**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 1 UNITED STATES DEPARTMENT OF ENERGY **PUBLIC MEETING ON ENERGY CONSERVATION PROGRAM FOR CERTAIN COMMERCIAL AND INDUSTRIAL EQUIPMENT: TEST**  **PROCEDURES FOR METAL HALIDE BALLASTS** U.S. Department of Energy Room 1E-245 1000 Independence Avenue, Southwest Washington, D.C. Friday, December 19, 2008 9:00 a.m. Participants DOUG BROOKMAN, Facilitator LINDA GRAVES U.S. Department of Energy GARY FERNSTROM Pacific Gas and Electric Company CONAN O'ROURKE Lighting Research Center ROBERT LINGARD Pacific Northwest National Laboratory GRAHAM PARKER Pacific Northwest National Laboratory MICHAEL MYER Pacific Northwest National Laboratory KEITH COOK Philips Lighting National Electrical Manufacturers Association MARILYN PLACET Pacific Northwest National Laboratory DAIN HANSEN National Electrical Manufacturers Association**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 2 A G E N D A AGENDA ITEM : PAGE : Welcome 3 Linda Graves Opening Remarks, Introductions and Agenda Review 3 Doug Brookman Stakeholder Opening Statements 5 (None) Statute and Context Linda Graves 6 Michael Myer 7 Proposed Ballast Efficiency Test Method: Test 9 Setup and Conditions, Test Measurement, and Ballast Efficiency Calculation Michael Myer Proposed Standby and Off Mode Test Method 24 Michael Myer Conclusions and Closing Remarks 59 Linda Graves Adjourn**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 3 P R O C E E D I N G S 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 9:00 a.m. Welcome Linda Graves MS. GRAVES: Good morning. It's my pleasure to welcome you to this public meeting on test procedures for metal halide ballasts. I am Linda Graves. I am the project leader for Lighting Standards at the U.S. Department of Energy. I am here with representatives of our lighting teams from Pacific Northwest National Laboratory and the Lighting Research Center. I'm going to turn the meeting over to Doug Brookman, who is our meeting facilitator, and Doug will keep us on track and ensure that everyone has the opportunity to fully contribute to the meeting. Thank you. Opening Remarks, Introductions, and Agenda Review Doug Brookman MR. BROOKMAN: Thank you. Good morning, everybody. I'm going to do a quick agenda review, and we're going to do introductions as well. In fact, let's start with introductions. Let's do that. Please go around the room. If you'd say your name and organizational affiliation.**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 4 MR. MYER: Michael Myer, Pacific Northwest National Laboratory. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. FERNSTROM: Gary Fernstrom representing the Pacific Gas and Electric Company. MR. LINGARD: Robert Lingard, Pacific Northwest National Laboratory. MS. PLACET: Marilyn Placet, Pacific Northwest National Laboratory. MR. HANSEN: Dain Hansen, the National Electrical Manufacturers Association. MR. COOK: Keith Cook, Philips Lighting and NEMA. MR. O'ROURKE: Conan O'Rourke, Lighting Research Center. MS. GRAVES: Linda Graves. MR. BROOKMAN: And we're missing a person or two, but they'll be joining us shortly. I'm going to do a very brief agenda review and then we're going to launch into it here. Following this agenda review, there's an opportunity for each of you to make a brief opening statement summarizing your issues and concerns for today's meeting. Immediately following that we're going to turn to presentation followed by discussion on the statute and the context. And following that, the**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 5 proposed ballast efficiency test method. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 We'll take a break mid morning, around about 11 o'clock or so, and then following the mid-morning break we'll have a presentation followed by discussion on proposed standby and off mode test method. And immediately following that we'll have conclusions and closing remarks and another opportunity for any of you that wish to make concluding remarks to do so. So that's the plan for today. We plan to adjourn around about noon or 12:30 today. We'll see how that goes. That's the agenda for today's meeting. Questions or comments here at the outset? Particularly, is there anything else that any of you think you want to raise that wouldn't be covered in this agenda as written? (No response.) Stakeholder Opening Statements MR. BROOKMAN: Okay. So then, now is an opportunity for any of you to make brief opening remarks, summary statements about issues that you would like to raise, or issues of concern. Keith Cook: I think we'll get into them, so I'm -- MR. BROOKMAN: Okay. Not at this point.**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 6 Okay. Gary, anything from you? No? Okay. