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 8 E

- 089

Mon day April 18 , 201 1

**Chair:**

Tina Kaarsberg , PhD

**Facilitator:**Executive Court Reporters (301) 565

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Doug Brookman Public Solutions Baltimore, MD

**Participants Identified:** Susan Anderson OSRAM SYLVANIA 10 0 Endicott Street Danvers, MA 01923

Jennifer Amann ACEEE 529 14 th 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 Aven u e Suite 1100 Portland, OR 97204

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- 0064 3 Cheryl English Acuity Brands Lighting One Lithonia Way Con y ers, GA 30012

Bob Erhar d t 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. 307 E Cleveland, OH 441 1 2

Kate Jensen Steptoe & Johnson 1330 Connecticut Avenue NW Washington, DC 20036

- 1795

Elizabeth Joyce Energy Solutions 1810 Harrison Street Oakland, CA 94 6 12

Andrew Johnson OSRAM SYLVANIA 54 Cherry Hill Dr. Danvers, MA 019 2 3

Rebecca LancasterExecutive Court Reporters (301) 565

- 0064 4 G eneral E lectric 3010 Spartansburg Hwy East Flat Rock, NC 28792

Joanna Mauer Appliance Standards Awareness Project (ASAP) 529 14 th Street NW, Suite 6 00 Washington, DC 20045

Justin Neumann N ational E lectrical M anufacturer’s A ssociation (NEMA) 1300 North 17 th Street , Suite 1752 Rosslyn, VA 22209

Rebecca Rainer Cooper Lighting 5035 Highway 6 1 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 N atural R esources D efense C ouncil 1200 New York Avenue ., NW Suite 400 Washington, DC 20005

Rachel Dicke n son Navigant Consulting 1801 K Street NW Suite 500 Washington, DC 20006

Mahima “Mimi” Gupta Associate Director Navigant Consulting 1801 K Street NWExecutive Court Reporters (301) 565

- 0064 5 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 D epartment of Energy General Counsel’s Office

Brian Coffey **Presenters:**

Navigant Consulting 1801 K Street NW Suite 500 Washing t on, 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 PNN L 57 Bedford Street Suite 101 Lexington, MA 01760

Matt hew Walker Navigant ConsultingExecutive Court Reporters (301) 565

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**AGENDA**

**ITEM PAGE** 

Welcome, Doug Brookman 9

Introductions 9

Agenda Review , Doug Brookman 1 1

Opening Statements 1 4

Introduction Dr. Kaarsberg 18

Regulatory History Brian Coffey 19

Rulemaking Overview Brian Coffey 2 0

Market Assessment Brian Coffey 21

Test Procedure Brian Coffey 2 5

Options for Standards Brian Coffey 29

Scope of Coverage Brian Coffey 43

Technology Options Brian Coffey 47

Screening Analysis Brian Coffey 49

Engineering Analysis Matt hew Walker 51

Energy Use and Markups Analysis Michael Myer 84Executive Court Reporters (301) 565

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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 12 6

NOPR An a lyses Michael Myer 133

Closing Remarks 140Executive Court Reporters (301) 565

- 0064 9

MR. BROOKMAN: Good morning and w elcome to 2

public meeting on Energy Conservation Standards for 3

Preliminary Analysis for Metal Halide Lamp Fix t ures. 4

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

Brookman from Public Solutions i n Baltimore. 6

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

have welcoming remarks first thing this morning. 8 P R O C E E D I N G S 1

You can turn these microphones on and off, 9

the little green LED button needs to be glowing for 10

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

organizational affiliation, please. 12

**Introductions** 13

MS. RAINER: Rebecca Rainer , Cooper 14

Lighting, and Vice Chair of the Lighting Institute. 15

MR. BROOKMAN: Thank you. 16

MR. ERHARDT : Bob Erhardt , Philips 17

Electronics

. 18

MR. HIRT: Tom Hirt, Hubbell Lighting. 19

MS. JENSEN: Ka te Jensen , Steptoe & 20

Johnson. 21

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

used to that. 23

MS. JENSEN: Kate Jensen , Steptoe & 24

Johnson. We represent Acuity Brands Lighting. 25Executive Court Reporters (301) 565

- 0064 10 MR. BROOKMAN: Thank you. 1

MR. HARDING: Tom Harding, Venture 2

Lighting. 3

MR. COOK: Keith Cook, Philips Lighting. 4

MR. NEUMANN: Justin Neumann with the 5

National Electrical Manufacturers Association. 6

MR. STEVENS: Mike Stevens, Georgia Power

. 7

MR. HOWLEY: Joe Howley w ith GE Lighting 8

and Chair man of the NEMA Lamp Section. 9

MS ANDERSON: Susan Anders on , OSRAM 10

SYLVANIA

. 11

MS. MAUER: Joanna Mauer, Appliance 12

Standards Awareness Project. 13

MR. STAS: Eric Stas, DOE General 14

Counsel’s office. 15

MS. ARMSTRONG: Ashley Armstrong , 16

Department of Energy. 17

MS. KAARSBERG: Tina Kaarsberg , DOE. 18

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

up. 20

MR. WALKER: Matthew Walker, Navigant. 21

MR. COFFEY: Brian Coffey, Navigant. 22

MR. MORRIS: Scott Morris, Pacific 23

Northwest National Laboratory. 24

MR. GREEN: John Gree n, Cooper Lighting 25Executive Court Reporters (301) 565

- 0064 11 and Chair of the NEMA Ballast Section. 1

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

on. Please. 3

MR. JOHNSON: Andrew Johnson, OSRAM 4

SYLVANIA

. 5

MR. STEPHENS: Charlie Stephens, Northwest 6

Energy Efficiency Alliance. 7

MS. JOYCE: Elizabeth Joyce, Energy 8

Solutions on behalf of Pacific Gas and Electric 9

Company. 10

MS. LANCASTER: Rebecca Lancaster, GE. 11

MR. BOYD: Brian Boyd, Pacific Northwest 12

National Lab. 13

MR. COOK: Hayden Cook, Navigant. 14

MR. BALLO: Tim Ballo , Earth Justice. 15

MR. BROOKMAN: Again, welcome and thanks 16

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

**Agenda Review** 18

MR. BROOKMAN: I think a ll of you received 19

a packet of information as you checked in this 20

morning. That in clud es both the PowerPoint slides 21

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

proceeds, an executive summary of the preliminary 23

analysis and also a copy of the Federal Register 24

Notice . We’ll be referring to these as we go along 25Executive Court Reporters (301) 565

- 0064 12 today. 1

I’m going to do a very quick agenda 2

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

substantive material

. You can see as you look at 4

the agenda, i mmediately following this agenda 5

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

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

think are especially r elevant for today’s 8

proceeding. 9

Immediately following that we’re going to 10

have an overview of the statute and context, market 11

assessment, Technology Assessment and the Screening 12

Analysis . We’ll take a break mid

- morning around 13

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

Analysis, and continuing on, Energy Use and End

- Use 15

Load Characterization , and Mark

- ups for Equipment. 16

Price Determination. We’ll take lunch mid

- day, 17

round about noo nish. 18

Immediately following lunch, Life

- Cy cle 19

Cost and Payback Period , Shipments and National 20

Impacts Analysis

. Then Preliminary Manufacturer 21

Impact A nalysis , NOPR Analy ses , and then closing 22

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

so

. 24

Ther e’s

-- typically, the Department 25Executive Court Reporters (301) 565

- 0064 13 provides another opportunity for anybody that wishes 1

to make closing remarks, supplemental issues that 2

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

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

Questions and co mments on the agenda? 5

Then I’d ask for your consideration, you 6

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

courtesies if you will. P lease speak one at a time. 8

Please say your name for the record

. You don’t need 9

to say your organizational affiliation every time 10

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

B ut if you say your name each time you speak. There 12

will be a complete transcript of this proceeding 13

that will be posted on the EERE website

-- yes? 14

They keep kind of changing that up a lit tle bit. 15

I’m going to be q u eu ing each pe rson to 16

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

the Department to have follow

- on comments. 18

S ometimes th e back and forth is very beneficial for 19

the Department as they build their record of comment 20

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

please share the air time with your colleagues here , 22

and keep the focus here. 23

If you haven’t already done so, p lease 24

turn your cell phones on silent mode, and limit the 25Executive Court Reporters (301) 565

- 0064 14 sidebar conversations. I think everybody’s already 1

gotten used to turning the se microphones on and off. 2

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

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

and off. 5

So that is, I think, everything I in tended 6

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

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

MS. KAARSBERG: Yeah, I actually had one 9

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

before. We are going to try

-- we’re still new to 11

th e webinar

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

the webinar posted questions right before the first 13

break, right before lunch, and right before we 14

adjourn. So if you have

-- not you in the room, but 15

those of you who are on the webinar. 16

**Opening Statements** 17

DR . KAARSBERG: Okay. The purpose of the 18

meeting is, I guess it’s a two

- way street. We 19

present the preliminary analysis to you for the 20

energy conservation standard. We get comments back 21

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

That’s sort of t he three principles. Someone once 23

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

everything, so

-- and we’d r e ally like you to 25Executive Court Reporters (301) 565

- 0064 15 provide comments, statements on the standard, and 1

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

overarching comment or any kind of comment in the 3

agenda. If anyone has any? 4

MR. BROOKMAN: Yes, opening statements 5

here at the outset? Yes, Justin. 6

MR. NEUMANN: Justin Ne u ma n n with NEMA. I 7

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

to make opening comments here f or this rulemaking. 9

NEMA is initially

-- we’re worried [that] the energy 10

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

because of two separate rulemakings going on and 12

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

one on metal halide luminaries and Navigant as the 14

third party outside group handling that, and then on 15

HID lamps with PNNL. Those two products are 16

essentially intertwined and with two separate 17

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

savings may be missed by handling it this way. 19

And also it appears to us, based on the 20

Federal Register document, that the analysis , as the 21

current rules in place already do a good job in 22

creating ener gy savings for the consumers, a nd NEMA 23

feels that there are no big gains to be had 24

currently in this rulemaking. Industry has been 25Executive Court Reporters (301) 565

- 0064 16 working towards achieving much higher energy savings 1

down other avenues and we fear that this rulemaking 2

could be counterproductive to that. The market s , 3

for the NEMA manufacturers are already driven 4

towards energy efficient appliances, that’s what 5

their customers are asking for, and we fear that 6

this rulemaking could potentially hinder that as the 7

market is already going in that direction. 8

We’re also worried that ENERGY STAR is 9

also developing standards for the sa me lumina i res 10

and with two different standards in place, this also 11

could adversely affect the marketplace. There are 12

also some concerns about the liabilities of 13

electronics at high ambie nt temperatures, and how 14

that could affect the product. 15

We’d like to thank you for conducting the 16

manufacturer interviews that have been done so far 17

and encourage you to continue to do so with the 18

various NEMA members. And we also appreciate our 19

previous comments, both written and verbal, that 20

have been taken into consi deration so far in this 21

rulemaking process. Thank you. 22

MR. BROOKMAN: Thank you. Other comments 23

here? Introductory comments at the outset? Bob. 24

MR. ERHARDT : Bob Erhardt , Philips 25Executive Court Reporters (301) 565

- 0064 17 Lighting and Electronics. One comment with respect 1

to Justin’s intro duction. When industry met on 2

Thursday, there was a completely different payback 3

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

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

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

find it difficul t to comment on it. We wish that 7

the DOE had been consistent or at least given us 8

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

dramatic change. 10

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

think most of you in this room are familiar that 12

these oral comm ents will be captured for the record, 13

but the Department really appreciates your written 14

comments as well, extensive detailed written 15

comments is what they appreciate most. 16

Other comments here at the outset? Okay. 17

And let me echo Tina’s sentiments, wel coming those 18

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

find a way to insert your questions where 20

appropriate as the day goes along. 21

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

going to hear from Brian Coffey first. 23

MR. COFFEY: I think we still have Tina 24

first, a slide or two, actually. 25Executive Court Reporters (301) 565

- 0064 18 MR. BROOKMAN: Okay. 1

**INTRODUCTION** 2

DR. KAARSBERG: I wanted to talk a little 3

bit about these boxes that you see everywhere. My 4

understanding is that these boxes have been around 5

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

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

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

posted on the W eb in the third section of the 9

E xecutive S ummary of the preliminary analysis and 10

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

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

front of them, and they are not necessarily 13

sequential because we wanted you to be able to cross 14

reference, because the information in the written 15

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

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

couple that aren’t in the E xecutive S ummary. Just a 18

little housekeeping type thing there. 19

Of course, those are things that we 20

especially would like to have comments on, but of 21

course, you’re welc ome to comment on anything. 22

And speaking of comments, I just want to 23

quickly remind you that public comments

-- we have a 24

process, and the process enables us to address 25Executive Court Reporters (301) 565

- 0064 19 everyone’s comments and there are several ways: e

1

mail, post, courier, that you ca n provide us 2

comments for the record in addition to verbal 3

comments or posted comments for the webinar folks. 4

And we would encourage you, especially on the 5

written comments, to

- - any kind of process 6

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

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

better, we’re constantly trying to streamline and 9

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

it over to Brian Coffey of Navigant. 11

**Regulatory History** 12

MR. COFFEY: Thanks, Tina. 13

DR. KAARSBERG: Oh, there he is. 14

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

what’s going to be in this presentation, content

16

wise, so I’ll start with the overview and statutory 17

context for the rulemaking. Here’s the regulatory 18

background of t he rulemaking. The Energy Polic y 19

Conservation Act of 1975, or EPCA, established the 20

conservation standards and development for certain 21

commercial equipment. The Energy Independence and 22

Security Act of 2007, or EISA, prescribed standards 23

for metal halide lamp fixtures by requiring that 24

they contain ballast meeting or exceeding defined 25Executive Court Reporters (301) 565

- 0064 20 efficiency levels. It also directed DOE to develop 1

at test procedure for those ballasts based on an 2

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

EISA also directed DOE to incorporate 4

standby and off mode p rovisions in the standards 5

rulemaking. Finally, EISA directed DOE to amend 6

standards for metal halide lamp fixtures and publish 7

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

revision to that rule seven years later on January 9

1, 2019. 10

**Rulemaking Over view**  11

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

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

kicked off the metal halides rulemaking in December 14

2009 with the publication of a framework document 15

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

Register

Later this year, DOE will publish a Notice 20

proposing a standard and hold another meeting to 21

receive feedback on that proposal. 22 notice announcing this preliminary analysis 17

meeting wherein DOE presents its initial analytical 18

results. 19

The fi nal rule arrives on the first of 23

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

effect three years later, on January 2015. 25Executive Court Reporters (301) 565

- 0064 21 So those are the background details of the 1

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

Here’s an expansion of the preliminary a nalysis 3

stage, our current stage, and the analyses that 4

comprise it. 5

**Market and Technology Assessment** 6

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

the market and technology assessment, which 8

characterizes the metal halide fixture industry, 9

determines the rulemaking’s proper scope of 10

coverage, breaks down that scope of coverage into 11

equipment classes, and identifies techno logy options 12

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

look at the Screening Analysis , which screens out 14

those technology options on the basis of four 15

criteria and relab e ls the remaining ones “design 16

options” for consideration in the next analysi s , the 17

Engineering, which you can see in the next chevron 18

right there. 19

Definitions. EISA 2007 defined the term 20

metal halide lamp fixture. It means a light fixture 21

for general lighting application designed to be 22

operated with a metal halide lamp and fo r a metal 23

halide lamp. EISA then went on to establish 24

efficiency standards for ballast contained in a 25Executive Court Reporters (301) 565

- 0064 22 subset of metal halide lamp fixtures. This is an 1

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

standards for the lamp, or for the optical portion 3

of the fixture. It set standards only for the 4

ballast sold in new fixtures that match certain 5

criteria. 6

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

meet which standards. Here’s the current statutory 8

scope of coverage. Pulse

- S tart ballast from 150 to 9

500 watts inclusive have to be 88 percent efficient. 10

Magnetic pul se

- start ballast from 150 to 500 watts 11

inclusive have to be 94 percent efficient. Non

12

pulse

- start electronic ballasts have to 90 percent 13

efficient if between 150 and 250 watts, and 92 14

percent e fficient if between 250 and 500 watts. 15

EISA also excluded fixtures with ballasts 16

that met certain conditions, including regulated l ag 17

ballast, 480 volt electronic ballast, and 150 watt 18

ballast rated for both use in wet locations and for 19

ambient temperatu res above 50 ° Celsius. 20

DOE is considering expanding the scope we 21

just mentioned to cover new fixtures with lamp 22

wattages 50 and above. DOE is not considering 23

extending coverage below 50 watts, mainly because 24

low wattage metal halide is often used to r eplace 25Executive Court Reporters (301) 565

