is applied in the same way in both 

9 situations. This data was developed looking across 

10 publicly available information of states sales tax, 

11 comes out to just over seven percent. 

12 Contractor markup, this is 13 percent. 

13 The Department of Energy uses in a number of 

14 lighting rules, and it would welcome any comments at 

15 this point.

16 And then you have the baseline markup --

17 then you have the electrical wholesaler markup. The 

18 difference -- the prime difference between the 

19 baseline is this is calculated by net sales over 

20 cost of sales, whereas the incremental markup is 

21 calculated by the operating profit divided by cost 

22 of sales. For that reason, that’s why the 

23 incremental markup is smaller than the baseline 

24 markup. I’ll hold for any comments on these values 

25 at this moment.
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1 MR. BROOKMAN: Would you restate what the 

2 difference between baseline and incremental markup?

3 MR. MYER: Sure. Baseline is calculated 

4 by taking the net sales dividing by the cost of 

5 sales, whereas the incremental markup is the 

6 operating profit divided by cost of sales. And 

7 that’s why it’s a smaller relationship.

8 MR. BROOKMAN: Thank you. Oh, Bob 

9 Erhardt.

10 MR. ERHARDT: Yeah, Bob Erhardt, Philips 

11 Lighting Electronics. Does the DOE have some 

12 documentation of how it comes up with a 13 percent 

13 markup for contractor, and 23 and five percent for 

14 the -- well, contractor markup and wholesaler 

15 markup?

16 MR. MYER: Yes, Chapter 7 of the Technical 

17 Support Document, Markup Analysis, discusses each of 

18 these three values separately. As I said before, 

19 the sales taxes we look at all the sales taxes for 

20 the states.

21 The wholesaler markup is looking at 

22 publicly available data that 10K is between from ... 

23 exists, and as a side note, you mentioned the 

24 fluorescent ballast rule already, they also have 

25 that same comment about the relation between what 
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1 DOE estimated and the accuracy. And in the 

2 fluorescent lamp ballast documentation and their 

3 public meeting’s next month, you’ll find out that 

4 there is a good correlation between DOE and their 

5 markup analysis for the electrical wholesaler.

6 For the contractor, the documentation, 

7 actually I would have to go back a couple rules. As 

8 I said, it’s a standard number that DOE has been 

9 using for a number of lighting rules, and I would 

10 have to go back to the original rule to find that 

11 supporting documentation, but it is a historic value 

12 that maybe needs re-evaluation.

13 MR. ERHARDT: Thank you.

14 MR. BROOKMAN: Thank you. Let’s go to the 

15 comment box.

16 MR. MYER: Yes, so this is issue ES-29, 

17 which we welcome any comments from anyone who knows 

18 whether or not these markups are typical, as well as 

19 metal halide lamp fixture pricing data that we could 

20 use to verify the markups as developed for the 

21 preliminary analysis.

22 MR. BROOKMAN: Justin.

23 MR. NEUMANN: NEMA cannot discuss this 

24 publicly because of antitrust issues.

25 MR. BROOKMAN: And will you, though, try 
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1 to send some stuff?

2 MR. NEUMANN: We will if we can. We will 

3 if we can.

4 MR. BROOKMAN: Thank you. Yes, Rebecca.

5 MS. RAINER: Just a general comment. The 

6 analysis that you did does cover many of our 

7 shipments or sales, but here also is another channel 

8 which is the utility channel that, in many times, is 

9 quite different than the channel that you have 

10 listed here.

11 MR. BROOKMAN: Can you say what the steps 

12 are in the utility channel, going back to slide 48?

13 MS. RAINER: There are different scenarios 

14 with different areas of the country. Many times, 

15 it’s the manufacturer direct to the actual utility. 

16 Sometimes it is the manufacturer to an electrical 

17 distributor to the utility.

18 MR. BROOKMAN: Okay. 

19 MR. MYER: So it appears that in that 

20 situation, the contractor in a manufacturer to 

21 distributor to utility, the contractor is 

22 sidestepped in that situation?

23 MS. RAINER: In most cases, yes.

24 MR. MYER: Thank you.

25 MR. MYER: And sales tax would be 
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1 applicable in either way, of course. 

2 MS. RAINER: Yes.

3 MR. MYER: Great.

4 MR. BROOKMAN: Could you say? Is that --

5 is that pathway a big chunk of sales?

6 MS. RAINER: I think it probably varies by 

7 manufacturer. For my company, yes, it is a pretty 

8 sizable portion of our sales.

9 MR. MYER: Sales of metal halide fixtures 

10 or outdoor roadway fixtures?

11 MS. RAINER: Well, sales of outdoor 

12 product. Of course it is all outdoor product, but 

13 metal halide does play a big part in that, yes.

14 MR. MYER: Thank you.

15 MR. BROOKMAN: Thank you. Additional 

16 comments. Let’s just see the comment box there. 

17 Okay. 

18 MR. MYER: At this point, our schedule 

19 we’d have lunch, and obviously we’re a little too 

20 early for lunch.

21 MR. BROOKMAN: We’re going to keep going.

22 MR. MYER: Great. So at this time, I’m 

23 going to introduce Scott Morris to discuss life24 cycle cost and payback analyses.

25 MR. BROOKMAN: Scott Morris.
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1 MR. MORRIS: Thank you, Michael. Good 

2 morning, everyone. If I appear nervous, it’s only 

because I had my 26th 3 birthday this morning and I’m 

4 nervous about being over a quarter of a century old. 

5 So I apologize.

6 MR. BROOKMAN: Be careful -- so what we’ve 

7 ascertained is that the presenter does not know the 

8 target audience.

9 MR. MORRIS: I had to just say it, I’m 

10 sorry.

11 MR. BROOKMAN: You’d better move quickly.

12 MR. MORRIS: I’ll get through it quick, 

13 don’t worry.

14 DR. KAARSBERG: I have to also note, it is 

15 the first day of Earth Week at the Department of 

16 Energy. Yay, Earth!

17 MR. BROOKMAN: Thank you, Tina. Okay. 

18 Onward. 

19 MR. MORRIS: Okay. Down to business.

20 Life-Cycle Cost and Payback Analyses

21 MR. MORRIS: The Life-Cycle Cost and 

22 Payback Analyses combine results from the 

23 engineering analysis, the energy use 

24 characterization, and the markups analysis to make 

25 comparisons between candidate standard levels within 
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1 equipment classes. The life-cycle cost analysis, as 

2 you can see, is also used as -- some of the results 

3 from the life-cycle cost analysis are used as inputs 

4 for the national impact analysis.

5 Life-cycle cost and payback periods are 

6 monetary means of comparing fixtures within 

7 equipment classes. Life-cycle costs are the total 

8 costs of ownership for a given fixture, and payback 

9 period calculations indicate how many years it takes 

10 to payback the -- for an individual consumer to 

11 recover the incremental cost differences between a 

12 baseline fixture and a more efficient fixture 

13 system.

14 The chart up here is best and easiest 

15 understood reading from right to left. The life16 cycle cost for a fixture is calculated by adding the 

17 total installed cost of a fixture to the sum of 

18 discounted annual operating costs across the 

19 lifetime of the fixture. The installed fixture 

20 costs include the equipment and labor associated 

21 with installing an entire lamp, ballast, and fixture 

22 system.