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 So then, let's proceed with the presentation part. All of you have received this packet, and this will describe -- will be the basis for the presentation. I'd ask for your consideration as we're going along today. There aren't so many of us, so it won't be too complicated. Please speak one at a time. Please say your name for the record. If you could turn your cell phones on "silent" and limit the sidebar conversations. I'm going to ask you to please be as concise as possible. I'll be queuing people to speak as best I can, also wanting to encourage follow-on comments. So then, are you ready to go? Or do you want to do the next segment? Statute and Context Linda Graves (PowerPoint presentation) MS. GRAVES: So the purpose of today's public meeting is to review the statute and the DOE actions for metal halide ballasts. This will include a test procedure which is based on ANSI Standard C82.6-2005, and we are including within the scope of this rulemaking consideration about the standby and off**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 7 mode. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 So we will present our proposed test procedure and the reporting requirements. We are here to clarify any questions you might have about the proposal, and we seek your comment on the test procedure. And at the end we'll discuss the next steps for this rulemaking. Presentation by Michael Myer (PowerPoint presentation) MR. MYER: From time to time during the presentation you will see a slide that looks like this, which is where it's titled "Issues for Comment." You'll see a box that will say "Issue Box" and it will have a number related to it in the NOPR. This is a specific item where DOE welcomes comments about data, information, or other concerns. MR. BROOKMAN: Michael, introduce yourself. MR. MYER: Thank you, Doug. Michael Myer. MR. BROOKMAN: Thank you. MR. MYER: So, moving forward with the agenda for the presentation, we will first discuss the statute and context, then move on to the proposed ballast efficiency test method, standby and off mode test method, reporting requirements, and finally a closing. This is just a general overview of the**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 8 statute and context. Section 324(c) of the Energy Independence and Security Act, which will from this point on be referred to as EISA, 2007, amended EPCA to require DOE to establish procedures for metal halide lamp ballasts. So this is the background on that. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 The EISA prescribed certain ballast efficiencies for different types of ballasts, from an inclusive wattage range of 150 watts to 500 watts. The range of efficiencies is listed in this table by ballast type and wattage range, where applicable. This is just a general review of what EISA requires for the test -- what the results for the test procedure will reflect. MR. BROOKMAN: Keith. MR. COOK: You wanted questions as we go or hold them until the end? MR. BROOKMAN: Let's do it that way. MR. COOK: One question I've got is, right now C82.6 is being revised by ANSI. Has DOE or PNNL considered actually participating in those meetings? They've done that before in some of the solid-state lighting standards. MR. BROOKMAN: Keith, can you say where they are in that review? MR. COOK: They expect to actually have them**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 9 completed by the middle of this year. They expect to have everything finished by mid 2009. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. BROOKMAN: Okay. MR. MYER: Were you looking for a response? MR. BROOKMAN: If you please. MR. MYER: I was actually slightly aware that they were revising that. I believe at first that the test procedures -- C82.6-2005 is defined by EISA, so we're still bound by what the EISA requires. So while it is -- I appreciate that you informed us that they're working on it and I might participate, but at this point we're required to just follow what EISA states. MR. COOK: Okay. MR. BROOKMAN: DOE would be welcome to participate? MR. COOK: Absolutely. MR. MYER: Okay. Thank you. Proposed Ballast Efficiency Test Method: Test Setup and Conditions, Test Measurement, and Ballast Efficiency Calculation Michael Myer (PowerPoint presentation) MR. MYER: Following along on the ballast efficiency, certain lamp fixtures are exempted from the efficiency standards. So you'll see that these**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 1 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 exempted fixtures include fixtures with a regulated ballast or a fixture that uses an electronic ballast that operates at greater than 480 volts or a very specific fixture that's rated only for 