- 0064 23 less efficient lighting technologies like halogen. 1

In contrast to EISA, DOE is considering covering the 2

currently exempt 150 watt fixtures, based on 3

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

In keeping with EISA, DOE has no plans to 5

r egulated lag ballasts, both because they are costly 6

and unlikely to become a loophole, and because they 7

account for such a tiny fraction of ballasts sold. 8

DOE is not aware of any commercially available 9

ballasts able to operate natively on 480 volts and 10

is considering not covering those as well. 11

DOE invites comment on this proposed scope 12

of coverage. 13

MR. BROOKMAN: So there you can see the 14

proposed possible expansion of scope. Comments on 15

that? Joanna. 16

MS. MAUER: Joanna Mauer. We strong ly 17

support the expansion of scope to the additional 18

wattage range because I think the preliminary 19

analysis shows there’s certainly potential for 20

savings. We also support the coverage of the 150 21

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

like it ma y have become somewhat of a loophole. 23

And for regulated lag ballasts, I think we 24

encourage the Department to consider the possibility 25Executive Court Reporters (301) 565

- 0064 24 of coverage and we understand the inherent

-- that 1

regulated lag ballasts may be inherently less 2

efficient and a lower standard might be appropriate, 3

but to consider potentially a separate product class 4

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

about the market for those. 6

And I was wondering if you could comment 7

on the rationale for the current exemption of th e 8

480 volt electronic ballast. 9

MR. COFFEY: Those ballasts were exempted 10

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

electronic ballast able to operate on 480 volts, but 12

would certainly welcome comment with any information 13

on that. 14

MR. BROOKMAN: B ob. 15

MR. ERHARDT : Bob Erhardt , Philips 16

Lighting Electronics. Would like to point out that 17

the allowance on the 150 watt ballast was because 18

the 150 watt ballast was seen already as an energy 19

savings for the 175 watt ballast that it replaces, 20

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

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

as a way to realize energy savings to push people 23

for a transfer from 175 to 150 watt. 24

MR. BROOKMAN: Okay. Thank you. 25Executive Court Reporters (301) 565

- 0064 25 Additional comments on this possible expa nsion of 1

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

current plans to cover fixtures that use regulated 3

lag ballasts.” Keith? No? Okay. 4

**Test Procedure** 5

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

procedure that I mentioned before, is based on the 7

ANSI standard C82.6

- 2005. Manufacturers have 8

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

available. Some commenters at the framework meeting 10

had suggested it might become available in 2010, but 11

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

has no provisions for testing high frequency 13

ballasts, and there was a thought that the coming 14

revision might address them. 15

One other point is that the test procedure 16

is non

- specific with respect to which input voltage 17

should be used for testing when a ballast is rated 18

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

considering amending the test procedure to require 20

testing at all input voltages, and reporting an 21

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

derived efficiency when conducting its own tes ting 23

for the preliminary analysis. 24

In addition to active mode testing, DOE

-- 25Executive Court Reporters (301) 565

- 0064 26 I’m sorry, EISA directs DOE to amend test procedures 1

to include standby and off mode energy consumption. 2

Standby mode means that the ballast is providing 3

certain secondary fun ctions, but not its primary 4

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

theory metal halide ballasts can be designed with 6

auxiliary control devices that could consume energy 7

in standby mode. 8

Fl u orescent ballasts sometimes use a 9

protocol called DALI

-- digital addressable lighting 10

interface

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

metal halide ballasts. 12

And then off mode refers to a ballast 13

being connected to a main power source but providing 14

neither active nor standby mode function. DOE 15

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

halide lighting, and has tentatively concluded that 17

it cannot establish a standard that incorporates 18

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

So here we have some test procedure 20

related request for comment . DOE requests comment 21

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

status of the revised version of the document. DOE 23

requests comment on whether it should amend its 24

current test procedure for metal halide lamp 25Executive Court Reporters (301) 565

- 0064 27 ballasts to include specification o f voltage when 1

testing for efficiency. Of particular interest is 2

whether efficiency is affected by the voltage or by 3

the number of operating voltages. 4

DOE also seeks comment on any other 5

appropriate changes to the current test procedure 6

for metal hali de ballasts based on findings from its 7

preliminary analysis for metal halide fixtures. 8

And then finally, DOE invites comments on 9

issues of standby mode and off mode. 10

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

for the record. 12

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

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

being prepared for a final voting, and it should 15

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

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

As far as what’s included in th at, 18

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

been finalized, but it will address

-- its major 20

change is it will address the electronic ballast 21

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

that regard. Very little, if any, changes to th e 23

magnetic testing. So it’s primarily focused on 24

electronic, and should provide the test procedure 25Executive Court Reporters (301) 565

- 0064 28 that you need. 1

MR. BROOKMAN: Thank you. Bob. 2

MR. ERHARDT : Bob Erhardt , Philips 3

Ligh ting Electronics on issue ES

- 2. While the 4

industry will prepare a industry response at a later 5

date concerning average versus highest voltage 6

testing, I will comment that the number of voltages 7

on a electromagnetic ballast is affected

-- does 8

affect efficiency, because you are not able to 9

optimize the number

-- the wire size on the primary 10

when you need to have multiple input voltages. So 11

more voltages on electromagnetic ballast do tend to 12

lower efficiency on at least one or another voltage. 13

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

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

absolutely right, but we also need to recognize that 16

the market has really driven us to multiple tap

17

ballasts because of inventory concerns. They only 18

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

for a single voltage, it significantly addresses the 20

cost problem. 21

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

MS. ANDERSON: Susan Anderson, OSRAM 23

SYLVANIA . We also have a precedent set with the 24

fluorescent ballast standards where we only tested 25Executive Court Reporters (301) 565

- 0064 29 the highest rated voltage, so that’s an established 1

precedent. And in view of the additional work 2

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

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

at the highest rated voltage. 5

MR. BROOKMAN: The Department really would 6

a ppreciate your detailed comments in writing on that 7

subject. Okay. Other comments? Has anybody 8

addressed ES

- 3 yet? Keith. 9

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

agrees with the proposal on ES

- 3. We’re in 11

agreement. 12

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

Other additional comments on these three comment 14

boxes? Okay. 15

**Options for Fixture Standards** 16

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

other choices DOE might have for setting fixture 18

standards. Just to remind everybody, although a 19

fixture includes a lamp, ballast and an optical 20

portion, EISA 2007 addressed only the ballast. 21

DOE is considering now whether amended 22

standards should address the ballast only, the 23

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

optical portion of the fixture. 25Executive Court Reporters (301) 565

- 0064 30 A lamp ballast metric, that’s without any 1

fixture consideration, would have the advantage of 2

allowing manufacturer to pursue efficiency gains 3

where they were most economical and allow 4

optimization at the systems level. A fixture metric 5

might have the further benefit of encouraging 6

fixtures that absorb less light and distribute it 7

more effectively. So let’s explore those two 8

options. 9

Here’s the lamp

- ballast system approach, 10

which would entail setting a standard in terms of 11

lamp lumens and ballast inp ut watts. It wouldn’t 12

measure what the ballast is outputting, as a ballast 13

standard does, only what goes into the ballast and 14

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

mentioned, were that manufacturers would have some 16

flexibility to optimize whereve r it was most 17

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

efficacy lamps might not be compatible with all 19

ballast types. 20

One example of that could be with ceramic 21

metal halide, which DOE understands may be more 22

efficacious over the life of the l amp, but unable to 23

reliably operate on high frequency ballasts. DOE 24

hasn’t preliminarily found that high frequency is 25Executive Court Reporters (301) 565

- 0064 31 the only path to higher ballast efficiency, but if 1

it were, then this could be an example of 2

compatibility problem. 3

A lamp ballast ap proach might sidestep 4

this issue. Drawback to the lamp ballast approach 5

might be that many fixtures are shipped without 6

lamps and that DOE would need to specify how to 7

assess compliance in those cases. One option could 8

be to publish a table of standard l amps that contain 9

default lamp efficacy values. 10

A second issue is that DOE is currently 11

conducting high

- intensity discharge lamps rulemaking 12

that has the potential to conflict with any lamp

13

based standards that this rulemaking sets. Some 14

commenters at t he framework meeting noted that this 15

could present a compliance burden for manufacturers. 16

DOE invites comment on 17

1. The specific lamp efficacy values that 18

could be included in a table of standard 19

lamps; 20

2. examples of systems that could benefit 21

from this app roach; 22

3. the manufacturer impacts and feasibility 23

of a lamp

- ballast system standard in 24

addition to a lamp

- specific standard that 25Executive Court Reporters (301) 565

- 0064 32 could result from an ongoing HID lamps 1

rulemaking; and then 2

4. Whether consumers could and would relamp 3

fixtures with lamps effica cious than those 4

with which they were sold. 5

MR. BROOKMAN: Bob Erhardt

. 6

MR. ERHARDT : Bob Erhardt , Philips 7

Lighting Electronics. Yes, NEMA agrees that lamps

- 8

- the system approach is a preferred approach for 9

any rulemaking. We do agree with the potential 10

conflict and difficulties with having two separate 11

rulemakings between lamps and ballasts. There are 12

some areas where a ballast can be labeled for a 13

specific lamp, in particular, some of the newer 14

lamps that are coming out that have higher effic acy, 15

but that will involve some complexity on keeping 16

ballasts and lamps consistent. 17

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

speaking on behalf of your company or on behalf of 19

someone else? 20

MR. ERHARDT : I believe these are

-- this 21

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

MR. BROOKMAN: Thank you. 23

MR. ERHARDT : I was looking for my bullet 24

points, but I’m trying to speak from memory, and I’m 25Executive Court Reporters (301) 565

- 0064 33 trying to keep this NEMA

-- 1

MR. BROOKMAN: That’s fine. 2

MR. ERHARDT :

-- approved. And 3

considering re lamp of fixtures, if a ballast and a 4

luminaire is labeled for a particular lamp, that 5

luminaire is only keeps its UL listing if that lamp 6

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

instance, that was labeled with a C type lamp 8

designation, then if someo ne were to put an M type 9

designation in there, they would risk voiding their 10

UL listing. So it is possible, within some 11

limitations, to specify the lamp type. 12

MR. BROOKMAN: Okay. 13

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

the earlier 3.4 that I was also supposed to comment 15

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

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

want to keep going? 18

MR. ERHARDT : Which one haven’t I

-- oh, 19

now something that NEMA has done with ENERGY STAR 20

and with fluorescent lamps is they ha ve maintained a 21

table of ballast and lamp efficacies such that a 22

manufacturer

-- a luminaire manufacturer knows that 23

they must meet a certain lamp

- ballast efficacy, they 24

could take one from the NEMA database. We don’t 25Executive Court Reporters (301) 565

- 0064 34 know if something like this would be acceptable to 1

DOE. 2

MR. BROOKMAN: Okay. You see several 3

issues called out there in ES

- 5. Additional 4

comments on these? Yes, Bob. 5

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

number two, there are some lamp

- ballast systems that 7

are out on the market tha t only operate with one 8

specific lamp and one specific ballast and they can 9

be impacted by some of the considerations that DOE 10

is doing such that

-- for instance, Philips has a 11

system which I believe is the highest system 12

efficacy system on the market that cannot operate on 13

an high frequency ballast, and would not meet some 14

of the ballast requirements that DOE is considering. 15

MR. BROOKMAN: So the Department would 16

appreciate any additional comments on this. Okay. 17

MR. COFFEY: So in addition to a lamp

18

ballast standard, DOE has the option of setting a 19

fixture

- based standard. Fixtures can absorb 20

significant amounts of light and also distribute 21

light to places that aren’t useful to the 22

application. That can be considered a type of 23

inefficiency because l umens that required energy to 24

produce aren’t doing anything useful. DOE looked at 25Executive Court Reporters (301) 565

- 0064 35 a few different fixture metrics that could be used 1

for setting fixture

- based standards. A fixture 2

efficiency is the simplest, taking into account the 3

amount of light leavin g a fixture, but saying 4

nothing of light distribution. The problem with 5

using fixture efficiency alone is that different 6

applications require different light patterns, some 7

of which are inherently less efficacious to produce. 8

A fitted

- target efficacy is a metric that 9

we had been developing, and it took into account 10

both the amount of light leaving the fixture and the 11

rectangularity of the light pattern. The thought 12

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

illuminate a large surface with se veral fixtures, 14

maybe a roadway, rectangles tile together more 15

neatly than circular patterns would. Circular 16

patterns might have dark and overlit areas that 17

correspond to wasted lumens. 18

The problem with this approach is probably 19

obvious, it’s that not a ll metal halide applications 20

call for tiling together light patterns to 21

illuminate large open spaces from above. 22

The next one, unli ke fitted

- target 23

efficacy

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

that NEMA had been developing that did have 25Executive Court Reporters (301) 565

- 0064 36 different metrics for different applications. It 1

was fairly complex, however, and the application 2

definitions could be ambiguous. DOE doesn’t set 3

standards by application, only by features of the 4

equipment and given the huge variety of fixture 5

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

definitions with the level of clarity and rigor that 7

the government rulemaking requires. 8

So DOE explored some options for setting 9

fixture

- level standards, but ultimately found none 10

of them satisfactory and decided to set standards

-- 11

or preliminarily decided to set standards for only 12

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

there could be some other metrics being developed 14

and DOE welcomes comment on the details of those and 15

generally on its decision not to u se a fixture 16

system approach. 17

MR. BROOKMAN: Keith. 18

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

aware, this is an extremely complex issue and 20

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

listed here that are under consideration. Due to 22

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

respond in written comments on this one. 24

MR. BROOKMAN: Okay. Additional comments 25Executive Court Reporters (301) 565

- 0064 37 on this preliminary decision? No additional 1

comments, okay, let’s proceed. 2

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

performance stan dards, DOE has the authority to set 4

design standards that prohibit or mandate certain 5

features on metal halide lamp fixtures. 6

California’s Title 20 did this when it prohibited 7

probe

- start for its covered wattage range, and 8

presented some pathways to compl iance that called 9

for sensors on fixtures. DOE is considering setting 10

standards

-- setting similar standards, particularly 11

in the case of prohibiting probe

- start. 12

Although probe

- start ballasts are fairly 13

similar to pulse

- start ballasts in efficiency, they 14

operate lamps that are generally less efficacious, 15

at least for some wattage levels. A consumer might 16

opt to save energy while maintaining similar light 17

levels by replacing probe

- start fixtures of a 18

certain wattage with either fewer pulse

- start 19

fixtu res of the same wattage, or with the same 20

number of pulse

- start fixtures of a lower wattage. 21

DOE is not aware of probe

- start ballasts 22

having any advantageous features and views their 23

prohibition as a possible path to energy savings. 24

So here’s some comm ent requests on this 25Executive Court Reporters (301) 565

- 0064 38 design standard topic before we talk about how DOE 1

breaks down its proposed scope of coverage into 2

equipment classes. I’ll just read these. 3

DOE may consider a federal design standard 4

similar to California’s Title 20 and requests 5

com ment on the feasibility of this action and the 6

expected consumer preferences for occupancy sensors, 7

dimming or reduced lamp

-- reduced

- wattage lamp 8

pairings. 9

DOE also seeks comment on the expected 10

change in lumen output and the initial efficacy when 11

movi ng from regular to reduced wattage versions of 12

lamps. Next one

-- 13

MR. BROOKMAN: Let’s pause. 14

MR. COFFEY: Sure. 15

MR. BROOKMAN: Let’s take comment on ES

- 6 16

here, Keith. 17

MR. COOK: We really appreciate the DOE 18

taking a look at this from a systems perspective. 19

This is definitely headed in the right direction, we 20

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

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

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

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

written comments, just due to everything this 25Executive Court Reporters (301) 565