23 Annual ownership, in the middle here, 

24 annual ownership or operating costs include 

25 annualized lamp replacement costs, annualized 
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1 ballast replacement costs, and the cost of 

2 electricity for a fixture within a year. Note that 

3 the energy use characterization provides inputs to 

4 the annual operating costs and the markup analysis 

5 provides inputs to the installed fixture cost, which 

6 affects the initial price of a fixture.

7 One of the important inputs for the life8 cycle cost calculations includes lifetime 

9 assumptions for fixtures, ballasts, and lamps. 

10 Perhaps of most interest to DOE at this 

11 point is receiving input concerning assumed lifetime

12 values for interior and exterior fixtures. We 

13 talked earlier that DOE does not set standards by 

14 application, but in our analyses, we used 

15 distinctions between interior and exterior fixtures 

16 to develop life-cycle cost.

17 In -- sorry, at this point interior 

18 fixtures -- yes.

19 MR. COOK: Could you back up just one 

20 slide? I do have a comment on that.

21 MR. BROOKMAN: Keith Cook.

22 MR. COOK: I do think that you also need 

23 to incorporate possibly a cost for redesigning 

24 fixtures for subsequent years. It’s not included 

25 here and if, for some reason, you decide to go from 
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1 a magnetic ballast to an electronic ballast, there 

2 is a redesign cost that has to be captured.

3 MR. BROOKMAN: Thank you.

4 MR. MORRIS: Any further comments? Thank 

5 you. Okay. In the framework stage of this 

6 rulemaking, we received -- there were comments and 

7 discussions concerning ballast lifetimes, and DOE 

8 understood that magnetic ballasts last longer than 

9 electronic ballasts. In this case, 50,000 hours 

10 versus 30,000 hours for ballast lifetimes. And 

11 finally, given the relatively short lifetime of a 

12 ballast, and the relatively longer lifetime of a 

13 fixture, you can -- I guess it would be intuitive to 

14 think that during the lifetime of a given fixture, 

15 we would be replacing at least one ballast. And 

16 we’ll talk about the ramifications of that in a few 

17 minutes.

18 Now, the -- assumed values for lamp 

19 lifetimes come from the high-intensity discharge 

20 lamps determination, and that’s been discussed 

21 previously in that determination. Any further 

22 comments on this slide?

23 MS. MAUER: Joanna Mauer. I may have 

24 missed you saying this, but do you have a specific 

25 data source for the lifetimes of magnetic versus 
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1 electronic ballasts?

2 MR. MORRIS: Best I can tell, it would 

3 be from the framework stage of this rulemaking.

4 MR. MYER: DOE received comment during the 

5 framework portion of it that magnetic ballast had a 

6 longer life, so industry submitted comments on the 

7 estimated life between both magnetic and electronic 

8 ballasts. If there’s an industry representative who 

9 might be able to validate those values?

10 MR. BROOKMAN: Joe, please.

11 MR. HOWLEY: Actually I wanted to make a 

12 comment. This is Joe Howley from GE Lighting. Make 

13 a comment on the lamp lifetimes. The lamp lifetimes 

14 listed appear to be for vertical lamp operation, and 

15 this is one of the lighting technologies that is 

16 affected by orientation. When you burn them 

17 horizontally they will have a shorter lamp life, so 

18 this would provide a more aggressive idea of how 

19 long the lamps will last. A significant number of 

20 metal halide fixtures do operate the lamps 

21 horizontally, and would have a reduced lifetime. It 

22 would probably be averaged into your lifetime 

23 considerations.

24 MR. BROOKMAN: Thank you. Can you give me 

25 that estimate across the industry?
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1 MR. HIRT: Just a comment. It’s not true 

2 universally. One number that’s been used is the 

3 life is 25 percent shorter for many lamps. Some 

4 lamps, however, I know are rated not to reduced 

5 life. So there is a mixed bag, as you might expect.

6 MR. BROOKMAN: Thanks. That’s helpful. 

7 Joanna Mauer.

8 MS. MAUER: Joanna Mauer. Just one more 

9 question. I was wondering if anyone could comment 

10 on whether lamps operated with electronic ballasts 

11 have longer lifetimes than operated with magnetic 

12 ballasts?

13 MR. BROOKMAN: Tom?

14 MR. HIRT: I’ll try again. Yes and no. 

15 Some people rate them longer, some don’t. Some I 

16 think have already incorporated those electronic 

17 ballasts in some of their ratings, so it’s a very 

18 complicated situation, and it’s highly variable 

19 among manufacturers.

20 MR. BROOKMAN: The rating comes from the 

21 manufacturer?

22 MR. HIRT: Yes.

23 MR. BROOKMAN: I see.

24 MR. MORRIS: Can anybody offer comment on 

25 perhaps the ratio or the mixture -- the percentage 
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1 of fixtures that have longer and shorter lifetimes, 

2 and how it varies by equipment class or wattages?

3 MR. BROOKMAN: Joe Howley.

4 MR. HOWLEY: Perhaps NEMA could provide 

5 more information in our written comments. I don’t 

6 think we have anything right at hand right at this 

7 moment.

8 MR. BROOKMAN: Thank you. Okay. 

9 MR. MORRIS: Well, first of all, to Bob’s 

10 comment in the opening statements regarding the 

11 slight modifications in payback periods, to cut to 

12 the chase, the two versions that Bob was looking at, 

13 the difference between payback period was due 

14 primarily, well not primarily, it was due to 

15 differences in markups. During our quality 

16 assurance testing between two weeks ago and a week 

17 and a half ago, we discovered that we were using too 

18 high of markups. I let that, suffice to day itself. 

19 So we corrected for the over -- we corrected for the 

20 larger markups and that’s where that discrepancy 

21 came from.

22 The next three slides --

23 MR. BROOKMAN: Yes, Bob.

24 MR. ERHARDT: It wasn’t a small 

25 discrepancy. It was a factor of three.
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1 MR. BROOKMAN: And you don’t see that 

2 reflected in this table, Bob?

3 MR. ERHARDT: Well, you’re saying it’s due 

4 to, you know, 10 percent versus 5 to 20 percent 

5 markup, and it was a factor of 3 in payback period, 

6 so I don’t consider that to be a small discrepancy.

7 MR. BROOKMAN: Susan, please, the 

8 microphone.

9 MS. ANDERSON: There were payback periods 

10 as long as 15 years in the previous version, and 

11 then suddenly this version -- I discovered it in the 

12 document this past Friday.

13 MR. MORRIS: Well, yes, we appreciate you 

14 guys noting that. Markups can change a lot, so 

15 yeah, that was an oversight on my part and we 

16 corrected that -- those changes were incorporated 

17 about a week and a half ago, before we published the 

18 documents.

19 MR. BROOKMAN: What we see here is the 

20 most current version.

21 MR. ERHARDT: Thank you.

22 MR. MORRIS: Okay. So the next few slides 

23 discuss and give the results for the life cycle cost 

24 and payback period analyses. There are really four 

25 things to note, four things of importance.
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1 1. Whether the calculated life-cycle cost 

2 savings are positive or negative.

3 2. The calculated and available or 

4 unavailable, according the slides, payback 

5 periods.

6 3. The first primary reason for positive 

7 life-cycle cost versus negative life-cycle 

8 costs and available or unavailable payback 

9 periods, which is primarily due to 

10 substantial efficiency gains between CSLs 

11 within equipment classes.