150-watt lamps, is wet location-rated, and has a very specific ballast that is rated to operate at an ambient air temperature above 50 degrees centigrade. So, moving forward to the metal halide lamp test procedure schedule, on December 5th, two weeks ago, the test procedure NOPR was issued. We are now in the public meeting and will soon start the 75-day comment period, with a target publication of the metal halide test procedure final rule June 30th of 2009. Moving forward to the proposed ballast efficiency test method, test setup and conditions, lamp orientation. DOE proposes lamp orientation for testing as specified in Section 4.3 of ANSI Standard C82.6- 2005. This essentially requires a vertical, base-up orientation. This is the most stable. It gives the most repeatable and accurate results when doing that. And DOE is proposing a vertical, base-up orientation. Continuing on, this is our first request for comment. This is Item 4 in the NOPR. The Department invites comment on the appropriateness of the lamp orientation requirements as specified in Section 4.3 of**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 1 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ANSI Standard C82.6-2005 that require vertical, baseup, unless the manufacturer specifies another orientation for the ballast and associated lamp combination. We're also seeking comment on whether a preferred lamp orientation approach exists within the industry for lamp ballast testing. MR. BROOKMAN: So it's also helpful for the Department if you can respond in the affirmative. MR. COOK: We have no comment on this. We agree with it. MR. BROOKMAN: Okay. MR. MYER: Okay. MR. BROOKMAN: Thanks, Keith. MR. MYER: Thank you. MR. BROOKMAN: Yes, Gary. Please. MR. FERNSTROM: I guess I have a comment and a question for industry. In our efforts in Californiato advocate for improved efficiency for horizontalburned lamps we've heard from industry that that's a significantly different product and needs to be treated in different ways because of the burning position. Yet here I'm seeing that the horizontal-burned products would be used in conjunction with ballasts except in the vertical position? Or am I misunderstanding that?**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 1 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. BROOKMAN: Keith. MR. COOK: The purpose is to end up with a standard for testing ballasts, not lamps. And so the result, we just want to make sure we have a uniform way of setting the test up. But lamp orientation is not the key, it's the ballast. MR. FERNSTROM: I understand. Thank you very much. MR. BROOKMAN: Thank you. That's helpful. Okay. MR. MYER: Continuing on to power supply, ambient test temperatures, and instrumentation for the test procedure, DOE proposes power supply characteristics as specified in Section 4.1 of ANSI Standard C82.6-2005. We've outlined in greater detail what Section 4.1 requires: three percent of fundamental voltage and frequency components, limits on the impedance power, and recommendations on power supply devices. MR. BROOKMAN: Keith. MR. COOK: Yeah. One comment we have on that is, you do specify an impedance to the power source to be no more than three percent. We do feel that is too high, but we will come back with written comments. MR. MYER: Thank you.**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 1 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. O'ROURKE: This is Conan from the Lighting Research Center. This is the ANSI standard. MR. COOK: It is being revised. That is one that they're already working on. MR. BROOKMAN: Okay. MR. MYER: And when you say too high at three percent, you expect it to be a revised lower number? MR. COOK: Correct. MR. MYER: Okay. Thank you. MR. BROOKMAN: Gary. MR. FERNSTROM: The reality being that the source that drives these ballasts is typically of lower impedance in the field; is that correct? MR. COOK: Uh-huh. MR. FERNSTROM: Thanks. MR. MYER: Okay. Continuing on, ambient test temperature. DOE proposes ambient test temperature as specified in Section 4.2 of ANSI Standard C82.6-2005. This just requires a maintained temperature of 25 plus or minus 5 degrees centigrade to reduce any potential variances. Also, DOE proposes a draft-free environment. MR. BROOKMAN: Keith. MR. COOK: Basically, we agree with the temperatures, but we need definition on what is meant**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 1 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 by "draft-free." MR. BROOKMAN: Can you elaborate a little more on that? MR. MYER: I can elaborate. We'll come up -- in the revised and final NOPR we'll come up with some technical definition for "draft-free." Standing air. I mean, you don't -- it's -- MR. COOK: You have to be careful