- 0064 39 encompasses, but we agree, it is the right 1

direction. 2

MR. BROOKMAN: That’s helpful. Okay. 3

Thank you. Yes, your name, please

. 4

MS. JOYCE: Elizabeth Joyce, Pacific Gas 5

and Electric. Just want to reiterate our support 6

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

- 7

type metric. We are reviewing information on the 8

popular compliance pathways in California, in 9

response to t his standard and just general other 10

feedback in responses to the standard, and we will 11

be submitting that to DOE in our written comments. 12

MR. BROOKMAN: You’re gathering data and 13

when will you have it? 14

MS. JOYCE: Hopefully by the time we 15

submit our wr itten comments for this, at least some 16

preliminary information. The preliminary 17

information that we’ve collected so far indicates 18

that most fixtures that have gone through C E C 19

Appliance database

-- of those that do list their 20

compliance pathway, which is only about a quarter of 21

the total fixtures in the database, most prefer or 22

are listed under either the reduced wattage 23

requirement or under just a simple ballast 24

efficiency metric. Not as many that are going for 25Executive Court Reporters (301) 565

- 0064 40 the controls compliance pathway. We’ll loo k at that 1

in more detail. 2

MR. BROOKMAN: Thank you. Bob Erhardt

. 3

MR. ERHARDT : One comment concerning the 4

California Title 20 controls requirement. There is 5

a difficulty involved for the luminaire 6

manufacturers the way the Title 20 is implemented, 7

wh ere it says that all pieces of the control system 8

must be integral to the luminaire. And I believe 9

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

embraced. Our company would ask the DOE to consider 11

that a simplified approach, having controllable 12

lumina i res, for instance, can account

-- would allow 13

-- encourage more dimming systems out there. 14

MR. BROOKMAN: Yes, Rebecca. 15

MS. RAINER: We do believe that this is 16

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

DOE considers street lighting in its analy sis and 18

may treat it a little differently. There may be 19

additional studies that need to be done with street 20

lighting and dimming. 21

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

Cheryl, is it not? Yes. 23

MS. ENGLISH: Thank you, Cheryl English, 24

Acuity Brands Lighting. The Title 20 approach has 25Executive Court Reporters (301) 565

- 0064 41 pros and cons. Pros on it, it does add a lot of 1

flexibility for manufacturers and designers. On the 2

con side, that also adds complexity to the 3

enforcement and reporting associated with it. 4

I also want to note that w e have been 5

working with CEC on something that was an error in 6

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

corrected, but the 336 to 500 watt reduced lumen 8

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

not achievable with products today, an d so we’ve 10

been working with CEC to try to get that corrected 11

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

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

proceed. 14

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

ES

- 6. These are good comments. You wa nt to lay out 16

the other two comment boxes? 17

MR. COFFEY: Sure. It sounded like people 18

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

the second comment. DOE understands that metal 20

halide lamps are often dimmed using bi

- level 21

capacitors in conjuncti on with relays, motion 22

sensors or photocells. DOE requests comment on the 23

cost of employing these methods to save energy, and 24

on usage patterns that would allow DOE to estimate 25Executive Court Reporters (301) 565

- 0064 42 the energy they could save. 1

And then the last issue is that DOE 2

requests comment on mean lumen differences between 3

probe and pulse

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

1000 watts, and on any other information that would 5

help it assess potential energy savings of 6

prohibiting probe start. 7

DOE also requests comment on a design 8

standard that prohibits probe start ballasts. 9

MR. BROOKMAN: Justin. 10

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

issue ES

- 10, as Keith stated previously, NEMA will 12

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

addressing this in the written comments. 14

MR. B ROOKMAN: Thank you. And yes, 15

please, Tom. 16

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

far as ES

- 22 is concerned, you list four 18

representative wattages, 70 watt and you’re 19

comparing probe and pulse. There are no probe

- start 20

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

are no differences. 250 and 400 are similar probe 22

starts versus pulse

- starts, probably in the range of 23

eight to 15 percent energy savings of mean lumen 24

outputs today. The 1000 watt probe versus pulse, 25Executive Court Reporters (301) 565

- 0064 43 anywhere from zero to about e ight percent, depending 1

on the manufacturer. Small amount. 2

As far as requests on design standards 3

that prohibit probe

- start, first of all, the EISA 4

bill already bans probe

- start between 150 and 500. 5

There are virtually none

-- very few that I know 6

pr obe start ballasts 150 and below, or below 150, so 7

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

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

own documents are pretty efficient anyway. The lamp 10

performance is hardly any different, zero to maybe 11

eight percent for some people. 12

MR. BROOKMAN: Okay. Thank you. Other 13

comments on these three boxes? Okay. 14

MR. COFFEY: So we’ve overviewed the 15

different options that DOE has for setting energy 16

conservations standards, now we’ll discuss how DOE 17

br eaks down its scope of coverage. 18

**Scope of Coverage** 19

MR. COFFEY: DOE may establish separate 20

equipment classes and evaluate separate standards 21

for each equipment class. DOE divides covered 22

equipment into classes by the type of energy used, 23

the capacity of the equipment or other performance

24

related features that justify different standard 25Executive Court Reporters (301) 565

- 0064 44 levels, such as those affecting consumer utility. 1

EISA 2007’s set standards for metal halide 2

lamp fixtures both by rated lamp wattage and by 3

ballast type. There were separate standards for 4

pulse

- start, probe

- start, and non

- pulse start 5

electronic. 6

Here’s a summary of the different factors 7

DOE considered using to establish equipment classes. 8

Currently, DOE is considering setting standards only 9

by wattage. DOE did consider input voltage, 10

starting method, nu mber of lamps per ballast, 11

electronic configuration and circuit type, and any 12

features related to fixture application, but is 13

currently considering establishing equipment classes 14

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

factors, but let’s look specifi cally at input 16

voltage and wattage. 17

Here’s voltage. Most ballasts can operate 18

at more than one. DOE explored setting equipment 19

classes by input voltage, but found that there was 20

no prevailing relationship between voltage and 21

efficiency, and so prelimin arily decided to include 22

all voltages in a single equipment class. 23

The one possible exception to the 24

efficiency conclusion might be in the case of 25Executive Court Reporters (301) 565

- 0064 45 ballasts that operate only at 480 volts, which 1

commenters at the framework meeting had suggested 2

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

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

establish a separate equipment class for input 5

voltages above 300, it would also need to specify 6

how to consider ballasts that were operated at 480 7

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

fair number of what we’ve been calling quint

- input

9

voltage ballasts that can operate at 120, 208, 240, 10

277, and 480 volts. 11

DOE is interested in information about 12

efficiency variation with voltage and whether DOE’ s 13

test results are representative of the market. 14

DOE also seeks comment on whether it would 15

be appropriate to establish a separate equipment 16

class for ballasts operating above 300 volts, and if 17

so, why quint

- input

- voltage ballasts should belong 18

in one class or the other. 19

MR. BROOKMAN: Justin. 20

MR. NEUMANN: Again, NEMA will address 21

this in their written comments. 22

MR. BROOKMAN: Okay. Other comments on 23

this one before we move on? Okay. 24

MR. COFFEY: So here’s wattage. As I 25Executive Court Reporters (301) 565

- 0064 46 mentioned earlier, DOE used only wattage to set 1

equipment classes. Different applications require 2

different light output, so [application has] an 3

impact to consumer utility. Also ballast efficiency 4

tends to increase with higher lamp wattages, and so 5

DOE preliminarily decid ed to set classes by rated 6

lamp wattage. 7

Here there on the table there are 50 to 8

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

classes. DOE seeks comment on the outlined metal 10

halide lamp fixture equipment classes and on the 11

different features of fixt ures that may affect 12

efficiency or utility

-- I’m sorry

-- and utility, 13

including, but not limited to wattage, voltage, 14

number of lamps per ballast, electronic 15

configuration, and circuit type, starting method and 16

features related to application. 17

MR. BR OOKMAN: Please. 18

MS. JOYCE: Elizabeth Joyce. Just wanted 19

to ask DOE for a little more clarification on its 20

decision to not separate product classes according 21

to indoor versus outdoor use, since we understand 22

that there’s some pretty big design differen ces that 23

are necessitated by, for example, designing a 24

fixture for outdoor use. 25Executive Court Reporters (301) 565

- 0064 47 MR. COFFEY: DOE doesn’t set standards by 1

application, only by physical features related to 2

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

of indoor and outdoor, DOE woul d certainly be 4

interested in hearing comment on that. 5

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

thought you were giving additional comment. Bob, 7

please. 8

MR. ERHARDT : Yes. While NEMA will be 9

supplying a more detailed response in written 10

comments, there have been some comments from the 11

industry that the 150 to 250 may require

-- could 12

benefit from further delineation, and perhaps even a 13

formula approach I think was suggested somewhere 14

else in the document. 15

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

present a little bit on that approach later today. 17

MR. BROOKMAN: Other comments on this 18

specific issue related to wattage? Okay. Nothing 19

additional? 20

**Technology Options** 21

MR. COFFEY: DOE identified a number of 22

technology options that could be used to improve 23

efficiency. The left

- most table corresponds to 24

magnetic ballasts, where you can increase efficiency 25Executive Court Reporters (301) 565

- 0064 48 by using better cores field, copper in place of 1

aluminum wiring, increase core stock height to a 2

point, and increase conductor cross

- section to a 3

point, o r simply by substituting an electronic 4

ballast. 5

The right

- most table corresponds to 6

electronic ballasts, and here we can either use 7

lower loss componentry

-- so that’s diodes, 8

capacitors, transistors, et cetera

-- or we can have 9

optimization at the syste ms level with better 10

integrated circuit designs. 11

DOE requests comment on the feasibility, 12

performance improvement, and cost of these 13

technology options, as well as on any recent 14

developments in their maturity. DOE considers these 15

technology options furt her in the screening analysis 16

MR. BROOKMAN: Bob Erhardt

. 17

MR. ERHARDT : Bob Erhardt , Philips 18

Lighting Electronics. Concerning improved core 19

steel, many of the designs already are using the 20

best laminated steel. There’s been some discussion 21

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

on amorphous materials, those involve a completely 23

different manufacturing process and would be not 24

practicable to implement. 25Executive Court Reporters (301) 565

- 0064 49 The increase d stack height and increa sed 1

conductor cross

- section have limitations as the 2

current lumina i res are designed for a given form 3

factor, and increasing the size of the ballast may 4

render it no longer useful. 5

And there’s a similar issue with 6

electronic ballast. Electronic ballasts are not 7

direct

- to

- replacements for electromagnetic ballasts. 8

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

always require a luminaire redesign. 10

MR. BROOKMAN: Thank you. So you see 11

there the two different options that DOE requests 12

comment on. Addi tional comments? No additional 13

comments? Okay. 14

MR. COFFEY: So DOE identifies those 15

technology options in the Market and Technology 16

Assessment. 17

**Screening Analysis** 18

MR. COFFEY: And then in the Screening 19

Analysis, the technology options are screene d on the 20

basis of four criteria: 21

**•** technological feasibility ; 22

**•** practicability to manufacture, install and 23

service ; 24Executive Court Reporters (301) 565

- 0064 50

**•** adverse impacts on product utility or 1

availability to consumers ; and 2

**•** adverse impacts to health and safety. 3

DOE is not aware of amorphous steel being 4

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

in prototypes and used widely in other products. 6

Distribution transformers is one example, and 7

therefore DOE did not screen out amorphous steel

. 8

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

the t echnology options we’ve discussed, and invites 10

comment on whether amorphous steels and electrical 11

components more efficient than those currently used 12

in ballasts are technologically feasible and 13

practicable to manufacture. 14

MR. BROOKMAN: Bob Erhardt

. Unless

-- 15

Justin, you want to speak first? 16

MR. ERHARDT : Yeah, Bob Erhardt . NEMA 17

will be supplying detailed written analysis, but 18

again, amorphous steels require completely different 19

manufacturing process and most electronic ballast do 20

use some of the h ighest levels of components already 21

in order to handle temperatures, et cetera. 22

MR. BROOKMAN: Anything additional, 23

Justin? 24Executive Court Reporters (301) 565

- 0064 51 MR. NEUMANN: No. 1

MR. BROOKMAN: So

-- okay. Thank you. 2

MR. COFFEY: That concludes the screening 3

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

Walker up to discuss the engineering. 5

MR. BROOKMAN: So let me invite again, 6

those that are joining us via the W eb, please do 7

submit your questions if you have any. Great. 8

**Engineering Analysis** 9

MR. WALKER: Hi everyone. My name is 10

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

engineering analysis. E ngineering analysis uses the 12

design options and market information we’ve just 13

talked about from the screening analysis and market 14

technology assessment to develop a cost

- efficie ncy 15

relationship for each equipment class. This cost

16

efficiency information is then passed to subsequent 17

life

- cycle costs and national impacts analyse s. 18

This slide goes over the basi c methodology 19

used for an engineering analysis. DOE begins by 20

choosin g representative wattages and fixtures to 21

serve as characteristic of the entire equipment 22

class. Then DOE looks and defines characteristics 23

of models in each equipment class which will serve 24

as baseline references to assess changes due to 25Executive Court Reporters (301) 565

- 0064 52 energy conservat ion standards. Then DOE identified 1

more efficient substitutes from a database of 2

commercially available metal halide ballasts, then 3

develops candidate standard levels, or CSLs that 4

span the range of efficiency from the baseline to 5

the max tech

-- the maxi mum technologically 6

feasible. And finally, DOE determines 7

manufacturer’s selling prices for the baseline 8

fixtures and their more efficient substitutes. 9

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

selecting the representative wattages and fixtures. 11

So w ithin each equipment class DOE identified a 12

ballast that operated a particular rated lamp 13

wattage to analyze as the representative wattage. 14

This wattage was used to characterize the cost and 15

efficiencies associated with the entire equipment 16

class. 17

The representative wattage was selected 18

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

was also based on availability in catalogs as well 20

kind of confirming conversations with manufacturers 21

during interviews. You can see these wattages in 22

the third colum n from the left on the table on this 23

slide. 24

Then, in addition, based on comments we 25Executive Court Reporters (301) 565

- 0064 53 received in response to the framework document, DOE 1

also chose representative fixtures to be able to 2

account for any changes in fixture cost with 3

efficiency. For each equipment class, DOE 4

identified commonly used fixture types based on the 5

applications commonly served by the wattage range. 6

The fixture types identified are not meant 7

to be an exhaustive list, but rather a 8

representative group to take into account variat ion 9

in fixture costs among the different fixtures used 10

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

representative fixture types on the fourth column of 12

the table. 13

And this brings us to our first request 14

for comment in the engineering section, DOE is 15

requesting comment on its selection of 16

representative wattages, as well as the fixtures 17

used for these equipment classes. 18

MR. BROOKMAN: Justin. 19

MR. NEUMANN: Again, NEMA will address 20

this in the written comments. Susan has something 21

to add. 22

M R. BROOKMAN: Okay. Susan first. 23

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

written comments. 25Executive Court Reporters (301) 565

- 0064 54 MR. BROOKMAN: Thank you. 1

MS. ANDERSON: We do have one thing we 2

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

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

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

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

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

toward the 150 watt and the reason we had the 8

exception for the 150 watt ballast in the EISA. 9

MR. BROOKMAN: So noting that NEMA will 10

supply detailed comments, you’re suggesting that 250 11

be more like

-- 12

MS. ANDERSON: 175. 13

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

this is important, this early differentiating the 15

equipment classes. Additional co mments at this 16

point? 17

MR. WALKER: I think Mimi has a

-- your 18

mic is on, I think. 19

MR. BROOKMAN: Mimi Gupta. 20

MS. GUPTA: Mimi Gupta, Navigant 21

Consulting. So is there a significant efficiency 22

difference between the 175 watt and the 250 watt? 23

MR. BROOKMAN: I guess I’ll

-- Bob is 24

going to try to answer that, and if not I’ll turn to 25Executive Court Reporters (301) 565