12 4. And we’ve had some discussion about this 

13 morning; the second primary reason for 

14 these differences in positive and negative 

15 values due to a transition from magnetic 

16 to electronic ballast types, which is 

17 necessary as we increase CSLs.

18 So to be succinct, in the 70 watt, 250 

19 watt and 400 watt equipment classes, the higher 

20 efficiency fixtures use electronic ballasts. 

21 Electronic ballasts are shorter lived than magnetic 

22 ballasts. The equipment and the labor costs of 

23 replacing electronic ballasts more frequently 

24 overshadow the cost savings realized by reduced 

25 energy costs.
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1 To illustrate this point in terms of 

2 payback periods, the annual ownership or operating 

3 costs for fixtures with electronic ballasts are 

4 greater than the operating costs for fixtures using 

5 magnetic ballasts.

6 MR. BROOKMAN: Charlie Stephens.

7 MR. STEPHENS: Charlie Stephens. Is there 

8 some reason why you annualized the maintenance costs 

9 for that kind of a maintenance activity that’s 

10 actually incurred on a periodic basis -- seven, 

11 eight, nine years in some cases, at a time? It 

12 actually does -- I’m just wondering why you don’t 

13 use the capital replacement cost methodology there 

14 instead of annualizing this stuff. In a net present 

15 value kind of calculation, it makes it a fairly 

16 significant difference.

17 MR. MORRIS: I would agree with that. And 

18 perhaps for the sake of brevity, it would be best 

19 for me to respond in written comments, but I 

20 appreciate that thought and it’s something I’ve 

21 wondered about myself. Well, something we’ve 

22 considered, definitely.

23 MR. BROOKMAN: Okay. 

24 MR. MORRIS: The results for the 250 and 

25 400 watt equipment classes are similar to the 
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1 results in the 70 watt equipment class. Fixtures at 

2 lower CSLs, including the baseline, operate magnetic 

3 ballasts, and fixtures at the higher CSLs operate 

4 electronic ballasts.

5 MR. ERHARDT: Excuse me?

6 MR. MORRIS: Yes, sir.

7 MR. BROOKMAN: Bob. Go ahead, Bob.

8 MR. ERHARDT: Bob Erhardt, Philips 

9 Lighting Electronics. How does the -- I’m very 

10 confused by your life-cycle cost versus payback 

11 period ratios.

12 MR. MORRIS: Okay. 

13 MR. ERHARDT: How is it that baseline one 

14 has a life cycle cost savings of $26, and a payback 

15 period of three years, and baseline two has a cost 

16 of $24, which is less than two percent difference, 

17 and has almost a two to one difference in payback 

18 period? How do you come up with that?

19 MR. MORRIS: Good question. That’s 

20 primarily due to discounting of operating costs over 

21 time. So the idea that -- let’s see how I can put 

22 this briefly -- the idea that energy savings and 

23 more expensive costs today are worth more to you 

24 than they are in 20 years or 50 years from now. 

25 It’s simply an artifact of the calculations, and 
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1 discounting. Good question, though.

2 The 1000 watt equipment class is slightly 

3 simpler to look at than the other equipment classes. 

4 All fixtures in this equipment class, as we have 

5 discussed previously, operate magnetic ballasts and 

6 these -- this equipment class operates -- or the 

7 fixtures in this equipment class are inherently more 

8 efficient than lower wattage fixtures. 

9 So this brings us to Executive Summary 

10 issue 30. We talked about the assumed lifetime 

11 values for fixtures, ballasts and lamps, and DOE is 

12 especially interested in comments concerning the 

13 values for the equipment used in this rulemaking, 

14 whether they be fixture lifetimes, ballast 

15 lifetimes, or lamp lifetimes.

16 MR. BROOKMAN: So there you see all of 

17 these tables, and the comment box, so let’s see if 

18 we have any comments at this time. 

19 MS. JOYCE: Elizabeth Joyce. Just wanted 

20 to comment, it was previously mentioned that for 

21 electronic ballasts, they may improve the lamp life 

22 and improve lumen appreciation, and we’d like to 

23 suggest that DOE perhaps take that into account when 

24 considering electronic ballasts, that there might be 

25 a longer lamp life, necessitating fewer lamp 
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1 replacements.

2 MR. BROOKMAN: Thank you. Bob Erhardt.

3 MR. ERHARDT: Yes, it is true that some 

4 electronic ballast systems with lamps can have 

5 improved lumen maintenance. The difficulty is that 

6 there is not agreement from lamp manufacturers to 

7 rate their lamps differently, generically using 

8 electronic ballast. And speaking from my own 

9 company’s experience, some electronic ballasts can, 

10 in fact, lower lumen maintenance and not improve it.

11 MR. BROOKMAN: Thank you. Yes, Joe.

12 MR. HOWLEY: Joe Howley, GE Lighting. On 

13 the question of lamp failures, many manufacturers do

14 publish lamp mortality curves. The lamps do not all 

15 fail exactly at their rated lives, but they fail 

16 over a period of time based on a curve function. 

17 These are commonly available, you should be able to 

18 get some representative samples of lamp mortality 

19 curves if you’re trying to estimate lamp life 

20 failure mechanisms within your models.

21 MR. BROOKMAN: Thanks. You can see the 

22 comment box there, ES-30. Assume lifetimes, how 

23 they vary within representative equipment classes, 

24 et cetera. Other comments?

25 MR. JOHNSON: One more thought --
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1 MR. BROOKMAN: Andrew, I don’t think 

2 you’re on.

3 MR. JOHNSON: Andrew Johnson. In these 

4 calculations that there’s no mention of dimming. If 

5 we had the electronic ballast, we could do some 

6 dimming, or we could do dimming with magnetic 

7 ballasts too, that would affect some of the energy 

8 consumptions to consider.

9 MR. BROOKMAN: Thank you. Final comments 

10 on this issue box? Keith.

11 MR. COOK: Keith Cook. I’m not sure I 

12 really understand this question, because it implies 

13 that all equipment is used beyond their average 

14 lifetime, and that may not always be the case. For 

15 instance, renovation a lot of times, they may be 

16 replacing equipment that’s not that old, just that 

17 they want a fresh update, or they want higher 

18 efficiency. And so they’re replacing perfectly 

19 good, fairly new equipment sometimes. So I’m not 

20 sure that I necessarily agree with the way this 

21 particular question is being asked. It doesn’t 

22 always go beyond their average lifetime.

23 MR. BROOKMAN: Okay. 

24 MR. MORRIS: If I may, Doug?

25 MR. BROOKMAN: Yes, please.
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1 MR. MORRIS: That’s a good question, thank 

2 you. Something I should have mentioned earlier. In 

3 the preliminary analysis portion of this rulemaking, 

4 DOE assumed fixed lifetimes for life-cycle cost 

5 purposes for fixtures, and in the national impacts 

6 analysis -- we’ll talk about that in a minute -- we 

7 have assumed lifetime distributions for fixture 

8 lifetimes, which incorporate things such as early 

9 replacement of fixtures. And in the NOPR stage of 

10 this rulemaking, DOE will also consider 

11 distributions of lifetime -- distributions of 

12 fixture lifetimes for LCC purposes. So thank you 

13 for that point.

14 And as far as the last sentence there, I 

15 agree with you that sentence could be read to imply 

16 that everything lasts beyond their rated lifetime, 

17 where to your point, we are very aware that fixtures 

18 do not always last as long as they’re rated for, so 

19 thank you.