with that. You do actually want some movement of air. Otherwise you end up with stratification of the air in the test setup. And so -- but you want to minimize the amount of air flow. That's the reason it gets very difficult on how to define that.MR. MYER: Would you do it a cubic-feet-perminute or some type of HVAC typical definition? MR. COOK: Yeah. MR. BROOKMAN: Is there a typical configuration for this kind of testing? MR. COOK: ANSI is working on that, also, right now. MR. BROOKMAN: Oh, they are. So there's no kind of a standard box for this or anything? No? Okay. MR. O'ROURKE: This is Conan from the Lighting Research Center. Unfortunately, those air**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 1 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 flows are so low, most equipment that's available today doesn't measure it easily. It used to be a tissue test. MR. COOK: Exactly. (Laughter.) MR. MYER: You hang a tissue and if it moves, you've met your -- MR. COOK: Too much air flow. MR. BROOKMAN: So, Michael, you think it's going to be fairly easy for you to do some more complete, as you say, technical definition? MR. MYER: I don't know if it would be fairly easy, but we will try to come up with -- (Laughter.) MR. MYER: I would enjoy writing a specification about tissue tests. (Laughter.) MR. MYER: I can only imagine what the diameter and the dimensions of said tissue would be and how much movement qualifies. MR. COOK: The accepted language. MR. MYER: Exactly. (Laughter.) MR. MYER: But yes, I think we will come up with a better definition. It is a little ambiguous of**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 1 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 what "draft-free" is. MR. BROOKMAN: Anything else you want to say about this, Keith? MR. COOK: No. MR. BROOKMAN: Okay. Gary, please. MR. FERNSTROM: Or more significantly, what type of tissue. (Laughter.) MR. BROOKMAN: Double-ply or single-ply? MS. PLACET: We cannot name a brand. (Laughter.) MR. MYER: Thank you for the levity. Moving forward. And this actually brings us to a request for comment. Item 1, the Department invites comment and data on the applicability of the proposed ambient test temperature requirements based on Section 4.2 in ANSI Standard C82.6-2005. In particular, DOE is interested in comment on whether a different set of ambient test temperature -- test conditions might be more appropriate for the metal halide ballast testing. MR. BROOKMAN: Gary, no? MR. FERNSTROM: No. MR. BROOKMAN: Keith, you already said that this is okay.**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 1 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. COOK: Uh-huh. MR. BROOKMAN: Yeah. Okay. MR. MYER: Great. Continuing on into instrumentation, DOE proposes using the instrumentation prescribed in Sections 4.5.1 and 4.5.3 of ANSI Standard C82.6-2005. This slide just outlines what the digital requirements are for digital instrumentation so that it has a resolution of three and one-half digits and a minimum accuracy of 0.5 percent of the reading of the RMS capability. And then the next slide follows along on the requirements, only this time it's on the analog instrumentation. Analog ammeters and voltmeters: 0.5 percent up to 800 hertz. Analog wattmeters, 0.75 percent up to 1,000 hertz. For ballasts with power factors of 50 to 100 percent and plus or minus 0.5 percent up to 125 hertz for ballasts with power factors zero to 20 percent. DOE proposes to require all analog wattmeters used on ballasts with power factors less than 50 percent to have the same accuracy as those for ballasts with power factors less than 20 percent. For example, 0.5 percent for ballasts up to 125 hertz. There is just a disconnect in the ANSI standard of the power factors between 20 and 50 percent.**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 1 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Moving on for a request for comment, the Department invites comment and data on the applicability of the proposed instrumentation requirements for supplies, wattmeters, voltmeters, and ammeters required for testing based on the requirements in Section 4.0 of ANSI Standard C82.6-2005. DOE especially invites comment on the issue of the applicability of the proposed measurement accuracy of plus or minus 0.5 percent up to 125 hertz for ballasts with power factors between 20 and 50 percent because ANSI Standard C82.6-2005 does not provide an accuracy value for the proposed instrumentation for these power factors. MR. BROOKMAN: I have to say, I seldom wanted to have a degree in electrical engineering. (Laughter.) MR. BROOKMAN: However. Keith, can you comment on this for us? MR. COOK: No, not at this time. I'm trying to find the comments, in fact. MR. BROOKMAN: Okay. If you'd like then, we can either double back to this or you can just submit them in your written comments. Is this within the reasonable range, do you think, or has the Department got to reconsider what they're talking about here?