- 0064 55 Susan if needed. Go ahead, Bob. 1

MR. ERHARDT : Bob Erhardt , Philips 2

Lighting Electronics. As commented earlier, well, 3

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

general, feel that there is significant

-- there is 5

a significant change in the efficiency

-- ballast 6

efficiency throughout that range from 150 to 250, 7

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

delineation and perhaps a formula type approach. 9

MS . GUPTA: Okay. 10

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

Any additional comments on this comment box. Susan, 12

you’re okay? Okay. 13

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

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

the baseline models. 16

The baseline model will either just meet 17

the current federal energy conservation standards 18

and provide basic consumer utility, or it will 19

represent the least efficient, commonly sold ballast 20

where no standard exists. 21

DOE uses these baseline ballasts as 22

refe rence points for measuring changes in life

- cycle 23

costs, energy savings associated with the adoption 24

of standards. 25Executive Court Reporters (301) 565

- 0064 56 If you look at the table, you can see that 1

all the baseline ballasts are of the magnetic, CWA 2

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

representative wattages have no standard currently, 4

so for those equipment classes DOE based the 5

baseline eff iciency on tested data. By contrast, 6

for the 250 and 400 watt representative groups, DOE 7

set the baseline efficiency equal to the federal 8

standard that came from EISA 2007. 9

In addition, each baseline ballast is a 10

pulse

- start unit. As Brian mentioned earlier, both 11

probe and pulse

- start magnetic ballasts can achieve 12

about the same ballast efficiencies, but the pulse

13

start ballast is sometimes hard

-- can sometimes be 14

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

observation, DOE is considering a probe

- start 16

baseline. 17

So again, like Brian was talking about 18

earlier, a probe

- start baseline will allow DOE to 19

account for life

- cycle cost changes and energy 20

savings associated with the consumer making a 21

transition from a higher wattage probe

- start syste m 22

to a lower wattage pulse or reducing the number of 23

fixtures at the same wattage. 24

DOE is only considering this additional 25Executive Court Reporters (301) 565

- 0064 57 baseline for the 70 and 1000 watt groups because the 1

existing EISA standards have effectively eliminated 2

probe

- start ballasts in the two middle wattage 3

ranges. 4

MR. BROOKMAN: Tom first, then Susan. 5

MR. HIRT: Yeah, we commented a few 6

moments ago that there are no 70 watt probe

- start 7

ballast systems out there, so we can’t

-- there is 8

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

1000 watt, there is a probe

- start baseline. There 10

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

you’ve noted that the 1000 probe

- start ballasts are 12

already a good 92 percent efficient anyway, and the 13

ballasts are so similar, there’s very little t o be 14

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

that’s about it. 16

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

the idea here with the baseline is to account for 18

the difference in the lamp efficacy, because like 19

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

efficiency is about the same. 21

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

70 watt probe

- start. 23

MR. BROOKMAN: Susan. 24

MS. ANDERSON: No 70 watt probe

- start 25Executive Court Reporters (301) 565

- 0064 58 lamps or ballasts. 1

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

MS. ANDERSON: Probe

- star t lamps or 3

ballasts. 4

MR. BROOKMAN: Thank you. 5

MR. WALKER: This is good to know because 6

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

have to double check that. 8

MR. BROOKMAN: What is the lower end if 9

it’s not 70 for probes? 10

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

There are a few 150 watt probe

- start lamps and 12

ballasts, but below that there are no probe start 13

lamps or ballasts. 14

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

good education. Additional comments on this comment 16

box? 17

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

Doug? 19

MR. BROOKMAN: Yes, please, Mimi. 20

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

technical reason for that or is it just an 22

application related reason? 23

MR. HIRT: Yeah, there is a

-- there is 24

technical reason for that. Pro be

- start lamps, as 25Executive Court Reporters (301) 565

- 0064 59 you know, have three terminals in the arc tubes, 1

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

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

probe

- start starting electrode into the seal, so 4

they just go away. Plus your efficien cy of the size 5

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

in there kills the efficiency of that lamp anyway, 7

or the efficacy of that lamp. Ballasts could be 8

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

there below 150. 10

MR. BROOKMAN: Su san, please. 11

MS. ANDERSON: Susan Anderson. When that 12

whole family of the medium screw

- base, low wattage 13

metal halide lamps were introduced from the very 14

beginning, they have always been pulse start. We 15

never went down the probe start path. 16

MR. BROOK MAN: Okay. Good comments. 17

Additional comments before we move on? 18

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

Michael Myer, Pacific Northwest National Laboratory. 20

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

to understand. Are you saying there’s n o low 22

wattage, under 150 watt probe

- start lamps at all? 23

MR. HIRT: Correct. 24

MS. ANDERSON: Yes. 25Executive Court Reporters (301) 565

- 0064 60 MR. BROOKMAN: I see four heads nodding 1

yes among manufacturers around the table. 2

MR. MYER: Thank you. 3

MR. BROOKMAN: Thanks for that 4

clarification. Additional comments or questions? 5

Your name please. 6

MS. LANCASTER: Rebecca Lancaster with GE. 7

One thing that might be confusing people is that in 8

the catalogs for the fixture manufacturers, a lot of 9

times the lamp designation for these lower wattages 10

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

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

been pulse, but if you look in a fixture 13

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

watt metal hali de, that is a pulse start. 15

MR. BROOKMAN: I guess maybe for the 16

record we should note that in answering Michael’s 17

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

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

you. I just want to be clear. 20

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

the next step, selecting more efficient substitutes. 22

DOE tested about 50 metal halide ballasts to 23

identify more efficient substitutes for the baseline 24

products. They tested about four samples of each 25Executive Court Reporters (301) 565

- 0064 61 ballast, and a veraged measured efficiency at each 1

input voltage, as well as averaging the test results 2

for each sample to come up with a representative 3

value for that particular model. 4

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

blue diamonds are the electronic balla sts, the green 6

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

gap between the most efficient magnetic ballast that 8

we tested and the least efficient electronic 9

ballast. During interviews, manufacturers provided 10

some information regarding the types o f changes that 11

could be required to increase efficiency of these 12

magnetic ballasts. This involved inputs such as 13

changes to the magnetic core types, that sort of 14

thing. 15

This information allowed DOE to model the 16

cost and efficiency of magnetic ballast wi thin this 17

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

efficiency information for the engineering analysis. 19

And one final thing that I want to note on 20

this diagram is that we did not find any electronic 21

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

point this out. 23

This brings us to two issues for comment

. 24

So the first is the CSL

- 4 representative units for 25Executive Court Reporters (301) 565

- 0064 62 the 250 to 500 watt group is a high frequency 1

electronic ballast. The CSL

- 4 is the most efficient 2

level that DOE looked at in the pre liminary 3

analysis. And we request comment on the 4

appropriateness of using this high frequency 5

electronic ballast as representative, particularly 6

with respect to the compatibility concerns brought 7

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

that p erhaps a lower frequency electronic ballast 9

could also achieve that level, and it just happened 10

that we identified one that was high frequency. 11

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

second issue also, which is that DOE requests 13

comment on its observa tion that electronic ballasts 14

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

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

development and maybe will come out some time soon? 17

So, open up the floor. 18

MR. BROOKMAN: Bob Erhardt

. 19

MR. ERHARDT : Bob Erhardt , Philips 20

Lighting Electronics. NEMA feels that it is 21

inappropriate to use a high frequency electronic 22

ballast as a reference for rulemaking. Many of the 23

more

-- many lamps are not operable on high 24

frequency. It’s not just a matter of find ing 25Executive Court Reporters (301) 565

- 0064 63 compatibility. Manufacturer s have determined that 1

many ceramic metal halide and some of the new 2

highest efficacy lamps cannot be operated on high 3

frequency. 4

Low frequency square wave in some 5

instances can approach the efficiency of high 6

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

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

to supply a more detailed written response in this 9

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

specifics, we can comment further. 11

Concerning 1000 watt electronic metal 12

halide ballasts, there are some very small niche 13

markets where electronic ballasts have hand holds 14

(ph) but nothing in general lighting or area 15

lighting. 16

MR. BROOKMAN: Okay. Thank you. Cheryl 17

English. 18

MS. ENGLISH: Cheryl English, Acuity 19

Brand s. Another issue with regard to using high 20

frequency ones as baseline is because in outdoor 21

applications, temperature ambience and power quality 22

may make those types of ballasts less reliable or 23

unreliable in their application. 24

MR. BROOKMAN: Thank you. Keith. 25Executive Court Reporters (301) 565

- 0064 64 MR. COOK: Keith Cook. Even though you 1

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

show any efficiency improvement over the magnetic 3

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

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

examp le, but it has nothing to do with efficiency. 6

MR. BROOKMAN: Okay. Yes, Rebecca. 7

MS. RAINER: Rebecca Rainer. I just want 8

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

emphasize that electronic ballasts are not direct 10

replacements for magnetic ballasts in the luminaire. 11

MR. BROOKMAN: Thank you. Yes, Bob 12

Erhardt

. 13

MR. ERHARDT : One more comment . As I 14

indicated and just want to re iterate it, electronic 15

ballasts are not a direct replacement due to form 16

factor. There’s also the issue of relia bility. Now 17

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

electronic ballast , and electronic ballasts are 19

starting to make some inroads, but it is my 20

understanding it is one with using additional 21

circuitry that is not included in the cost price of 22

t he electronic ballast. Installations that I am 23

aware of include an additional transient suppression 24

unit that is not part of the cost of the electronic 25Executive Court Reporters (301) 565

- 0064 65 ballast. 1

MR. BROOKMAN: Have we covered those two? 2

I guess so. Okay. 3

MR. WALKER: So let’s go to the 4

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

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

main methods that DOE looks at. 7

The first is a bin approach, which you can 8

see on the left

- most plot, where a constant 9

efficiency requirement is set for a specific bin or 10

range of lamp wattages. 11

The second, which is seen on the far 12

right, is develop a continuous equation across the 13

entire wattage range that would relate output power 14

of the ballast or lamp power to efficiency. 15

And the third can be a hybrid of the two 16

in which each equipment class is assigned its own 17

equation. 18

So while bins could encourage production 19

of products of the upper or lower bounds of the 20

range, DOE preliminarily found that efficiency did 21

not vary substantially within the equipment classes 22

under consideration. Of course I think we have 23

already heard a little bit of feedback on that 24

already, that perhaps the 150 to 250 watt range 25Executive Court Reporters (301) 565

- 0064 66 could benefit from an equation approach. We’re also 1

thinking that another exception could be the 50 to 2

150 watt range, the very low wattage ballasts. 3

So I guess at this time we would like to 4

request specific comment on the different approaches 5

that could be taken for setting standards across the 6

wattage range. 7

MR. BROOKMAN: Bob Erhardt

. 8

MR. ERHARDT : Bob Erhardt , Philips 9

Lighting Electronics, speaking for NEMA. NEMA will 10

be supplying more detailed analysis. Generally 11

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

is always some variation

-- there is a definite 13

trend for higher eff iciency as the wattage gets 14

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

its comments. 16

MR. BROOKMAN: Okay. Even though this is 17

preliminary analysis, the Department appreciates 18

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

in the right dir ection. So that kind of a comment 20

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

will supply detailed comments as well. Other 22

comments on this issue box? 23

MR. WALKER: All right. So this slide 24

gives us a summary of efficiencies assigned to each 25Executive Court Reporters (301) 565

- 0064 67 CSL. DOE is requesting comment on these CSLs, in 1

particular, whether they capture the full range of 2

efficiency from the least efficient to the max tech, 3

and whether any significant intermediate levels are 4

missing or should be added. 5

And then in additi on, DOE believes that no 6

CSL in this rulemaking requires the use of 7

proprietary technology, and we are requesting 8

comment on this conclusion. 9

MR. BROOKMAN: Bob Erhardt

. 10

MR. ERHARDT : Bob Erhardt , Philips 11

Lighting Electronics . A comment would be tha t yes, 12

these efficiency levels do represent the range of 13

efficiency that could be expected, however, I would 14

also comment that within a given range, there are 15

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

certain lamp

- ballast combination can have a highe r 17

system efficacy than others in the same class. It 18

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

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

system, how well

-- how much step up or step down 21

you need in your system. These will all influenc e 22

the efficiency of the ballast. 23

So while one ballast in the 250 to 500 24

watt range may be able to hit 93

. 9, that probably is 25Executive Court Reporters (301) 565

- 0064 68 a high that may only be for the highest wattage 1

ballast in that range, and would not be 2

representative of what could be accomplis hed at 250, 3

for instance. So the DOE should take this into 4

consideration. 5

MR. BROOKMAN: Thank you. 6

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

be able to provide specific feedback on the sweet 8

spots that you mentioned in the written comments? 9

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

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

bit to the

-- this is also part of the lamp

- ballast 12

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

we’re very hesitant to make general comments on 14

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

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

a detailed response. 17

MR. BROOKMAN: Okay. Joanna Mauer

. 18

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

that represent the most efficient magnetic ballasts, 20

are those ba sed on conventional steel cores? 21

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

our analysis the most efficient magnetic ballast 23

that represents

-- that’s in these CSLs would be 24

what we would call like a model ballast, so that 25Executive Court Reporters (301) 565

- 0064 69 would be where we’ve taken input from the 1

manufacturers on a change in the core material to 2

improve the efficiency of a commercially available 3

ballast. Does that clarify anything for you? 4

MS. MAUER: I guess the question is 5

whether some of them are based on amorphous steel 6

and whether DOE has evaluated the efficiency 7

potential for using amorphous? 8

MR. BROOKMAN: Go ahead, Bob. 9

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

general comments, speaking from my own company. For 11

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

electromagnetic ballast that can meet 88 percent

-- 13

I’m sorry, in the 110

- 150. At 175 we must

-- we use 14

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

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

M6 anymore, but this gets back into the fundamental 17

VAs, th e Volt

- Amp ratings of the systems and how 18

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

the current is with respect to the open circuit 20

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

consider what materials are used in what ballast, 22

well to make a 17 5 meet 88 percent,

-- actually, 23

when I addressed the California Energy Commission 24

six years ago, I didn’t even think you could make a 25Executive Court Reporters (301) 565

- 0064 70 88 percent magnetic

-- electromagnetic ballast at 1

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

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

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

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

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

considered to be the drop in

-- at the time for 175 7

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

it quite as bit, some lumina i res, not all, could use 9

that product. 10

Eighty

- eight percent is

-- I’ll stick my 11

neck out again

-- I’ll say that’s the limit for 12

electromagnetic product at 175, and it cannot be 13

accomplished at 1 50. Materials can have some impact 14

at other wattages. 15

MR. BROOKMAN: Tom, please. 16

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

efficiency is going back to all copper windings, and 18

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

has gotten extreme ly expensive and hard to get, so 20

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

industry by forcing thick copper back into these 22

things to make the ballast more efficient. 23

MR. BROOKMAN: Keith Cook. 24

MR. COOK: Two comments. One is

-- 25Executive Court Reporters (301) 565

- 0064 71 MR. BROOKMAN: Are you on? 1

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

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

also very, very expensive steel and is no longer 4

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

from China these days and so we have import 6

problems. 7

Second comment I have is I’d like to 8

caution that this chart implies an accuracy due to 9

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

not be achievable. Repeatability and measurement 11

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

we’ve got cl asses that are less than one percent 13

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

not possible. 15

MR. BROOKMAN: What would you suggest that 16

the Department do with respect to granularity? 17

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

recommendations on that

. 19

MR. BROOKMAN: Okay. Thank you. 20

Additional comments on these candidate standard 21

levels, both

-- as you see both the specified or the 22

possible equipment classes and the CSLs? No 23

additional comments? Okay. 24

MR. WALKER: So now we’re moving into the 25Executive Court Reporters (301) 565

- 0064 72 final step of the engineering analysis, which is 1

developing a manufacturer’s selling price. So first 2

DOE has developed some manufacturer production costs 3

based on its analysis of material, labor, factory 4

overhead, and appreciation. The material and labor 5

are determined using a tear down analysis that 6

involves disassembling a unit, costing out 7

individual components, and estimating appropriate 8

labor costs for automatic versus manual insertion of 9

components. 10

And th en public information, such as 10

- Ks 11

and other information is used to estimate the 12

overhead and appreciation. So that gives us a 13

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

manufacturer markup is applied to bring the MPC to a 15

manufacturer’s sellin g price. 16

The manufacturer markup was developed 17

using publicly available financial information like 18

the 10

- Ks and input from manufacturer interviews to 19

kind of

-- to refine that number. There could be 20

two main methods of applying this manufacturer 21

markup , which was determined to be 1.47. 22

First would be to assume that the ballast 23

and empty fixture are manufactured by a single 24

company. In this case, DOE would apply the markup 25Executive Court Reporters (301) 565