20 MR. BROOKMAN: Final comments on this? 

21 Yes, please.

22 MR. STEVENS: Mike Stevens, Georgia Power. 

23 Is electricity price -- is there details on what 

24 you’re using? Are we going to get details on your 

25 assumptions on the calculations?
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1 MR. MORRIS: Yes, absolutely. In the 

2 Chapter 8 technical support document, it goes 

3 through all the detailed electricity pricing, 

4 electricity price change forecasting that DOE used 

5 for the analysis. So everything and more than you 

6 want to know would be in Chapter 8.

7 DR. KAARSBERG: Can I make a comment?

8 MR. BROOKMAN: Yes, Tina.

9 DR. KAARSBERG: Hi, I have a comment 

10 that’s actually a little bit more related to what we 

11 were talking about earlier when we talked about 

12 different CSLs, different classes, and some of you 

13 raised the issue of indoor versus outdoor. And of 

14 course the answer is we don’t regulate by 

15 application – in- or outdoor applications.

16 However, I’ve been talking with our 

17 Counsel here, or exchanging notes, and he has 

18 indicated that you could regulate according to 

19 characteristics such as whether or not a fixture is 

20 waterproof, whether it’s reliable under a very wide 

21 range of temperatures, shatter proof, wind proof up 

22 to 50 miles an hour -- very specific types of 

23 characteristics could form a type of class as long 

24 as it’s according to specific characteristics.

25 He hasn’t shaken his head no yet, so I 
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1 guess I’m okay. But I just wanted to mention that 

2 because I do think it’s an important thing, given 

3 that a lot of these fixtures are used in outdoor 

4 applications. So I wanted to also encourage you, if 

5 you had any characteristics you would suggest to 

6 distinguish the indoor versus outdoor, that would be 

7 very helpful to us. Thank you.

8 MR. BROOKMAN: Okay. Thank you. So then, 

9 let’s proceed. 

10 National Impact Analysis

11 MR. MORRIS: Now we’ll talk about the 

12 National Impact Analysis. Whereas the life-cycle 

13 cost and payback period analyses calculate the cost 

14 of fixture ownership for an individual consumer, the 

15 national impact analysis calculates the energy 

16 savings and economic impact to the nation as a 

17 whole. In addition to a few inputs from the LCC 

18 analysis, the national impact analysis also requires 

19 another set of inputs. These are fixture shipments.

20 In overly simplistic terms, the shipments 

21 analysis multiplies the energy use and cost of one 

22 fixture, by the number of fixtures that will exist 

23 in the country during the analysis period, and the 

24 national impact analysis tells us how much energy 

25 and money the country could save as a whole, as a 
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1 result of an amended standard.

2 DOE used a three step process to calculate 

3 its shipments, so right now we’re going to focus on 

4 shipments, kind of that link between life-cycle cost 

5 inputs and national impact analysis.

6 • First, DOE used NEMA and the US Census 

7 Current Industrial Reports data to develop 

8 historical metal halide lamp fixture 

9 shipments.

10 • Second, DOE calculated an installed national 

11 stock of metal halide lamp fixtures.

12 • Finally, DOE developed future, projected 

13 fixture shipments and stock based on several 

14 quantities, such as fixture lifetimes, 

15 replacement and fixture growth rates or 

16 replacement growth rates, retirement rates,

17 and the rate at which other sorts of (new 

18 and/or existing) emerging technologies are 

19 encroaching and displacing the shipments of 

20 metal halide lamp fixtures.

21 To get into a little bit more of the 

22 technical jargon behind this, I’m going to turn to 

23 my colleague Michael Myer to talk about how we 

24 developed our shipments analysis.
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1 MR. MYER: Thanks, Scott. So the 

2 Department of Energy published in June 2010, the HID 

3 Lamps Determination. Of course HID lamps has been 

4 talked [about] on again and off again during this 

5 meeting. HID lamps cover metal halide lamps as well 

6 as other technologies.

7 The Department of Energy had robust data 

8 about HID lamp shipments from as early as 1990 all 

9 the way up to 2008. The census data was somewhat 

10 limited in that it stopped at 2001. By actually 

11 comparing the two sets of data, we found a pretty 

12 significant trend that roughly 37 percent of lamp 

13 shipments corresponded with the same fixtures 

14 shipments, despite ups and downs from year to year. 

15 And so we actually liked that, it seemed really 

16 good, so we used that value and carried it on 

17 through developing some historical values as well as 

18 projecting those values into the future.

19 This chart is base case shipments. Base 

20 case shipments in a graph. What it does is it 

21 assumes that in the absence of an amended or a new 

22 standard, you’ll notice, of course, the 250 watt and 

23 the 400 watt are in the same equipment class -- I’m 

24 sorry, wattage class, so that’s why the lines are 

25 superimposed over each other. This shipments graph 
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1 assumes that over time, emerging technologies or 

2 existing technologies will encroach somewhat on 

3 metal halide shipments at some point.

4 We heard during the framework analysis --

5 framework public meeting, that interior applications 

6 of metal halide had been replaced by linear 

7 fluorescents portion and from our own analysis, we 

8 would agree with that. We also are taking into 

9 account that over time, both new technologies, such 

10 as LED or induction or possibly new emerging 

11 technologies will encroach somewhat on metal halide 

12 shipments as well.

13 I’m going to hold here for a second.

14 MR. BROOKMAN: So why don’t you flip back 

15 to slide 62, since this is your logic. Any comments 

16 on either of these slides, 62 or 63?

17 MR. MYER: I want to just advance to the -

18 - actually this is --

19 MR. BROOKMAN: Bob Erhardt.

20 MR. ERHARDT: The previous slide, this 

21 slide.

22 MR. MYER: Yes.

23 MR. ERHARDT: Now you’ve indicated that 

24 your census data dropped in 2001 or 2008, so how do 

25 you get your projection of increased sales from 2014 
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1 to 2020?

2 MR. MYER: Well, actually, this graph 

3 would start in 2015, the effective date of the 

4 standard and goes up to -- predicts the future up 

5 until 2020 plus.

6 MR. ERHARDT: All right. And if you look 

7 at the chart, you have a significant growth between 

8 2015 and 2025, let’s say.

9 MR. MYER: Yes.

10 MR. ERHARDT: And I don’t know the census 

11 numbers from the last five years, but I know that T5 

12 and HO is making some inroads on interior metal 

13 halide, and I know that solid-state lighting is 

14 making some inroads in exterior metal halide. So 

15 I’m asking where are you getting your projection for 

16 an increase in metal halide sales from 2015 to 2025? 

17 It’s not clear to me that that would necessarily 

18 follow, based on those two trends that I just 

19 mentioned.

20 MR. MYER: I understand. So in the HID 

21 lamps determination, we projected the growth of HID 

22 lamps into the future, and in that we actually 

23 developed a similar curve. And again, in using the 

24 relationship -- that 37 percent of lamp shipments 

25 correlate to fixture shipments, we proposed that 
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1 relationship in the absence of more articulated 

2 data.

3 MR. ERHARDT: And Bob.

4 MR. ERHARDT: So how did you come up with 

5 your projection of increased HID lamp shipments?

6 MR. MYER: That’s a different rule, Bob.

7 MR. ERHARDT: Well, that’s the difficulty 

8 in having two separate rulemakings. From an 

9 industry point of view, it’s not clear, you know. I 

10 know that T5HO is making inroads on interior, and I 

11 know that solid-state lighting and T8 fluorescent is 

12 making inroads on interior high bay, and SSL is 

13 making inroads on outdoor.