- 0064 73 to both the production cost of the ballast and the 1

production cost of the emp ty fixture, and together 2

create a total MSP for that entire fixture. 3

The second situation could be where there 4

are two companies, one company manufactures the 5

ballast and the other company manufactures the empty 6

fixture. In this situation, DOE could app ly a 7

markup to the ballast one time from the ballast 8

manufacturer to the fixture manufacturer, and then a 9

second markup would be applied to that ballast from 10

the fixture manufacturer to the person they’re 11

selling it to. 12

In the preliminary analysis, DOE m odeled 13

its markups on the first approach, which is applying 14

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

doing it the second time. 16

There is no comment box on this slide. I 17

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

methodology used, and the prelim inary determination 19

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

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

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

MR. BROOKMAN: Tom? Question? Comment? 23

Bob Erhardt

. 24

MR. ERHARDT : NEMA will supp ly written 25Executive Court Reporters (301) 565

- 0064 74 comments. This is just a

-- I’ll almost make this a 1

personal observation. I was involved in supply

2

based management in my company for some time, and 3

the DOE should consider that no manufacturer is 4

going to carry the overhead of manufacturing t heir 5

own ballasts if they could realize the same overall 6

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

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

the ballast. 9

MR. BROOKMAN: Your comment suggests that 10

this structure may not reflect the complexit y of 11

pricing decisions that a company might make? 12

MR. ERHARDT : Yes. 13

MR. BROOKMAN: Okay. Just please, your 14

name. 15

MR. JOHNSON: Andrew Johnson. Just a 16

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

magnetic ballasts we always have transient 18

pro tection. But it’s really application related, so 19

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

protection; indoor application, it wouldn’t be 21

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

ballasts have the integral transient protection 23

built int o them, so it wouldn’t add extra 24

protection as it’s defined in the product. 25Executive Court Reporters (301) 565

- 0064 75 MR. BROOKMAN: Thank you. Did you say 1

your name? 2

MR. JOHNSON: Andrew Johnson. 3

MR. BROOKMAN: Thank you. So th is is 4

important how the Department derives the 5

manufacturer’s selling price, and these models, 6

these representations, they matter to them. 7

Additional comments on these

-- this structure, 8

these features? Okay. 9

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

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

little bi t already, how electronic ballasts may need 12

some modifications to the active replacements for a 13

magnetic system. 14

So DOE considered a few of these 15

additional cost adders, estimating that for 16

transient protection, the end user cost could be 17

somewhere betwe en $30 and $70 dollars. We also are 18

recognizing that thermal protection could be 19

required for the electronic ballast as well as the 20

idea that 120 volt taps are not available in all 21

electronic ballasts and these 120 volt taps can be 22

used to power auxiliary equipment, so again, there 23

could be additional cost to adding this to an 24

electronic ballast. 25Executive Court Reporters (301) 565

- 0064 76 So DOE is requesting comment on the 1

thermal issues and other reliability concerns 2

associated with electronic ballasts when used as 3

replacements for existing mag netic systems. 4

It is also seeking comment on the cost of 5

these additional items and the applications in which 6

the measures would be necessary. We didn’t have

-- 7

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

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

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

as on the different applications in which they’re 11

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

of thing. 13

MR. BROOKMAN: Justin. 14

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

will just addre ss this in their written comments. 16

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

MS. RAINER: Rebecca Rainer. Just a 18

general comment. The items that you have listed do 19

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

UL certification when you switch from magnetic to 21

electronic, you will have to recertify all your 22

product. That is a very extensive cost on the 23

manufacturer also. 24

MR. BROOKMAN: You see the comment box. 25Executive Court Reporters (301) 565

- 0064 77 Thermal issues, reliability cost and applications, 1

all of which the Department req uests comment. Bob 2

Erhardt

. 3

MR. ERHARDT : Yeah, I just wanted to 4

reiterate. There was a comment that some electronic 5

ballasts already have transient protection for 6

outdoor. Speaking for my company, I disagree with 7

that. 8

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

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

-- 10

MS. ANDERSON: Andrew was speaking for the 11

position of OSRAM SYLVANIA

. 12

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

yes, go ahead. 14

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

a Philips outdoor ballast for street lighting that 16

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

volts. 18

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

ahead. 20

MR. ERHARDT : There are

-- in order to 21

avoid issues in the field, most applications are 22

employing addition al transient protection. 23

MR. BROOKMAN: Okay. So it seems like 24

we’re talking about a smaller subset of this. 25Executive Court Reporters (301) 565

- 0064 78 Rebecca, go ahead. 1

MS. RAINER: Just a comment for the 2

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

standards for the area and roadway lighting in the 4

utility division. The requirement in ANSI 136 is 5

10KV for outdoor lighting. 6

MR. BROOKMAN: Okay. 7

MR. WALKER: Mimi has a comment or a 8

question? 9

MR. BROOKMAN: Mimi. 10

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

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

certification. If you’re switching from a lower 13

efficiency magnetic ballast to a higher efficiency 14

magnetic ballast, does that require new UL 15

certification? 16

MS. RAINER: Any change to the ballast or 17

the electricals of a produc t, if it has any bearing 18

on the thermal issues, yes, it will require 19

additional testing. 20

MR. BROOKMAN: Is it

-- a full 21

recertification or i s i t a nudge, for lack of a 22

technical term? 23

MS. RAINER: It would depend on the 24

product. Sometimes it could ve ry well be a full 25Executive Court Reporters (301) 565

- 0064 79 recertification. Sometimes it will be simply 1

opening the file, retesting and recertifying the 2

data. 3

MR. BROOKMAN: Okay. Bob. 4

MR. ERHARDT : Just one comment again on 5

transient protection. Ten KV is an outdoor 6

requirement. Electrom agnetic ballasts can withstand 7

anywhere from

-- at least some product

-- some of 8

our product has been tested from 15 to 20 KV 9

transient protection, transient capability, and so I 10

still am speaking for our company, of the opinion 11

that electromagnetic produc t, even when electronic 12

product has ten KV capability, electromagnetic 13

product is still more robust. 14

MR. BROOKMAN: Okay. So yes, Cheryl 15

English. 16

MS. ENGLISH: Cheryl English, Acuity 17

Brands. On the UL recertification question, I think 18

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

lot of extras are not just drop

- ins, so there’s the 20

engineering time associated with redesigning a 21

ballast housing, the testing associated with that, 22

the in

- house engineering, the extra cost of the 23

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

certifying organizations or CSAs, so there is 25Executive Court Reporters (301) 565

- 0064 80 certainly a lag to market in our ability to get 1

those products out quickly to the marketplace. 2

MR. BROOKMAN: Thanks. Okay. 3

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

note? 5

MR. BROOKMAN: Mimi, please. 6

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

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

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

but getting the actual costs to these issues so that 10

they can be taken into accou nt in the analysis 11

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

So I know you guys are going to be submitting 13

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

could provide to the Department of Energy, I think 15

that would be really useful. 16

MR. BROOKMAN: Keith, go ahead. 17

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

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

address those issues. 20

MR. BROOKMAN: Even aggregated at NEMA, 21

huh? 22

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

it’s still very diffi cult because in order to 24

aggregate it, we have to discuss it, and we’re not 25Executive Court Reporters (301) 565

- 0064 81 allowed to do that, so

-- 1

MR. BROOKMAN: It can be disclosed, though 2

-- I mean it can be

-- well, it would be good if you 3

could do it.. Bob. 4

MR. ERHARDT : Bob Erhardt , Philips 5

Lighting and Electronics. Also a general comment. 6

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

to implement electronic ballast luminaires need to 8

be redesigned, if you go to Light fair you’ll see 9

that many, if not most luminaire manufacturers are 10

dedicating their engineering resources to 11

implementing other technologies rather than 12

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

a requirement that luminaire manufacturers redesign 14

their mature technologies, you may be precluding 15

them from develo ping new products using SSL and 16

dimming systems and other areas where the industry 17

has been concentrating its effort. 18

MR. BROOKMAN: Okay. All productive 19

comments. Additional comments before we move on? 20

MR. WALKER: All right. So this last 21

slide of engineering summarizes the manufacture 22

production costs of the ballast component and the 23

empty fixture component, as well as the overall 24

fixture MSP. This is done as an example with the 25Executive Court Reporters (301) 565

- 0064 82 equipment class for th e 250 to 500 watt group. 1

Notice that the ballast price has a fairly large 2

increase from CSL

- 2 to CSL

- 3, and this represents 3

the transition from magnetic to electronic ballast. 4

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

change with efficiency in t he preliminary analysis. 6

Now we’ve received a lot of comments today 7

about how that may not be the case in electronic 8

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

need to be redesigned. 10

DOE based this preliminary determination 11

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

which an electronic ballast could fit in a fixture 13

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

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

weights involved with magnetic and electronic 16

ballast and some electr onic ballasts actually tended 17

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

So based on this, the empty fixture cost 19

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

based on a tear down of the representative fixtures 21

that we talked about earlier, a nd all those costs 22

were averaged together. 23

So at this time we would request comments 24

on these costs and prices as well as in particular, 25Executive Court Reporters (301) 565

- 0064 83 the maximum technologically feasible ballast 1

efficiency and its associated MSP, especially if 2

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

tables. That’s all. 4

MR. BROOKMAN: Justin. 5

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

our written comments to go more in depth here. 7

MR. BROOKMAN: Thank you. Additional 8

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

a dditional comments at this time. Okay. 10

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

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

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

10:45. 14

While you’re here in the For r estal 15

Building you need to wear this v isitor’s badge and 16

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

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

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

almost directly beneath us. If you go to the 20

elevator bank and down to the ground floor. Please 21

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

down there now. They changed over the service 23

orientation and so go quickly if you want coffee. 24

(Whereupon, the meeting was recessed for a 25Executive Court Reporters (301) 565

- 0064 84 16 minute period.) 1

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

on the

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

the W eb [participant s ] ready to go? Let me 4

encourage those that are joining us via the W eb, 5

we’re prepared today to try to answer questions 6

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

We’re going to move directly into e nergy 8

use, mark

- ups analysis, and hear from Michael Myer. 9

**Energy Use and Mark**

**- ups Analysis**  10

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

just to finish sitting. 12

(Pause.) 13

MR. MYER: Great, looks like everyone is 14

suf ficiently hydrated, and if someone comes in late, 15

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

professes. We’re starting energy use, mark

- ups 17

analysis, which will feed into the life cycle and 18

payback analyses. 19

This graphic shows the relationship t o 20

each other, where the energy use

-- how often a 21

fixture is used and the energy consumed, multiplied 22

by electricity price will feed into life cycle cost. 23

The markup of the equipment will also factor into 24

both the life

- cycle cost and the payback analyses. 25Executive Court Reporters (301) 565

- 0064 85 Energy is pretty straight forward. It’s 1

power multiplied by operating hours. DOE developed 2

this input power

-- you’ve seen these values earlier 3

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

together. On the left hand side you have the 5

representative wattage class, and on the right hand 6

side, you have the baseline and corresponding CSL 7

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

this point in the presentation. 9

Moving to the next slide. DOE developed 10

average annual operating hours by looking at a 11

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

Lighting Market Characterization, which is a survey 13

of installed equipment and fixtures. CBECS, which 14

is the Commercial Building Energy Consumption 15

Survey, which is how buildings use

-- how buildings 16

are operated and energy usage of those buildings. 17

And then MECS, which is the Manufacturing Energy 18

Consumption Survey, which just dictates

-- helps 19

determine the probability of a certain building type 20

existing. 21

DOE then takes those data sources and 22

aggrega tes it, along with census data, to take care 23

of regional differences in population, and DOE 24

developed average annual operating hours shown in 25Executive Court Reporters (301) 565

- 0064 86 the table below by sector on the left, and average 1

annual operating hours on the right, in hours. 2

Moving into th e next slide, that data in 3

the last two tables multiplied together, so you have 4

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

annual operating hours shown in the previous slide 6

multiplied together, and you get the annual energy 7

usage. 8

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

the representative wattage and the baseline CSL on 10

the right hand side. All values here are in 11

kilowatt hours. Pretty straightforward. 12

And moving into the next slide. This 13

brings up issue ES

- 27, DOE is requesti ng comment on 14

the methodology and the assignment that we used, 15

using Lighting Characterization as a data source, 16

using Commercial Building Energy Consumption Survey 17

as a source, using the Manufacturing Energy 18

Consumption Survey as a source. DOE welcomes 19

c omment on the basis and assignment of the end user 20

operating profiles for the fixtures covered in this 21

rulemaking. 22

MR. BROOKMAN: Justin. 23

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

we will address this in our written comments. 25Executive Court Reporters (301) 565

- 0064 87 MR. BROOKMAN: I know the Department’s 1

looking forward to that. 2

MR. NEUMANN: You just record it and every 3

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

MR. BROOKMAN: Just to elaborate on that, 5

I’m certain the Department would like those comments 6

sooner rather than later

. 7

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

be frank, the short timeframe between the publishing 9

of the Federal Register

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

timeline as well, as you know. Bob. 14 document and this meeting 10

gave us very little time to prepare our comments for 11

the public meeting. 12

MR. ERHARDT : Yeah, the other comment is 15

we are also just a little bit occupied with the 16

fluorescent rulemaking happening at the same time. 17

MR. BROOKMAN: Yeah. 18

MR. ERHARDT : And the California Energy 19

Commis sion Title 24 revisions, so this is

-- we had 20

three major sets of documents released within one 21

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

MR. BROOKMAN: We appreciate that, and in 23

fact we appreciate your diligence here as well. So 24

then you see the comment box, and let’s see if we 25Executive Court Reporters (301) 565

- 0064 88 can get any additional comments or early lead as to 1

how the Department is doing with these tables, if 2

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

Okay. Great. 4

MR. MYER: Continuing on into the markup 5

analysis. So DOE developed a markup analysis to 6

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

the lower left hand

-- represented in this diagram 8

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

moves through the distribution channel, first to a 10

wholesaler, then to a contractor, then sales tax 11

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

To determine the wholesaler markup, DOE 13

used publicly available data from the Securities and 14

Exchange Commission for 10K as we’ve discussed 15

beforehand, and that’s how we d etermined the 16

wholesaler markup which we’ll discuss in the next 17

slide, as well as the other two markups. 18

So this slide shows the relationship 19

between the baseline markup and the incremental 20

markup. Let me first define those terms. The 21

baseline markup i s the markup associated with just 22

the baseline equipment. The incremental markup is 23

the additional markup applied to a more efficient 24

version. So, for instance, if the fixture costs 25Executive Court Reporters (301) 565

- 0064 89 $100 and a more efficient version costs $120, the 1

first hundred dollars is applied the baseline, the 2

additional $20 is applied to the incremental markup 3

-- the incremental markup applies to the additional 4

$20 dollars. 5

Other information on this slide. Of 6

course, sales tax is the same in both columns 7

because it is applied in the same way in both 8

situations. This data was developed looking across 9

publicly available information of states sales tax, 10

comes out to just over seven percent. 11

Contractor markup, this is 13 percent. 12

The Department of Energy uses in a number of 13

lig hting rules, and it would welcome any comments at 14

this point. 15

And then you have the baseline markup

-- 16

then you have the electrical wholesaler markup. The 17

difference

-- the prime difference between the 18

baseline is this is calculated by net sales over 19

co st of sales, whereas the incremental markup is 20

calculated by the operating profit divided by cost 21

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

incremental markup is smaller than the baseline 23

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

at this moment. 25Executive Court Reporters (301) 565

- 0064 90 MR. BROOKMAN: Would you restate what the 1

difference between baseline and incremental markup? 2

MR. MYER: Sure. Baseline is calculated 3

by taking the net sales dividing by the cost of 4

sales, whereas the incremental markup is the 5

operating profit divide d by cost of sales. And 6

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

MR. BROOKMAN: Thank you. Oh, Bob 8

Erhardt

. 9

MR. ERHARDT : Yeah, Bob Erhardt , Philips 10

Lighting Electronics. Does the DOE have some 11

documentation of how it comes up with a 13 percent 12

marku p for contractor, and 23 and five percent for 13

the

-- well, contractor markup and wholesaler 14

markup? 15

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

Support Document, Markup Analysis , discusses each of 17

these three values separately. As I said before, 18

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

the states. 20

The wholesaler markup is looking at 21

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

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

fluorescent ballast rule already, they also have 24

that same comment about the relation between what 25Executive Court Reporters (301) 565

- 0064 91 DOE estimated and the accuracy. And in the 1

fluorescent lamp ballast documentation and their 2

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

there is a good correlation between DOE and their 4

markup analysis for the electrical wholesaler. 5

For the contractor, the documentation, 6

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

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

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

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

supporting documentation, but it is a historic value 11

that maybe needs re

- evaluation. 12

MR. ERHARDT : Thank you. 13

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

comment box. 15

MR. MYER: Yes, so this is issue ES

- 29, 16

which we welcome any comments from anyone who knows 17

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

metal halide lamp fixture pricing data that we could 19

use to verify the markups as developed for the 20

preliminary analysis. 21

MR. BROOKMAN: Justin. 22

MR. NEUMANN: NEMA cannot discuss th is 23

publicly because of antitrust issues. 24

MR. BROOKMAN: And will you, though, try 25Executive Court Reporters (301) 565

- 0064 92 to send some stuff? 1

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

if we can. 3

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

MS. RAINER: Just a general comment. The 5

analysis t hat you did does cover many of our 6

shipments or sales, but here also is another channel 7

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

quite different than the channel that you have 9

listed here. 10

MR. BROOKMAN: Can you say what the steps 11

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

MS. RAINER: There are different scenarios 13

with different areas of the country. Many times, 14

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

Sometimes it is the manufacturer to an electrical 16

distributor to th e utility. 17

MR. BROOKMAN: Okay. 18

MR. MYER: So it appears that in that 19

situation, the contractor in a manufacturer to 20

distributor to utility, the contractor is 21

sidestepped in that situation? 22

MS. RAINER: In most cases, yes. 23

MR. MYER: Thank you. 24

MR. MYER: And sales tax would be 25Executive Court Reporters (301) 565

- 0064 93 applicable in either way, of course. 1

MS. RAINER: Yes. 2

MR. MYER: Great. 3

M R. BROOKMAN : Could you say? Is that

-- 4

is that pathway a big chunk of sales? 5

MS. RAINER: I think it probably varies by 6

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

sizable portion of our sales. 8

MR. MYER: Sales of metal halide fixtures 9

or outdoor roadway fixtures? 10

MS. RAINER: Well, sales of outdoor 11

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

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

MR. MYER: Thank you. 14

MR. BROOKMAN: Thank you. Additional 15

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

Okay. 17

MR. MYER: At this point, our schedule 18

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

early for lunch. 20

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

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

going to introduce Scott Morris to discuss life

23

cycle cost and payback analyses. 24

MR. BROOKMAN: Scott Morris. 25Executive Court Reporters (301) 565

- 0064 94 MR. MORRIS: Thank you, Michael. Good 1

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

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

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

So I apologize. 5

MR. BROOKMAN: Be careful

-- so what we’ve 6

ascertained is that the presenter does not know the 7

target au dience. 8

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

sorry. 10

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

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

don’t worry. 13

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

the first day of Earth Week at the Department of 15

Energy. Yay, Earth ! 16

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

Onward. 18

MR. MORRIS: Okay. Down to business. 19

**Life**

**- Cycle Cost and Payback Analyses**  20

MR. MORRIS: The Life

- Cycle Cost and 21

Payback Analyses combine results from the 22

engineering analysis, the energy use 23

characterization, and the markups analysis to make 24

comparisons between candidate standard levels within 25Executive Court Reporters (301) 565

- 0064 95 equipment classes. The life

- cycle cost analysis, as 1

you can see, is also used as

-- some of the results 2

from the life

- cycle cost analysis are used as inputs 3

for the national impact analysis. 4

Life

- cycle cost and payback periods are 5

monetary means of comparing fixtures within 6

equipment classes. Life

- cycle costs are the total 7

costs of ownership for a given fixture, and payback 8

period calculations in dicate how many years it takes 9

to payback the

-- for an individual consumer to 10

recover the incremental cost differences between a 11

baseline fixture and a more efficient fixture 12

system. 13

The chart up here is best and easiest 14

understood reading from right to left. The life

15

cycle cost for a fixture is calculated by adding the 16

total installed cost of a fixture to the sum of 17

discounted annual operating cost s across the 18

lifetime of the fixture. The installed fixture 19

costs include the equipment and labor associated 20

with installing an entire lamp, ballast, and fixture 21

system. 22

Annual ownership, in the middle here, 23

annual ownership or operating costs include 24

an nualized lamp replacement costs, annualized 25Executive Court Reporters (301) 565

- 0064 96 ballast replacement costs, and the cost of 1

electricity for a fixture within a year. Note that 2

the energy use characterization provides inputs to 3

the annual operating costs and the mark up analysis 4

provides inputs to the installed fixture cost, which 5

affects the initial price of a fixture. 6

One of the important inputs for the life

7

cycle cost calculations include s lifetime 8

assumptions for fixtures, ballasts, and lamps. 9

Perhaps of most interest to DOE at this 10

po int is receiving input concerning assume d lifetime 11

values for interior and exterior fixtures. We 12

talked earlier that DOE does not set standards by 13

application, but in our analyses, we used 14

distinctions between interior and exterior fixtures 15

to develop lif e

- cycle cost. 16

In

-- sorry, at this point interior 17

fixtures

-- yes. 18

MR. COOK: Could you back up just one 19

slide? I do have a comment on that. 20

MR. BROOKMAN: Keith Cook. 21

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

to incorporate possibly a cost for red esigning 23

fixtures for subsequent years. It’s not included 24

here and if, for some reason, you decide to go from 25Executive Court Reporters (301) 565

- 0064 97 a magnetic ballast to an electronic ballast, there 1

is a redesign cost that has to be captured. 2

MR. BROOKMAN: Thank you. 3

MR. MORRIS: Any fur ther comments? Thank 4

you. Okay. In the framework stage of this 5

rulemaking, we received

-- there were comments and 6

discussions concerning ballast lifetimes, and DOE 7

understood that magnetic ballasts last longer than 8

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

versus 30,000 hours for ballast lifetimes. And 10

finally, given the relatively short lifetime of a 11

ballast, and the relatively longer lifetime of a 12

fixture, you can

-- I guess it would be intuitive to 13

think that during the lifetime of a given fix ture, 14

we would be replacing at least one ballast. And 15

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

minutes. 17

Now, the

-- assume d values for lamp 18

lifetimes come from the high

- intensity discharge 19

lamps determination, and that’s been discussed 20

previo usly in that determination. Any further 21

comments on this slide? 22

MS. MAUER: Joanna Mauer. I may have 23

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

data source for the lifetimes of magnetic versus 25Executive Court Reporters (301) 565

- 0064 98 electronic ballasts? 1

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

be from the framework stage of this rulemaking. 3

MR. MYER: DOE received comment during the 4

framework portion of it that magnetic ballast had a 5

longer life, so industry submitted comments on the 6

estimated life between both magnetic and elec tronic 7

ballasts. If there’s an industry representative who 8

might be able to validate those values? 9

MR. BROOKMAN: Joe, please. 10

MR. HOWLEY: Actually I wanted to make a 11

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

a comment on the lamp lifetime s. The lamp lifetimes 13

listed appear to be for vertical lamp operation, and 14

this is one of the lighting technologies that is 15

affected by orientation. When you burn them 16

horizontally they will have a shorter lamp life, so 17

this would provide a more aggressi ve idea of how 18

long the lamps will last. A significant number of 19

metal halide fixtures do operate the lamps 20

horizontally, and would have a reduced lifetime. It 21

would probably be averaged into your lifetime 22

considerations. 23

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

that estimate across the industry? 25Executive Court Reporters (301) 565

- 0064 99 MR. HIRT: Just a comment. It’s not true 1

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

life is 25 percent shorter for many lamps. Some 3

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

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

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

Joanna Mauer. 7

MS. MAUER: Joanna Mauer. Just one more 8

question. I was wondering if anyone could comment 9

on whether lamps operated with electronic ballasts 10

have longer lifetim es than operated with magnetic 11

ballasts? 12

MR. BROOKMAN: Tom? 13

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

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

think have already incorporated those electronic 16

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

c omplicated situation, and it’s highly variable 18

among manufacturers. 19

MR. BROOKMAN: The rating comes from the 20

manufacturer? 21

MR. HIRT: Yes. 22

MR. BROOKMAN: I see. 23

MR. MORRIS: Can anybody offer comment on 24

perhaps the ratio or the mixture

-- the perce ntage 25Executive Court Reporters (301) 565

- 0064 100 of fixtures that have longer and shorter lifetimes , 1

and how it varies by equipment class or wattages? 2

MR. BROOKMAN: Joe Howley. 3

MR. HOWLEY: Perhaps NEMA could provide 4

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

think we have anything rig ht at hand right at this 6

moment. 7

MR. BROOKMAN: Thank you. Okay. 8

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

comment in the opening statements regarding the 10

slight modifications in payback periods, to cut to 11

the chase, the two versions that Bob was lo oking at, 12

the difference between payback period was due 13

primarily, well not primarily, it was due to 14

differences in markups. During our quality 15

assurance testing between two weeks ago and a week 16

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

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

So we corrected for the over

-- we corrected for the 19

larger markups and that’s where that discrepancy 20

came from. 21

The next three slides

-- 22

MR. BROOKMAN: Yes, Bob. 23

MR. ERHARDT : It wasn’t a small 24

discrepa ncy. It was a factor of three. 25Executive Court Reporters (301) 565

- 0064 101 MR. BROOKMAN: And you don’t see that 1

reflected in this table, Bob? 2

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

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

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

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

MR. BROOKMAN: Susan, please, the 7

microphone. 8

MS. ANDERSON: There were payback periods 9

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

then suddenly this version

-- I discovered it in the 11

document this past Friday. 12

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

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

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

corrected that

-- those changes were incorporated 16

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

documen ts. 18

MR. BROOKMAN: What we see here is the 19

most current version. 20

MR. ERHARDT : Thank you. 21

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

discuss and give the results for the life cycle cost 23

and payback period analyses . There are really four 24

things to note, four things of importance. 25Executive Court Reporters (301) 565

- 0064 102 1. Whether the calculated life

- cycle cost 1

savings are positive or negative. 2

2. The calculated and available or 3

unavailable, according the s l i d es, payback 4

periods. 5

3. The first primary reason for positive 6

life

- cycle cost versus negat ive life

- cycle 7

costs and available or unavailable payback 8

periods, which is primarily due to 9

substantial efficiency gains between CSLs 10

within equipment classes. 11

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

morning ; the second primary reason for 13

these differences in positive and negative 14

values due to a transition from magnetic 15

to electronic ballast types, which is 16

necessary as we increase CSLs. 17

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

watt and 400 watt equipment classes , the higher 19

efficiency fixtures use electronic ballasts. 20

Electronic ballasts are shorter lived than magnetic 21

ballasts. The equipment and the labor costs of 22

replacing electronic ballasts more frequently 23

overshadow the cost savings realized by reduced 24

ene rgy costs. 25Executive Court Reporters (301) 565

- 0064 103 To illustrate this point in terms of 1

payback periods, the annual ownership or operating 2

costs for fixtures with electronic ballasts are 3

greater than the operating costs for fixtures using 4

magnetic ballasts. 5

MR. BROOKMAN: Charlie Stephens. 6

MR. STEPHENS: Charlie Stephens. Is there 7

some reason why you annualized the maintenance costs 8

for that kind of a maintenance activity that’s 9

actually incurred on a periodic basis

-- seven, 10

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

actually does

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

use the capital replacement cost methodology there 13

instead of annualizing this stuff. In a net present 14

value kind of calculation, it makes it a fairly 15

significant difference. 16

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

p erhaps for the sake of brevity, it would be best 18

for me to respond in written comments, but I 19

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

wondered about myself. Well, something we’ve 21

considered, definitely. 22

MR. BROOKMAN: Okay. 23

MR. MORRIS: The results for the 250 and 24

400 watt equipment classes are similar to the 25Executive Court Reporters (301) 565

- 0064 104 results in the 70 watt equipment class. Fixtures at 1

lower CSLs, including the baseline, operate magnetic 2

ballasts, and fixtures at the higher CSLs operate 3

electronic ballasts. 4

MR. ERH ARDT : Excuse me? 5

MR. MORRIS: Yes, sir. 6

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

MR. ERHARDT : Bob Erhardt , Philips 8

Lighting Electronics. How does the

-- I’m very 9

confused by your life

- cycle cost versus payback 10

period ratios. 11

MR. MORRIS: Okay. 12

MR

. ERHARDT : How is it that baseline one 13

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

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

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

and has almost a two to one difference in payback 17

period? How do you come up with that? 18

MR. MORRIS: Good question. That’s 19

primarily due to discounting of operating costs over 20

time. So the idea that

-- let’s see how I can put 21

this briefly

-- the idea that energy savings and 22

more expensive costs today are worth m ore to you 23

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

It’s simply an artifact of the calculations, and 25Executive Court Reporters (301) 565

- 0064 105 discounting. Good question, though. 1

The 1000 watt equipment class is slightly 2

simpler to look at tha n the other equipment classes. 3

All fixtures in this equipment class, as we have 4

discussed previously, operate magnetic ballasts and 5

these

-- this equipment class operates

-- or the 6

fixtures in this equipment class are inherently more 7

efficie nt than lower wattage fixtures. 8

S o this brings us to E xecutive Summary 9

issue 30. We talked about the assumed lifetime 10

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

especially interested in comments concerning the 12

values for the equipment used in this rulemaking, 13

whether they be fixture lifetimes, balla st 14

lifetimes, or lamp lifetimes. 15

MR. BROOKMAN: So there you see all of 16

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

we have any comments at this time. 18

MS. JOYCE: Elizabeth Joyce. Just wanted 19

to comment, it was previously mentioned that for 20

e lectronic ballasts, they may improve the lamp life 21

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

suggest that DOE perhaps take that into account when 23

considering electronic ballasts, that there might be 24

a longer lamp life, necessitating fewer lamp 25Executive Court Reporters (301) 565