14 MR. MYER: Yes, and that actually is what 

15 this graph tries to represent is that in the near 

16 term, when these newer technologies such as LED or 

17 induction are more expensive right now, probably in 

18 the near future, let’s say after 2020 or somewhere -

19 - probably around -- somewhere after 2020, they will 

20 actually become more cost effective, and you will 

21 see that slide. But in the near term, where they’re 

22 not as cost effective, you’ll still see some growth. 

23 And you’re shaking your head “no,” but that’s 

24 actually what we would actually request comment on 

25 32. This is just preliminary analysis, and DOE 
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1 would appreciate any prognostications into the 

2 future on shipments of metal halide fixtures, both 

3 the ups and downs of the technology. And we are 

4 projecting -- we have to project all the way out to 

5 2046.

6 MR. BROOKMAN: So, Rebecca.

7 MS. RAINER: I would say from my company, 

8 speaking on Cooper Lighting’s benefit, my chart 

9 would be very different than your chart as far as 

10 the 250 and 400, it would be very different. We see 

11 solid-state lighting progressing much more quickly.

12 MR. MORRIS: Both interior and exterior, 

13 or do you think the fluorescent will attack the 

14 interiors?

15 MS. RAINER: I think fluorescent on the 

16 interior side, and solid-state lighting on the 

17 outdoor side.

18 MR. BROOKMAN: So the ramp up to 2015 

19 would be a lot shallower?

20 MS. RAINER: Absolutely.

21 MR. BROOKMAN: Okay.

22 MR. MORRIS: But for the low wattage and 

23 high wattage?

24 MS. RAINER: I see more in that medium 

25 wattage range, but I also do see it in the lower 
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1 wattage. I think our chart would look much 

2 different than yours.

3 MR. BROOKMAN: Keith, perhaps --

4 MR. COOK: Keith Cook. I would agree with 

5 that also. I don’t see, in the medium and low 

6 wattage, and uptick. If anything, and at best, it 

7 would be flat, even with the growth being 

8 construction, it would be flat at best. And in the 

9 higher ones, I don’t see much upward growth, 

10 although there would be some.

11 MR. BROOKMAN: Okay. Thank you. That’s 

12 helpful to the Department to get that 

13 representation. Also, any additional details you 

14 can provide in writing. I saw Bob.

15 MR. ERHARDT: Yes, I was just -- I was 

16 going to make the comment that, you know, it’s hard 

17 to have a consensus opinion, but I have heard the 

18 arguments that in outdoor solid-state lighting 

19 already is cost-justified and that you’ll hear --

20 you’ll very much hear the same argument, and even 

21 that you can save energy and have a significant 

22 return on investment by going -- and this is another 

23 area where NEMA has made the general comment to the 

24 Department of Energy that we strongly support system 

25 approaches, because what is happening is a reason 
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1 that fluorescent is making such inroads on interior 

2 is because of dimmability, and the ability to have 

3 occupancy sensing. 

4 And if -- I mentioned, we’re 

5 simultaneously working with California Energy 

6 Commission on Title 24 regulation. They are almost 

7 abandoning their demands on Title 20 appliances, and 

8 they are focusing completely on systems approaches, 

9 saying that you must use controllable lighting 

10 everywhere, period. And our studies show 20 to 50 

11 percent improvements in energy savings using 

12 controllable lighting and we’re here talking back 

13 and forth about two and three percent energy 

14 savings. We see it as being counterproductive 

15 because if we are ever being forced to redesign 

16 mature product lines for two percent or three 

17 percent energy savings, and neglecting the 

18 opportunities for 20 to 50 percent energy savings, 

19 we see that as being counterproductive.

20 MR. BROOKMAN: Cheryl first.

21 MS. ENGLISH: Cheryl English, Acuity 

22 Brands Lighting. Michael, I know that some of us 

23 did provide cost information in these market trends 

24 through our Navigant manufacturer impact interviews. 

25 Was that factored into these analysis?
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1 MR. MYER: No --

2 MS. ENGLISH: Because I would say you 

3 might want to go back and look at the data that’s

4 already been provided, because I agree, I don’t 

5 think those charts represent what we’ve provided.

6 MR. BROOKMAN: Thank you. Keith.

7 MR. COOK: Keith Cook. Yeah, I would want 

8 to maybe build a little bit upon what Bob was 

9 saying. The fact that not only are we seeing the 

10 opportunity on interior changes due to controls, 

11 outdoor also. If you look at such cities as 

12 Raleigh, North Carolina, they have adopted a large 

13 control scheme, and the impact that has on each HID 

14 is significant, because of the fact that you don’t 

15 have instant start, and you don’t have good 

16 dimmability, and so the result is driving us to new 

17 technologies much faster than what you’d normally 

18 see.

19 MR. BROOKMAN: Thank you, Joe Howley.

20 MR. HOWLEY: Yes. One comment as I’m 

21 thinking about the analysis more. It sounds like 

22 the last fixture data you had ended in something 

23 like 2001. And you’re using the lamp data as a 

24 surrogate for fixture sales. We can discuss this 

25 within NEMA, but NEMA does track fixture sales, and 
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1 I believe the metal halide fixture sales -- looking 

2 at someone from the fixture section to --

3 PARTICIPANT: (comment off mic)

4 MR. HOWLEY: But is it directional? 

5 Wouldn’t be enough to be directional, though. Not 

6 metal halide versus high pressure sodium?

7 MR. MYER: So, Joe, do you still use that 

8 relationship? If we set granular fixture -- no? So 

9 can you use that relationship?

10 MR. BROOKMAN: So, Michael, restate what 

11 we just heard not on the record. Go ahead.

12 MR. MYER: So Joe Howley mentioned that 

13 one of the problems -- one of the limitations was 

14 that the census data stopped at 2001, which is true. 

15 But we had lamp data as current as 2008. We did 

16 request data and so we used the step-in wherein we 

17 married the two data together and tried to develop 

18 some ideas about shipments that way.

19 Joe then suggested to some of his NEMA 

20 colleagues who were manufacturers of lighting 

21 fixtures, we might be able to have some of that 

22 data. Lighting manufacturer said that data may 

23 exist, but not at the granularity that we need, 

24 because one of the issues is that it probably lumps 

25 HID technologies together and it may also, I’m 
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1 suggesting here, that it may not also break it down 

2 by other applications or -- as Tina mentioned, 

3 interior, you know, any of the features that we 

4 have, it might be almost too high level, but we’d 

5 still appreciate any data.

6 MR. BROOKMAN: That’s good. That was a 

7 good restatement. Excellent. So then additional --

8 MS. GUPTA: Can I ask a quick question?

9 MR. BROOKMAN: Mimi.

10 MS. GUPTA: This is Mimi Gupta, Navigant. 

11 Does NEMA track metal halide ballast sales by 

12 distribution channel? Like for example, OEM or --

13 MR. BROOKMAN: Bob.

14 MR. ERHARDT: Yeah, John and I were just 

15 trying to have a sidebar on that, and we’re not 

16 sure, but we’re going to check into it.

17 MS. GUPTA: Okay. That could be --

18 MR. ERHARDT: There may be a possibility 

19 from the ballast side to come up with some kind of 

20 numbers.

21 MR. BROOKMAN: Okay. Additional comments 

22 in this vein, related to the availability of data 

23 and the like?

24 MR. MYER: Which happens to be issues 31 

25 and 32, by the way.
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1 MR. BROOKMAN: Exactly. Did we state them 

2 adequately, Michael, or do you want to reemphasize 

3 them?

4 MR. MYER: Just to give everyone one more 

5 refresher. Issue 31 discussed DOE’s approach of 

6 correlating lamp fixture data with HID lamp data, 

7 and using that methodology, and we’ve heard comments 

8 on that. I’ll hold for a second.

9 Issue 32 has to do with prognostication

10 [?] into the future on the growth, decline and/or 

11 plateauing of metal halide fixtures, which we’ve 

12 also heard some comments on as well.

13 MR. BROOKMAN: So there you see 31 and 32. 

14 Additional comments? Okay. 

15 MR. MYER: Thank you. At this time, I’ll 

16 turn the presentation back to Scott Morris.

17 National Impact Analysis - Wrap up

18 MR. MORRIS: Thank you, Michael. We’re in 

19 the final stages of wrapping up the national impact 

20 analysis. 

21 So the assumptions for everything that 

22 we’ve kind of discussed from DOE’s perspective are 

23 found in Chapter 9, the shipments analysis.

24 Now, as previously mentioned, the life25 cycle cost and shipments analyses feed into the 
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1 national impact analysis. The national impact 

2 analysis outputs two important quantities of 

3 interest, one of those is national energy savings, 

4 the other is national net present value.

5 National energy savings is expressed in 

6 terms of quadrillion BTUs or quads, and the economic 

7 effect to the nation or the net present value is 

8 expressed in billions of dollars.

9 Now, keep in mind for these next two 

10 slides, there are several different results that we 

11 get from the national impact analysis, depending on 

12 what CSL DOE chooses to look at, there can be a wide 

13 range of national energy savings, as well as 

14 national net present value savings.

15 This image gives the maximum possible 

16 energy savings available from an amended standard. 

17 This means if the amended standard were to mandate 

18 that everything that was at -- that all the 

19 equipment classes were at their maximum CSL, this is 

20 the type of energy savings curve we would see, which 

21 cumulatively speaking, over the 30 years analysis 

22 period, amounts to about 1.7 quads of national 

23 energy savings.

24 Please consider, though, that DOE does 

25 absolutely examine the impacts, the economic impacts 
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1 of setting standards, and that’s what the net 

2 present value analysis -- or the net present value 

3 results -- take into consideration.

4 MR. BROOKMAN: Hold there. John.

5 MR. GREEN: Yes, John Green. This is an 

6 accumulated curve, not a per year curve?

7 MR. MORRIS: These are -- since the values 

8 here are per year, and then if you -- essentially if 

9 you took the integral of that curve, summed up all 

10 the energy savings annually, you would get the 

11 cumulative savings over the 30 year period.

12 MR. GREEN: All right. Thank you.

13 MR. BROOKMAN: Thank you. Okay. 

14 MR. MORRIS: Thank you. Just like the 

15 last slide, there are many different scenarios in 

16 which national net present value can be calculated. 

17 Net present value varies not only by equipment class 

18 but also by CSL, as you can see here. This 

19 particular image outlines the net present value of 

20 an amended standard achieving the maximum energy 

21 savings possible, subject to the constraint that the 

22 net present value of the amended standard would be 

23 positive, that it would actually be beneficial, 

24 economically speaking, for the nation.

25 So there are curves we could put up, a 
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1 national net present value curve that would look 

2 different than these, however, not all -- CSLs are 

3 not all amended CSL levels -- I didn’t say that 

4 right. Not all CSLs will save money and will not be 

5 economically viable, but some CSLs could, 

6 theoretically increase national energy savings.

7 I’ll rephrase that because that came out 

8 all backwards. Higher CSLs can and will save more 

9 energy, but they may not be economically viable. 

10 Better way to put it. Okay. 

11 Maybe I can hold it and if anybody has any 

12 comments regarding national impact analysis?

13 MR. BROOKMAN: And particularly the 

14 comments on the last set of curves were useful. Is 

15 there are any comment on these. That would be 

16 useful. Okay. 

17 MR. MORRIS: I don’t know what everyone 

18 wants to do.

19 MR. BROOKMAN: I want to keep going.

20 MR. MORRIS: Okay. Then we’ll go to 

21 Hayden Cook with the manufacturer impact analysis.

22 MR. BROOKMAN: That’s my -- my presumption 

23 is that we’re -- we’ve only got about ten or so 

24 slides left. We’re going to just keep going. We’re 

25 not going to pause for lunch or anything like that. 
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1 Let’s go.

2 Manufacturer Impact Analysis

3 MR. COOK: Hi. My name is Hayden Cook. 

4 I’m with Navigant. I’ll be speaking about the 

5 manufacturer impact analysis, or the MIA. The 

6 purpose of the MIA is to quantitatively and 

7 qualitatively assess the impacts of energy 

8 conservation standards on manufacturers of metal 

9 halide lamp fixtures. The key output of the MIA is 

10 a change in industry net present value, or INPV, 

11 resulting from these energy conservation standards.

12 DOE normally performs the MIA in three 

13 phases which is shown here on the slide. 

14 In phase 1, DOE creates an industry 

15 profile, building on the market and technology 

16 assessment. This market profile is then update 

17 through our interviews with manufacturers. This 

18 takes place during DOE’s preliminary analysis. 

19 During this time DOE identifies the key issues 

20 concerning manufacturers, which brings us to phase 2 

21 of the MIA.

22 In the second phase, which spans the NOPR 

23 and the final rule analyses, DOE builds a straw man 

24 industry cash flow model called the Government 

25 Regulatory Impact Model, or GRIM, to forecast free 
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1 industry cash flow in the metal halide industry. It 

2 does this for both the base case, and the standards 

3 case, and calculates the NPV for each of these 

4 cases. Also in phase two, DOE develops an interview 

5 guide that they use to lead subsequent discussions 

6 with manufacturers during MIA interviews which takes 

7 place in phase three.

8 In the third phase, DOE interviews a 

9 variety of different manufacturers to receive 

10 feedback on the items listed in the interview guide. 

11 These interviews are conducted under a nondisclosure 

12 agreement so no proprietary information is ever 

13 publicly disclosed. Following the interviews, DOE 

14 refines the GRIM and evaluates other qualitative 

15 issues, such as manufacturer capacity, employment 

16 impacts, and impacts on product competition.

17 Moving on to some of the key issues for 

18 manufacturer analysis. During the preliminary 

19 manufacturer interviews, DOE identified several 

20 issues concerning manufacturers.

21 • First, manufacturers are concerned about 

22 profitability impacts due to these amended 

23 energy conservation standards. 

24 Manufacturers believe that they may not be 
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1 able to pass on cost increases to consumers, 

2 which would decrease their profit margins. 

3 This problem could be particularly acute in 

4 the first cost-driven original equipment 

5 manufacturer distribution channel. Also 

6 high costs could drive manufacturer’s

7 customers to shift their businesses to 

8 overseas companies who can compete on 

9 cheaper level.

10 • The second one is market erosion. 

11 Manufacturers believe that alternative 

12 technologies, such as solid-state lighting 

13 and fluorescent lighting, which have been 

14 discussed previously are eroding the metal 

15 halide market, both in indoor and outdoor 

16 lighting applications. Higher prices for 

17 metal halide lamp fixtures may hasten this 

18 switch to these alternative technologies.