- 0064 106 repla cements. 1

MR. BROOKMAN: Thank you. Bob Erhardt

. 2

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

electronic ballast systems with lamps can have 4

improved lumen maintenance. The difficulty is that 5

there is not agreement from lamp manufacturers to 6

rate their lamps differently, generically using 7

electronic ballast. And speak ing from my own 8

company’s experience, some electronic ballasts can, 9

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

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

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

the question of lamp failures, many manufacturers do 13

publish lamp mortality curves. The lamps do not all 14

fail exactly at their rated lives, but they fail 15

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

These are commonly available, you should be able to 17

get some representative samples of lamp mortality 18

c urves if you’re trying to estimate lamp life 19

failure mechanisms within your models. 20

MR. BROOKMAN: Thanks. You can see the 21

comment box there, ES

- 30. Assume lifetimes, how 22

they vary within representative equipment classes, 23

et cetera. Other comments? 24

MR. JOHNSON: One more thought

-- 25Executive Court Reporters (301) 565

- 0064 107 MR. BROOKMAN: Andrew, I don’t think 1

you’re on. 2

MR. JOHNSON: Andrew Johnson. In these 3

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

we had the electronic ballast, we could do some 5

dimming, or we could do dimmi ng with magnetic 6

ballasts too, that would affect some of the energy 7

consumptions to consider. 8

MR. BROOKMAN: Thank you. Final comments 9

on this issue box? Keith. 10

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

really understand this question, because it implie s 12

that all equipment is used beyond their average 13

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

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

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

they want a fresh update, or they want higher 17

efficien cy. And so they’re replacing perfectly 18

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

sure that I necessarily agree with the way this 20

particular question is being asked. It doesn’t 21

always go beyond their average lifetime. 22

MR. BROOKMAN: Okay. 23

MR . MORRIS: If I may, Doug? 24

MR. BROOKMAN: Yes, please. 25Executive Court Reporters (301) 565

- 0064 108 MR. MORRIS: That’s a good question, thank 1

you. Something I should have mentioned earlier. In 2

the preliminary analysis portion of this rulemaking, 3

DOE assumed fixed lifetimes for life

- cycle cost 4

purposes for fixtures, and in the national impacts 5

analysis

-- we’ll talk about that in a minute

-- we 6

have assumed lifetime distributions for fixture 7

lifetimes, which incorporate things such as early 8

replacement of fixtures. And in the NOPR stage of 9

this rulemaking, DOE will also consider 10

distributions of lifetime

-- distributions of 11

fixture lifetimes for LCC purposes. So thank you 12

for that point. 13

And as far as the last sentence there, I 14

agree with you that sentence could be read to imply 15

that everythi ng lasts beyond their rated lifetime, 16

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

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

thank you. 19

MR. BROOKMAN: Final comments on this? 20

Yes, please. 21

MR. STEVENS: Mike Stevens, Georgia Power. 22

I s electricity price

-- is there details on what 23

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

assumptions on the calculations? 25Executive Court Reporters (301) 565

- 0064 109 MR. MORRIS: Yes, absolutely. In the 1

Chapter 8 technical support document, it goes 2

through all the detailed electricity p ricing, 3

electricity price change forecasting that DOE used 4

for the analysis. So everything and more than you 5

want to know would be in Chapter 8. 6

DR. KAARSBERG: Can I make a comment? 7

MR. BROOKMAN: Yes, Tina. 8

DR. KAARSBERG: Hi, I have a comment 9

tha t’s actually a little bit more related to what we 10

were talking about earlier when we talked about 11

different CSLs, different classes, and some of you 12

raised the issue of indoor versus outdoor. And of 13

course the answer is we don’t regulate by 14

application

– in

- or outdoor applications. 15

However, I’ve been talking with our 16

C ounsel here, or exchanging notes, and he has 17

indicated that you could regulate according to 18

characteristics such as whether or not a fixture is 19

waterproof, whether it’s reliable under a ve ry wide 20

range of temperatures, shatter proof, wind proof up 21

to 50 miles an hour

-- very specific type s of 22

characteristics could form a type of class as long 23

as it’ s according to specific characteristics. 24

He hasn’t shaken his head no yet, so I 25Executive Court Reporters (301) 565

- 0064 110 guess I’m o kay. But I just wanted to mention that 1

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

that a lot of these fixtures are used in outdoor 3

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

you had any characteristics you would suggest to 5

distinguish the indoor versus outdoor, that would be 6

very helpful to us. Thank you. 7

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

let’s proceed. 9

**National Impact Analysis** 10

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

National Impact Analysis. Whereas the life

- cycle 12

cost and payback period analyses calculate the cost 13

of fixture ownership for an individual consumer, the 14

national impact analysis calculates the energy 15

savings and economic impact to the nation as a 16

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

analysis, the nat ional impact analysis also requires 18

another set of inputs. These are fixture shipments. 19

In overly simplistic terms, the shipments 20

analysis multiplie s the energy use and cost of one 21

fixture, by the number of fixtures that will exist 22

in the country during the analysis period, and the 23

national impact analysis tells us how much energy 24

and money the country could save as a whole, as a 25Executive Court Reporters (301) 565

- 0064 111 result of an amended standard. 1

DOE used a three step process to calculate 2

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

shipments, kind of that link between life

- cycle cost 4

inputs and national impact analysis. 5

**•** First, DOE used NEMA and the US Census 6

Current Industrial Reports data to develop 7

historical metal halide lamp fixture 8

shipments. 9

**•** Second, DOE calculated an installe d national 10

stock of metal halide lamp fixtures. 11

**•** Finally, DOE developed future , projected 12

fixture shipments and stock based on several 13

quantities, such as fixture lifetimes, 14

replacement and fixture growth rates or 15

replacement growth rates, retirement rates, 16

and the rate at which other sort s of ( new 17

and/or existing ) emerging technologies are 18

encroaching and displacing the shipments of 19

metal halide lamp fixtures. 20

To get into a little bit more of the 21

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

my colle ague Michael Myer to talk about how we 23

developed our shipments analysis. 24Executive Court Reporters (301) 565

- 0064 112 MR. MYER: Thanks, Scott. So the 1

Department of Energy published in June 2010, the HID 2

Lamps Determination . Of course HID lamps has been 3

talked [about] on again and off again durin g this 4

meeting. HID lamps cover metal halide lamps as well 5

as other technologies. 6

The Department of Energy had robust data 7

about HID lamp shipments from as early as 1990 all 8

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

limited in that it stopped at 2001. By actually 10

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

significant trend that roughly 37 percent of lamp 12

shipments corresponded with the same fixtures 13

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

And so we actually liked that, it see med really 15

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

through developing some historical values as well as 17

projecting those values into the future. 18

This chart is base case shipment s . Base 19

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

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

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

the 400 watt are in the same equipment class

-- I’m 23

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

superimposed over each other. This shipments graph 25Executive Court Reporters (301) 565

- 0064 113 assumes that over time, emerging technologies or 1

existing technologies will encroach somewhat on 2

metal halide shipments at some point. 3

We heard during the framework analysis

-- 4

framework public meeting, that interior applications 5

of metal halide had been replaced by linear 6

fluorescents portion and from our own analysis, we 7

would agree with that. We also are taking into 8

account that over time, both new technologies, such 9

as LED or induction or possibly new emerging 10

technologies will encroach somewhat on metal halide 11

s hipments as well. 12

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

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

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

on either of these slides, 62 or 63? 16

MR. MYER: I want to just advance to the

- 17

- actually this is

-- 18

MR. BROOKMAN: Bob Erhardt

. 19

MR. ERHARDT : The previous slide, this 20

slide. 21

MR. MYER: Yes. 22

MR. ERHARDT : Now you’ve indicated that 23

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

you get your projection of increased sales from 2014 25Executive Court Reporters (301) 565

- 0064 114 to 2020? 1

M R. MYER: Well, actually, this graph 2

would start in 2015, the effective date of the 3

standard and goes up to

-- predicts the future up 4

until 2020 plus. 5

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

at the chart, you have a significant growth between 7

2015 and 2025, let’s say. 8

MR. MYER: Yes. 9

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

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

and HO is making some inroads on interior metal 12

halide, and I know that solid

- state lighting is 13

making some inroads in exterior metal halide. So 14

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

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

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

follow, based on those two trend s that I just 18

mentioned. 19

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

lamps determination, we projected the growth of HID 21

lamps into the future, and in that we actually 22

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

relationship

-- that 37 percent of lam p shipments 24

correlate to fixture shipments, we proposed that 25Executive Court Reporters (301) 565

- 0064 115 relationship in the absence of more articulated 1

data. 2

MR. ERHARDT : And Bob. 3

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

your projection of increased HID lamp shipments? 5

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

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

in having two separate rulemakings. From an 8

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

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

know that solid

- state lighting and T8 fluo rescent is 11

making inroads on interior high bay, and SSL is 12

making inroads on outdoor. 13

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

this graph tries to represent is that in the near 15

term, when these newer technologies such as LED or 16

induction are more expens ive right now, probably in 17

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

- 18

- probably around

-- somewhere after 2020, they will 19

actually become more cost effective, and you will 20

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

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

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

actually what we would actually request comment on 24

32. This is just preliminary analysis, and DOE 25Executive Court Reporters (301) 565

- 0064 116 would appreciate any prognostications into the 1

future on shipments of metal ha lide fixtures, both 2

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

projecting

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

2046. 5

MR. BROOKMAN: So, Rebecca. 6

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

speaking on Cooper Lighting’s benefit, my chart 8

would b e very different than your chart as far as 9

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

solid

- state lighting progressing much more quickly. 11

MR. MORRIS: Both interior and exterior, 12

or do you think the fluorescent will attack the 13

interiors? 14

MS. RAINER: I think fluorescent on the 15

interior side, and solid

- state lighting on the 16

outdoor side. 17

MR. BROOKMAN: So the ramp up to 2015 18

would be a lot shallower? 19

MS. RAINER: Absolutely. 20

MR. BROOKMAN: Okay. 21

MR. MORRIS: But for the low wattage and 22

high wattage? 23

MS. RAINER: I see more in that medium 24

wattage range, but I also do see it in the lower 25Executive Court Reporters (301) 565

- 0064 117 wattage. I think our chart would look much 1

different than yours. 2

MR. BROOKMAN: Keith, perhaps

-- 3

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

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

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

would be flat, even with the growth being 7

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

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

although there would be some. 10

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

helpful to the Department to get that 12

representation. Also, any additional details you 13

can provide in writing . I saw Bob. 14

MR. ERHARDT : Yes, I was just

-- I was 15

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

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

arguments that in outdoor solid

- state lighting 18

already is cost

- justified and that you’ll hear

-- 19

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

that you can save energy and have a significan t 21

return on investment by going

-- and this is another 22

area where NEMA has made the general comment to the 23

Department of Energy that we strongly support system 24

approaches, because what is happening is a reason 25Executive Court Reporters (301) 565

- 0064 118 that fluorescent is making such inroads on int erior 1

is because of dimm ability, and the ability to have 2

occupancy sensing. 3

And if

-- I mentioned, we’re 4

simultaneously working with California Energy 5

Commission on Title 24 regulation. They are almost 6

abandoning their demands on Title 20 appliances, and 7

they are focusing completely on systems approaches, 8

saying that you must use controllable lighting 9

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

percent improvements in energy savings using 11

controllable lighting and we’re here talking back 12

and for th about two and three percent energy 13

savings. We see it as being counterproductive 14

because if we are ever being forced to redesign 15

mature product lines for two percent or three 16

percent energy savings, and neglecting the 17

opportunities for 20 to 50 percent energy savings, 18

we see that as being counterproductive. 19

MR. BROOKMAN: Cheryl first. 20

MS. ENGLISH: Cheryl English, Acuity 21

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

did provide cost information in these market trends 23

through our Navigant manufa cturer impact interviews. 24

Was that factored into these analysis? 25Executive Court Reporters (301) 565

- 0064 119 MR. MYER: No

-- 1

MS. ENGLISH: Because I would say you 2

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

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

think those charts represent what we’ve provided. 5

MR. BROOKMAN: Thank you. Keith. 6

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

to maybe build a little bit upon what Bob was 8

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

opportunity on interior changes due to controls, 10

outdoor also. If you look at such cities as 11

Raleigh, North Carolina, they have adopted a large 12

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

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

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

dimmability, and so the re sult is driving us to new 16

technologies much faster than what you’d normally 17

see. 18

MR. BROOKMAN: Thank you, Joe Howley. 19

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

thinking about the analysis more. It sounds like 21

the last fixture data you had ended in something 22

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

surrogate for fixture sales. We can discuss this 24

within NEMA, but NEMA does track fixture sales, and 25Executive Court Reporters (301) 565

- 0064 120 I believe the metal halide fixture sales

-- looking 1

at someone from the fixture section to

-- 2

PARTICIPANT: (comment off mic) 3

MR. HOWLEY: But is it directional? 4

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

metal h alide versus high pressure sodium? 6

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

relationship? If we set granular fixture

-- no? So 8

can you use that relationship? 9

MR. BROOKMAN: So, Michael, restate what 10

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

MR. MYER: So Joe Howley mentioned that 12

one of the problems

-- one of the limitations was 13

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

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

request data and so we used the step

- in wherein we 16

married the two data together and tried to develop 17

some ideas about shipment s that way. 18

Joe then suggested to some of his NEMA 19

colleagues who were manufacturers of lighting 20

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

data. Lighting manufacturer said that data may 22

e xist, but not at the granularity that we need, 23

because one of the issues is that it probably lumps 24

HID technologies together and it may also, I’m 25Executive Court Reporters (301) 565

- 0064 121 suggesting here, that it may not also break it down 1

by other applications or

-- as Tina mentioned, 2

interior, y ou know, any of the features that we 3

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

still appreciate any data. 5

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

good restatement. Excellent. So then additional

-- 7

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

MR. BROOKMAN: Mimi. 9

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

Does NEMA track metal halide ballast sales by 11

distribution channel? Like for example, OEM or

-- 12

MR. BROOKMAN: Bob. 13

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

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

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

MS. GUPTA: Okay. That could be

-- 17

MR. ERHARDT : There may be a possibility 18

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

numbers. 20

MR. BROOKMAN: Okay. Additional comments 21

in this vein, related to the availability of data 22

and the like? 23

MR. MYER: Which happens to be issues 31 24

and 32, by the way. 25Executive Court Reporters (301) 565

- 0064 122 MR. BROOKMAN: Exactly. Did we state them 1

adequately, Michael, or do you want to reemphasize 2

them? 3

MR. MYER: Just to give everyone one mo re 4

refresher. Issue 31 discussed DOE’s approach of 5

correlating lamp fixture data with HID lamp data, 6

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

on that. I’ll hold for a second. 8

Issue 32 has to do with prognostication 9

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

plateauing of metal halide fixtures, which we’ve 11

also heard some comments on as well. 12

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

Additional comments? Okay. 14

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

turn the presentation bac k to Scott Morris. 16

**National Impact Analysis**

**- Wrap up**  17

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

the final stages of wrapping up the national impact 19

analysis. 20

So the assumptions for everything that 21

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

found in Chapter 9, the shipments analysis. 23

Now, as previously mentioned, the life

24

cycle cost and shipments analyses feed into the 25Executive Court Reporters (301) 565

- 0064 123 national impact analysis. The national impact 1

analysis outputs two important quantities of 2

interest, one of those is national energy savings, 3

the other is national net present value. 4

National energy savings is expressed in 5

terms of quadrillion BTUs or quads, and the economic 6

effect to the nation or the net present value is 7

expressed in billions of dollars. 8

Now, keep in mind for these next two 9

slides, there are several different results that we 10

get from the national impact analysis, depending on 11

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

range of national energy savings, as well as 13

national net present value savings. 14

This image gives the maximum possible 15

energy savings available from an amended standard. 16

This means if the amended standard were to mandate 17

that everything that was at

-- that all the 18

equipment classes were at their maximum CSL, this is 19

the typ e of energy savings curve we would see, which 20

cumulatively speaking, over the 30 years analysis 21

period, amounts to about 1.7 quads of national 22

energy savings. 23

Please consider, though, that DOE does 24

absolutely examine the impacts, the economic impacts 25Executive Court Reporters (301) 565

- 0064 124 of setting standards, and that’s what the net 1

present value analysis

-- or the net present value 2

results

-- take into consideration. 3

MR. BROOKMAN: Hold there. John. 4

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

accumulated curve, not a per year curve? 6

MR. MORRIS: These are

-- since the values 7

here are per year, and then if you

-- essentially if 8

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

the energy savings annually, you would get the 10

cumulative savings over the 30 year period. 11

MR. GREEN: All righ t. Thank you. 12

MR. BROOKMAN: Thank you. Okay. 13

MR. MORRIS: Thank you. Just like the 14

last slide, there are many different scenarios in 15

which national net present value can be calculated. 16

Net present value varies not only by equipment class 17

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

particular image outlines the net present value of 19

an amended standard achieving the maximum energy 20

savings possible, subject to the constraint that the 21

net present value of the amended standard would be 22

positive, that it would actually be beneficial, 23

economically speaking, for the nation. 24

So there are curves we could put up , a 25Executive Court Reporters (301) 565

- 0064 125 national net present value curve that would look 1

different than these, however, not all

-- CSLs are 2

not all amended CSL levels

-- I didn’t say that 3

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

economically viable, but some CSLs could, 5

theoretically increase national energy savings. 6

I’ll rephrase that because that came out 7

all backwards. Higher CSLs can and will save more 8

energy, but th ey may not be economically viable. 9

Better way to put it. Okay. 10

Maybe I can hold it and if anybody has any 11

comments regarding national impact analysis? 12

MR. BROOKMAN: And particularly the 13

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

there are any comment on these. That would be 15

useful. Okay. 16

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

wants to do. 18

MR. BROOKMAN: I want to keep going. 19

MR. MORRIS: Okay. Then we’ll go to 20

Hayden Cook with the manufacturer impact analysis. 21

MR. BROOKMAN: T hat’s my

-- my presumption 22

is that we’re

-- we’ve only got about ten or so 23

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

not going to pause for lunch or anything like that. 25Executive Court Reporters (301) 565