19 • On a related note, manufacturers believe 

20 that the standards for metal halide lamp 

21 fixtures have high opportunity costs by 

22 forcing resources toward upgrading existing 

23 product lines. Manufacturer have to divert 

24 resources away from product innovation and 
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1 emerging technologies, like the two 

2 previously mentioned, and then product 

3 conversion testing costs.

4 • Next, manufacturers are concerned with the 

5 product conversion and testing burdens that 

6 could result from these amended energy 

7 conservation standards. Manufacturers 

8 expect product development, redesign, and 

9 testing requirements which would ultimately 

10 result in a more existing, expensive product 

11 for consumers.

12 Then we go to a system approach here, and 

13 this has been discussed. While DOE is planning on 

14 using -- is planning on regulating the efficiency of 

15 metal halide lamps, ballasts only, some 

16 manufacturers are concerned with the system-wide 

17 approach of regulating the efficiency of the entire 

18 metal halide fixtures. Some manufacturers believe 

19 that a system approach could favor specific lamp and 

20 ballast combinations and penalize companies that do 

21 not package lamps with their ballasts.

22 And then lastly, there’s no - as has been 

23 previously discussed, there’s no ANSI-testing 

24 standard. Some manufacturers are worried about 
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1 setting efficiency standards for electronic ballasts 

2 when ANSI currently has no test procedures for such 

3 high frequency ballasts. Manufacturers observe that 

4 without a test procedure, efficiency measurement for 

5 the ballast poses challenges and requires expensive 

6 equipment.

7 So at this time, DOE requests comment on 

8 some of the characterizations of the key issues that 

9 are facing manufacturers and on the regulations 

10 contributing to their overall cumulative regulatory 

11 burden. That is ES-26 [which]is [on] the cumulative 

12 regulatory burden. ES-35 is [on] the identification 

13 of key issues facing manufacturers. Many of these 

14 points have been brought up previously, but DOE 

15 would be very interested in your commenting on this.

16 MR. ERHARDT: Bob Erhardt, Philips 

17 Lighting Electronics. Just -- you mentioned it, and 

18 I’d like to expand a bit. It’s not just that ANSI 

19 does not have a test procedure for high frequency 

20 electronic ballast, but the equipment available has 

21 limited accuracy once you get to the frequencies of 

22 125 kilohertz or so, and to try to differentiate a 

23 matter of half a percent or a percent, when your 

24 measurement accuracy may be in the order of two to 

25 five percent is maybe just not possible.
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1 MR. COOK: Thank you very much.

2 MR. HARDEN: I could just add, Tom Harden, 

3 not only -- the reason there is no test standard is 

4 there’s no lamp or ballast standards either for high 

5 frequency. So you can’t have a test standard without 

6 a standard to test it to, so you’re missing both the 

7 lamp and the ballast high frequency standards as 

8 well.

9 MR. BROOKMAN: So I thought that Hayden 

10 did a good job of laying out these issues that are 

11 on Page 70, so additional amplification on 70 and 

12 also again on -- we’ve begun to hear already today 

13 some of the cumulative regulatory burdens that might 

14 be on the industry, additional comments on that as 

15 well. Yes, please, Rebecca.

16 MS. RAINER: Again, Rebecca Rainer. Just 

17 a general comment. We have discussed I think 

18 extensively, the burden that this puts on 

19 manufacturers. There is also a burden on the 

20 consumers. It’s not a simple task to rewrite 

21 standards, to develop new product plans, maybe even 

22 new reg cases. So it’s not just the manufacturers. 

23 It also is the consumer too that does enter into the 

24 equation.

25 MR. BROOKMAN: Okay. Yes, Bob.
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1 MR. ERHARDT: I don’t know if this is 

2 exactly the right place to bring it up, but 

3 something that’s just occurred to me is that -- and 

4 we talked a couple times about having parallel 

5 regulatory paths. The impact of this regulatory 

6 action will have significant impact on your metal 

7 halide lamp regulatory process. If you start 

8 eliminating categories of ballasts, it is quite 

9 likely that they will disappear from the market and 

10 not be replaced, and will be taken over by 

11 fluorescent and solid state lighting. So you should 

12 take this into account. You are looking at tens of 

13 percent improvements in efficacy when you’re looking 

14 at your lamp regulatory actions, and you may kill 

15 all of that by your one and two percent action here.

16 MR. BROOKMAN: Okay. Thank you. Yes, 

17 Keith.

18 MR. COOK: Keith Cook. Just one comment I 

19 want to reiterate the fact that it’s not just 

20 multiple regulations within DOE, it’s also across 

21 agencies, such as EPA and the ENERGY STAR

22 implication. And there’s nothing worse than having 

23 multiple metrics for the exact same fixture that 

24 leads to confusion in the marketplace and a 

25 significant burden on manufacturers to do all this 
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1 testing. 

2 MR. COOK: The cumulative regulatory 

3 burden does take into account other state and local

4 regulations, as well as DOE and looks at all 

5 regulations that contribute to that.

6 MR. BROOKMAN: Yes, Cheryl.

7 MS. ENGLISH: Hayden, I think this has 

8 done a really good job at least at characterizing 

9 the manufacturer impact interview that I had. One 

10 thing that I think has changed in the marketplace 

11 since we originally did our interview is the 

12 volatility of materials in terms of availability and 

13 pricing, so I just made a note so that as NEMA looks 

14 at our responses on this, we need to look at that 

15 and try to get some data back to you, because when 

16 we start talking about additional use of steel and 

17 copper, the markets on those are really volatile 

18 right now.

19 MR. COOK: Thank you.

20 MR. BROOKMAN: Thank you. You see the 

21 comment boxes there. Additional comments before we 

22 move on?

23 NOPR Analysis

24 MR. MYER: So I’m going to -- this is 

25 Michael Myer. I’m going to return to finish up the 
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1 last couple of slides of the next phase, which is 

2 the NOPR analysis, so this is really high level 

3 where we’re going to the next phase.

4 MR. BROOKMAN: Michael, as you’re doing 

5 that, I’m going to hand out the -- the Department 

6 makes a Xerox copy of the business cards of all that 

7 have attended the meeting today, so I’m going to 

8 pass that out now while you’re doing this high 

9 level.

10 MR. MYER: So this graphic shows where 

11 we’ve been, where we’re going. So we’re starting 

12 the NOPR phase next. In the NOPR phase we’ll revise 

13 the preliminary analysis, but additional analyses 

14 will be done as well, those are the life cycle 

15 subgroup, manufacturer impact, utility impact, the 

16 employment impact and environmental assessment and 

17 the regulatory impact. 

18 In previous years there’s another break 

19 down of them with a little more definition. The LCC 

20 subgroup analysis is exactly as it sounds. It’s an 

21 analysis looking at what groups might be 

22 significantly affected by amended or new standards, 

23 whether it be a grocery store or a big box retailer, 

24 or stadium lighting. As Hayden just finished, we’ll 

25 -- the Department of Energy will continue the 
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1 manufacturer impact analyses. The Department of 

2 Energy will also do a utility impact analysis, 

3 looking at the effects of amended or new standards 

4 on the generation [and cost] of electricity.

5 Employment impact analysis, this is 

6 slightly different than what it sounds. The 

7 manufacturer impact analysis looks at the direct 

8 effect of employment on the manufacturers of the 

9 equipment. This phase looks to the indirect effect 

10 on the other people in the process.