- 0064 126 Let’s go. 1

**Manufacturer Impact Analysis** 2

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

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

manufacturer impact analysis, or the MIA. The 5

purpose of the MIA is to quantitatively and 6

qualitatively assess the impacts of energy 7

conservation standards on manufacturers of metal 8

halide lamp fixture s. The key output of the MIA is 9

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

resulting from these energy conservation standards. 11

DOE normally performs the MIA in three 12

phases which is shown here on the slide. 13

In phase 1, DOE creates an industry 14

profile, building on the market and technology 15

assessment . This market profile is then update 16

through our interviews with manufacturers. This 17

takes place during DOE’s preliminary analysis. 18

During this time DOE identifies the key issues 19

concerning manufa cturers, which brings us to phase 2 20

of the MIA. 21

In the second phase, which spans the NOPR 22

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

industry cash flow model called the Government 24

Regulatory Impact Model, or GRIM, to forecast free 25Executive Court Reporters (301) 565

- 0064 127 industry cash flow in the metal halide industry. It 1

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

case, and calculates the NPV for each of these 3

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

guide that they use to lead subsequent discussions 5

with manufactu rers during MIA interviews which takes 6

place in phase three. 7

In the third phase, DOE interviews a 8

variety of different manufacturers to receive 9

feedback on the items listed in the interview guide. 10

These interviews are conducted under a nondisclosure 11

agr eement so no proprietary information is ever 12

publicly disclosed. Following the interviews, DOE 13

refines the GRIM and evaluates other qualitative 14

issues, such as manufacturer capacity, employment 15

impacts, and impacts on product competition. 16

Moving on to s ome of the key issues for 17

manufacturer analysis. During the preliminary 18

manufacturer interviews, DOE identified several 19

issues concerning manufacturers. 20

**•** First, manufacturers are concerned about 21

profitability impacts due to these amended 22

energy conservatio n standards. 23

Manufacturers believe that they may not be 24Executive Court Reporters (301) 565

- 0064 128 able to pass on cost increases to consumers, 1

which would decrease their profit margins. 2

This problem could be particularly acute in 3

the first cost

- driven original equipment 4

manufacturer distribution channel. Also 5

high costs could drive manufacturer’s 6

customers to shift their businesses to 7

overseas companies who can compete on 8

cheaper level. 9

**•** The second one is market erosion. 10

Manufacturers believe that alternative 11

technologies, such as solid

- state li ghting 12

and fluorescent lighting, which have been 13

discussed previously are eroding the metal 14

halide market, both in indoor and outdoor 15

lighting applications. Higher prices for 16

metal halide lamp fixtures may hasten this 17

switch to these alternative technolog ies. 18

**•** On a related note, manufacturers believe 19

that the standards for metal halide lamp 20

fixtures have high opportunity costs by 21

forcing resources toward upgrading existing 22

product lines. Manufacturer have to divert 23

resources away from product innovation an d 24Executive Court Reporters (301) 565

- 0064 129 emerging technologies, like the two 1

previously mentioned, and then product 2

conversion testing costs. 3

**•** Next, manufacturers are concerned with the 4

product conversion and testing burdens that 5

could result from these amended energy 6

conservation standards. Ma nufacturers 7

expect product development, redesign, and 8

testing requirements which would ultimately 9

result in a more existing, expensive product 10

for consumers. 11

Then we go to a system approach here, and 12

this has been discussed. While DOE is planning on 13

usi ng

-- is planning on regulating the efficiency of 14

metal halide lamps, ballasts only, some 15

manufacturers are concerned with the system

- wide 16

approach of regulating the efficiency of the entire 17

metal halide fixtures. Some manufacturers believe 18

that a system approach could favor specific lamp and 19

ballast combinations and penalize companies that do 20

not package lamps with their ballasts. 21

And then lastly, there’s no

- as has been 22

previously discussed, there’s no ANSI

- testing 23

standard. Some manufacturers are wo rried about 24Executive Court Reporters (301) 565

- 0064 130 setting efficiency standards for electronic ballasts 1

when ANSI currently has no test procedures for such 2

high frequency ballasts. Manufacturers observe that 3

without a test procedure, efficiency measurement for 4

the ballast poses challenges and requires expensive 5

equipment. 6

So at this time, DOE requests comment on 7

some of the characterization s of the key issues that 8

are facing manufacturers and on the regulations 9

contributing to their overall cumulative regulatory 10

burden. That i s ES

- 26 [which] is [on] the cumulative 11

regulatory burden

. ES

- 35 is [on] the identification 12

of key issues facing manufacturers. Many of these 13

points have been brought up previously, but DOE 14

would be very interested in your commenting on this. 15

MR. ERHARDT : Bob Erhardt , Philips 16

Lighting Electronics. Just

-- you mentioned it, and 17

I’d like to expand a bit. It’s not just that ANSI 18

does not have a test procedure for high frequency 19

electronic ballast, but the equipment available has 20

limited accuracy once you get to the frequ encies of 21

125 kilohertz or so, and to try to differentiate a 22

matter of half a percent or a percent, when your 23

measurement accuracy may be in the order of two to 24

five percent is maybe just not possible. 25Executive Court Reporters (301) 565

- 0064 131 MR. COOK: Thank you very much. 1

MR. HARDEN: I cou ld just add, Tom Harden, 2

not only

-- the reason there is no test standard is 3

there’s no lamp or ballast standards either for high 4

frequency. So you can’t have a test standard without 5

a standard to test it to, so you’re missing both the 6

lamp and the ballast high frequency standards as 7

well. 8

MR. BROOKMAN: So I thought that Hayden 9

did a good job of laying out these issues that are 10

on Page 70, so additional amplification on 70 and 11

also again on

-- we’ve begun to hear already today 12

some of the cumulative regu latory burdens that might 13

be on the industry, additional comments on that as 14

well. Yes, please, Rebecca. 15

MS. RAINER: Again, Rebecca Rainer. Just 16

a general comment. We have discussed I think 17

extensively, the burden that this puts on 18

manufacturers. Th ere is also a burden on the 19

consumers. It’s not a simple task to rewrite 20

standards, to develop new product plans , maybe even 21

new reg cases. So it’s not just the manufacturers. 22

It also is the consumer too that does enter into the 23

equation. 24

MR. BROOKMAN : Okay. Yes, Bob. 25Executive Court Reporters (301) 565

- 0064 132 MR. ERHARDT : I don’t know if this is 1

exactly the right place to bring it up, but 2

something that’s just occurred to me is that

-- and 3

we talked a couple times about having parallel 4

regulatory paths. The impact of this regulatory 5

acti on will have significant impact on your metal 6

halide lamp regulatory process. If you start 7

eliminating categories of ballasts, it is quite 8

likely that they will disappear from the market and 9

not be replaced, and will be taken over by 10

fluorescent and solid state lighting. So you should 11

take this into account. You are looking at tens of 12

percent improvements in efficacy when you’re looking 13

at your lamp regulatory actions, and you may kill 14

all of that by your one and two percent action here. 15

MR. BROOKMAN: Okay. Thank you. Yes, 16

Keith. 17

MR. COOK: Keith Cook. Just one comment I 18

want to reiterate the fact that it’s not just 19

multiple regulations within DOE, it’s also across 20

agencies, such as EPA and the ENERGY STAR 21

implication. And there’s nothing worse t han having 22

multiple metrics for the exact same fixture that 23

leads to confusion in the marketplace and a 24

significant burden on manufacturers to do all this 25Executive Court Reporters (301) 565

- 0064 133 testing. 1

MR. COOK: The cumulative regulatory 2

burden does take into account other state and local 3

regulations, as well as DOE and looks at all 4

regulations that contribute to that. 5

MR. BROOKMAN: Yes, Cheryl. 6

MS. ENGLISH: Hayden, I think this has 7

done a really good job at least at characterizing 8

the manufacturer impact interview that I had. One 9

t hing that I think has changed in the marketplace 10

since we originally did our interview is the 11

volatility of materials in terms of availability and 12

pricing, so I just made a note so that as NEMA looks 13

at our responses on this, we need to look at that 14

and tr y to get some data back to you, because when 15

we start talking about additional use of steel and 16

copper, the markets on those are really volatile 17

right now. 18

MR. COOK: Thank you. 19

MR. BROOKMAN: Thank you. You see the 20

comment boxes there. Additional comments before we 21

move on? 22

**NOPR Analysis** 23

MR. MYER: So I’m going to

-- this is 24

Michael Myer. I’m going to return to finish up the 25Executive Court Reporters (301) 565

- 0064 134 last couple of slides of the next phase, which is 1

the NOPR analysis, so this is really high level 2

where we’re going to the next phase. 3

MR. BROOKMAN: Michael, as you’re doing 4

that, I’m going to hand out the

-- the Department 5

makes a Xerox copy of the business cards of all that 6

have attended the meeting today, so I’m going to 7

pass that out now while you’re doing this high 8

le vel. 9

MR. MYER: So this graphic shows where 10

we’ve been, where we’re going. So we’re starting 11

the NOPR phase next. In the NOPR phase we’ll revise 12

the preliminary analysis, but additional analyses 13

will be done as well, those are the life cycle 14

subgroup, manufacturer impact, utility impact, the 15

employment impact and environmental assessment and 16

the regulatory impact. 17

In previous years there’s another break 18

down of them with a little more definition. The LCC 19

subgroup analysis is exactly as it sounds. It’s an 20

analysis looking at what groups might be 21

significantly affected by amended or new standards, 22

whether it be a grocery store or a big box retailer, 23

or stadium lighting. As Hayden just finished, we’ll 24

-- the Department of Energy will continue the 25Executive Court Reporters (301) 565

- 0064 135

man ufacturer impact analyses. The Department of 1

Energy will also do a utility impact analysis, 2

looking at the effects of amended or new standards 3

on the generation [and cost] of electricity. 4

Employment impact analysis, this is 5

slightly different than what it sounds. The 6

manufacturer impact analysis looks at the direct 7

effect of employment on the manufacturers of the 8

equipment. This phase looks to the indirect effect 9

on the other people in the process. 10

The environmental assessment, the 11

Department of Ener gy is considering monetizing 12

[emissions of ] certain airborne particulates and 13

pollutants. The TSD does a great review of the most 14

current situation there on all the values and the 15

wide range of issues involved, with monetization of 16

these fine particulates and pollutants and what the 17

effects could also be, roughly. In the NOPR phase, 18

the Department will look at what happens to the 19

effects of the amended standards, if they are 20

monetized. 21

Finally, the regulatory impact analysis, 22

this is the only one that h as a slightly different 23

title than what it is. This looks at what would be 24

the effects of not doing the standards and looking 25Executive Court Reporters (301) 565

- 0064 136 at other means, through non

- regulatory actions, such 1

as voluntary programs, such as ENERGY STAR , tax 2

[credits for] manufacturers or other type of 3

incentives. 4

Issue 33, this is specifically going back 5

to the LCC subgroup analysis. As I said, DOE will 6

do this in the NOPR phase, but we’re looking for any 7

groups that might be affected, such as stadiums, 8

sports clubs, high

- end retail, grocery, big box 9

retail. So DOE welcomes additional suggestions for 10

its LCC subgroups analysis. 11

MR. BROOKMAN: You see the ones that DOE 12

has called out there, so if there are others that 13

they are missing, now would be a good time to 14

identify them. Joe Howley. 15

MR. HOWLEY: I’d just like to make one 16

comment on your environmental impact analysis and 17

maybe your utility analysis. 18

Almost all of the outdoor lighting 19

fixtures that we’re discussing here are operated 20

during the off peak load. Generally wi th these 21

analysis I see that you typically use average 22

impacts from the utility power generation, as 23

opposed to off peak impact. This could produce a 24

different analysis if you’re looking primarily at 25Executive Court Reporters (301) 565

- 0064 137 off peak impacts for the outdoor lighting fixtures. 1

An d then a portion of indoor lighting fixtures would 2

be used off peak as well, such as parking garages or 3

warehouses. 4

So I think in this particular case it’s a 5

little different than a lot of the rulemakings where 6

we assume a national average. This probably would 7

have less impact, given the off peak loading use 8

application of these particular products. 9

MR. BROOKMAN: Thank you. Rebecca. 10

MS. RAINER: Just a comment on the 11

subgroups. I see several that you have listed here, 12

but as manufacturers, we reall y sell most of our 13

products, or a lot of our products, through 14

distribution. We do not know where these products 15

are going. We do not know if they’re going to big 16

box retail, or if they’re going to grocery or 17

governmental properties or any of the subgrou ps most 18

of the time. So it would be very difficult, if not 19

impossible, for us to control what product would be 20

going to what end user. 21

MR. MYER: Gentleman from Georgia Power. 22

MR. BROOKMAN: Yes, please. 23

MR. STEVENS: Yes, in reference to the 24

utilit y impacts, I was wondering how did you choose 25Executive Court Reporters (301) 565

- 0064 138 the utilities? 1

MR. MYER: We actually haven’t done

-- I’m 2

just presenting the next step

-- 3

MR. STEVENS: Could we volunteer to be 4

part of the interview s ? 5

MR. MYER: I don’t think the Department 6

ever turns down data or help. We’re not saying no, 7

no, please we’ve got too much help, that’s not our 8

position, so I think it’s noted, and when we move 9

into that phase, we’ll follow correct procedures. 10

MR. BROOKMAN: So that was Mike. Thank 11

you, Mike. Additiona l comments on this? Did you 12

say

-- would you restate what the purpose of this 13

subgroup analysis is? 14

MR. MYER: To see what type of groups or 15

subportion of the population might be significantly 16

affected by a new or amended standard. 17

MR. BROOKMAN: Yes, particularly address 18

adverse impact. 19

MR. MYER: Yes. 20

MR. BROOKMAN: So additional comments, 21

questions on this last comment box? 22

MR. MYER: At this point

-- oh, forgot 23

this slide. So as the Department of Energy moves 24

from the preliminary analysis phase into the NOPR 25Executive Court Reporters (301) 565

- 0064 139 phase, they go from candidate standard levels to 1

trial standard levels. DOE is considering 2

developing trial standard levels [using] a number of 3

factors. Here are a couple that are mentioned: 4

combinations of efficiency levels, minimum life 5

cycle cost, maximum net present value, maximum 6

technological efficiency

-- so those are some of the 7

things that the Department of Energy will look at 8

when they develop TSLs. Once then, DOE will select 9

one and propose it for the NOPR. 10

MR. BROOKMAN: Yes, Joanna. 11

MS. MAUER: Joanna Mauer. We would just 12

encourage DOE to consider or to develop a TSL that 13

represents the maximum levels that are still cost 14

effective, and those levels may or may not be the 15

same as the minimum LCC levels. 16

MR. MYER: Tha nk you. 17

MR. BROOKMAN: Okay. Thank you. 18

Additional comments on this last slide? We’re 19

moving towards closure here. Let’s push up the 20

final comment box. 21

MR. MYER: And I’ll turn it back to Dr. 22

Kaarsberg. 23

MR. BROOKMAN: Yes, and before you do, 24

thou gh, before we do this, we ought to offer, as we 25Executive Court Reporters (301) 565

- 0064 140 promised, another opportunity

-- another opportunity 1

for anybody that wishes to make final remarks to 2

cover any issues that are relevant that have not yet 3

been fully covered, now would be the time to do 4

that. 5

DR. KAARSBERG: Okay. I’m not a medical 6

doctor, merely a PhD. I just want to remind you 7

again, and I probably don’t need to tell you that 8

we’re taking all your written comments and again I 9

apologize for the short interval between posting 10

this and the meeting. I want you to note that the 11

comment period closes on May 16, Monday, May 16 th

, 12

that is 45 days after the April 1 st posting

-- or 13

Federal Register

And is Brenda here? Brenda’s not here, 16

but Brenda Edwards is the person to whom all of 17

these comments get sent. You can send by e

- mail. 18

You can send by snail mail or courier. Just make 19

sure you put the energy conservation standards for 20

metal halide lam p fixtures, or ECS for MHLF. And 21

the docket number, and the regulatory identification 22

or RIN number. 23 notice. So that’s not that long 14

from now. 15

And finally, I want to encourage everyone 24

to also provide comments on our process. We are 25Executive Court Reporters (301) 565

- 0064 141 trying to be more streamlined, but we don’t want to 1

miss an y important interactions or input by doing 2

so, so your comments on that. 3

You all have given us a number of complete 4

comments already on the process, and I want to also 5

encourage the W ebinar folks to provide us some 6

feedback. 7

And with that, thank you ve ry much and 8

have a great lunch. 9

(Whereupon, at 12:03 p.m., the meet ing in 10

the above captioned matter was adjourned .) 11

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25Executive Court Reporters (301) 565

- 0064 142 **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