11 The environmental assessment, the 

12 Department of Energy is considering monetizing 

13 [emissions of ]certain airborne particulates and 

14 pollutants. The TSD does a great review of the most 

15 current situation there on all the values and the 

16 wide range of issues involved, with monetization of 

17 these fine particulates and pollutants and what the 

18 effects could also be, roughly. In the NOPR phase, 

19 the Department will look at what happens to the 

20 effects of the amended standards, if they are 

21 monetized.

22 Finally, the regulatory impact analysis, 

23 this is the only one that has a slightly different 

24 title than what it is. This looks at what would be 

25 the effects of not doing the standards and looking 
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1 at other means, through non-regulatory actions, such 

2 as voluntary programs, such as ENERGY STAR, tax 

3 [credits for] manufacturers or other type of 

4 incentives.

5 Issue 33, this is specifically going back 

6 to the LCC subgroup analysis. As I said, DOE will 

7 do this in the NOPR phase, but we’re looking for any 

8 groups that might be affected, such as stadiums, 

9 sports clubs, high-end retail, grocery, big box 

10 retail. So DOE welcomes additional suggestions for 

11 its LCC subgroups analysis.

12 MR. BROOKMAN: You see the ones that DOE 

13 has called out there, so if there are others that 

14 they are missing, now would be a good time to 

15 identify them. Joe Howley.

16 MR. HOWLEY: I’d just like to make one 

17 comment on your environmental impact analysis and 

18 maybe your utility analysis. 

19 Almost all of the outdoor lighting 

20 fixtures that we’re discussing here are operated 

21 during the off peak load. Generally with these 

22 analysis I see that you typically use average 

23 impacts from the utility power generation, as 

24 opposed to off peak impact. This could produce a 

25 different analysis if you’re looking primarily at 
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1 off peak impacts for the outdoor lighting fixtures. 

2 And then a portion of indoor lighting fixtures would 

3 be used off peak as well, such as parking garages or 

4 warehouses.

5 So I think in this particular case it’s a 

6 little different than a lot of the rulemakings where 

7 we assume a national average. This probably would 

8 have less impact, given the off peak loading use 

9 application of these particular products.

10 MR. BROOKMAN: Thank you. Rebecca.

11 MS. RAINER: Just a comment on the 

12 subgroups. I see several that you have listed here, 

13 but as manufacturers, we really sell most of our 

14 products, or a lot of our products, through 

15 distribution. We do not know where these products 

16 are going. We do not know if they’re going to big 

17 box retail, or if they’re going to grocery or 

18 governmental properties or any of the subgroups most 

19 of the time. So it would be very difficult, if not 

20 impossible, for us to control what product would be 

21 going to what end user.

22 MR. MYER: Gentleman from Georgia Power.

23 MR. BROOKMAN: Yes, please.

24 MR. STEVENS: Yes, in reference to the 

25 utility impacts, I was wondering how did you choose 
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1 the utilities?

2 MR. MYER: We actually haven’t done -- I’m 

3 just presenting the next step --

4 MR. STEVENS: Could we volunteer to be 

5 part of the interviews?

6 MR. MYER: I don’t think the Department 

7 ever turns down data or help. We’re not saying no, 

8 no, please we’ve got too much help, that’s not our 

9 position, so I think it’s noted, and when we move 

10 into that phase, we’ll follow correct procedures.

11 MR. BROOKMAN: So that was Mike. Thank 

12 you, Mike. Additional comments on this? Did you 

13 say -- would you restate what the purpose of this 

14 subgroup analysis is?

15 MR. MYER: To see what type of groups or 

16 subportion of the population might be significantly 

17 affected by a new or amended standard.

18 MR. BROOKMAN: Yes, particularly address 

19 adverse impact.

20 MR. MYER: Yes. 

21 MR. BROOKMAN: So additional comments, 

22 questions on this last comment box?

23 MR. MYER: At this point -- oh, forgot 

24 this slide. So as the Department of Energy moves 

25 from the preliminary analysis phase into the NOPR 
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1 phase, they go from candidate standard levels to 

2 trial standard levels. DOE is considering 

3 developing trial standard levels [using] a number of 

4 factors. Here are a couple that are mentioned: 

5 combinations of efficiency levels, minimum life 

6 cycle cost, maximum net present value, maximum 

7 technological efficiency -- so those are some of the 

8 things that the Department of Energy will look at 

9 when they develop TSLs. Once then, DOE will select 

10 one and propose it for the NOPR.

11 MR. BROOKMAN: Yes, Joanna.

12 MS. MAUER: Joanna Mauer. We would just 

13 encourage DOE to consider or to develop a TSL that 

14 represents the maximum levels that are still cost 

15 effective, and those levels may or may not be the 

16 same as the minimum LCC levels.

17 MR. MYER: Thank you.

18 MR. BROOKMAN: Okay. Thank you. 

19 Additional comments on this last slide? We’re 

20 moving towards closure here. Let’s push up the 

21 final comment box.

22 MR. MYER: And I’ll turn it back to Dr. 

23 Kaarsberg.

24 MR. BROOKMAN: Yes, and before you do, 

25 though, before we do this, we ought to offer, as we 
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1 promised, another opportunity -- another opportunity 

2 for anybody that wishes to make final remarks to 

3 cover any issues that are relevant that have not yet 

4 been fully covered, now would be the time to do 

5 that.

6 DR. KAARSBERG: Okay. I’m not a medical 

7 doctor, merely a PhD. I just want to remind you 

8 again, and I probably don’t need to tell you that 

9 we’re taking all your written comments and again I 

10 apologize for the short interval between posting 

11 this and the meeting. I want you to note that the 

comment period closes on May 16, Monday, May 16th 12 , 

that is 45 days after the April 1st 13 posting -- or 

Federal Register 

16 And is Brenda here? Brenda’s not here, 

17 but Brenda Edwards is the person to whom all of 

18 these comments get sent. You can send by e-mail. 

19 You can send by snail mail or courier. Just make 

20 sure you put the energy conservation standards for 

21 metal halide lamp fixtures, or ECS for MHLF. And 

22 the docket number, and the regulatory identification 

23 or RIN number. 

14 notice. So that’s not that long 

15 from now.

24 And finally, I want to encourage everyone 

25 to also provide comments on our process. We are 
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1 trying to be more streamlined, but we don’t want to 

2 miss any important interactions or input by doing 

3 so, so your comments on that.

4 You all have given us a number of complete 

5 comments already on the process, and I want to also 

6 encourage the Webinar folks to provide us some 

7 feedback.

8 And with that, thank you very much and 

9 have a great lunch.

10 (Whereupon, at 12:03 p.m., the meeting in 

11 the above captioned matter was adjourned.) 

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REPORTER'S CERTIFICATE

This is to certify that the attached proceedings 

before:

U.S. DEPARTMENT OF ENERGY

In the Matter of:

ENERGY CONSERVATION STANDARD

PRELIMINARY ANALYSIS FOR METAL HALIDE LAMP FIXTURES

Were held as herein appears and that this is the 

original transcript thereof for the file of the 

Department, Commission, Board, Administrative Law 

Judge or the Agency.

Further, I am neither counsel for or related to 

any party to the above proceedings.

 Official Reporter

Wendy Greene 

Dated: April 28, 2011