**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 1 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. COOK: Well, there are some comments -- I'm trying to find them right now -- having to do with the analog versus the digital type wattmeters and the applicability to some of that stuff. So we'll include that in our written comments. MR. BROOKMAN: Okay. MR. MYER: Do you know if the ANSI revision is going to address the difference in the power factors? MR. COOK: Yeah, it is. MR. MYER: Okay. Thank you. Continuing on, continuing with the test procedure, DOE proposes that only one analog instrument may be connected to the test circuit at one time to reduce impedance effects on the testing. DOE believes that these instrument requirements set forth in ANSI would facilitate repeatable and consistent testing measurement. Another request for comment, Item 3, the Department invites comment on the applicability of the proposed test circuit connection requirements based on Sections 4.5 and 6.10 of ANSI Standard C82.6-2005. MR. BROOKMAN: Gary. MR. FERNSTROM: My observation is that these days it's much more likely we're going to find digital**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 2 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 instruments being used. It would be hard to find an old analog instrument of relatively low impedance with that kind of accuracy. However, this is all an ANSI test standard, and we're fine with it however you write it. MR. BROOKMAN: Okay. MR. MYER: Continuing? MR. BROOKMAN: Michael, you're being very efficient and clipping right along. I want to make sure we provide an opportunity if Keith, if you want to

-- MR. COOK: No, I'm fine right now. MR. BROOKMAN: Okay, okay. Thank you. MR. MYER: Finally, on to lamp stabilization. DOE proposes the process for lamp stabilization that would follow Section 4.4 of ANSI Standard C82.6-2005. There are three sections in 4.4, and the next three slides will outline the actual requirements for them. Section 4.4.1 just requires that the lamp be seasoned or burned in, essentially operated, for a minimum of 100 hours prior to the use with a ballast test. Section 4.4.2 is the basic stabilization method. This just requires the lamps operated at plus or minus 3 percent of the rated wattage and, again,**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 2 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 this ambient temperature of 25 degrees plus or minus five. Lamp burning could be anywhere from 30 minutes to six hours before the lamp is finally stabilized. A standby ballast is recommended. And then once the lamp has been transferred to the ballast test circuit, restabilization time is important. So you should take the measurement within five minutes after restabilization. Okay. Continuing, and Section 4.4.3, the alternative stabilization method in ANSI Standard C82.6, recognizes that some low-frequency ballasts that transfer from the reference ballast to the test ballast is undefined. So the following method should be used to ensure reproducible results. Lamp characteristics should be determined with a reference ballast. The same lamp will be driven by the ballast under test for 15 minutes, and the electrical measurement should be taken within two minutes after the 15-minute stabilization period. MR. BROOKMAN: This is all a part of the ANSI test procedures, so it should be relatively uncontroversial. MR. COOK: Yeah. We just want to make sure that it does remain consistent with the ANSI standard. Any changes would have significant effect on outcomes**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 2 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in comparison to historical values. MR. BROOKMAN: Right. Okay. Thank you, Keith. Thank you. MR. MYER: The Department invites comment and data on the applicability of the proposed lamp seasoning and system stabilization requirements that follow the ANSI Standard C82.6-2005 requirement for a 100-hour seasoning period and the stabilization method in either 4.4.2 or 4.4.3 of ANSI Standard C82.6-2005, with additional methods from ANSI Standard C78.389- 2004. DOE is particularly interested in whether a preferred lamp seasoning or lamp stabilization approach exists within the industry. MR. BROOKMAN: Keith. MR. COOK: Typically, we go with the first one, not the alternative. MR. BROOKMAN: The lamp seasoning? MR. MYER: No, the lamp seasoning standard, but the basic is what you're saying, correct? MR. COOK: Right. MR. MYER: 4.4.2. MR. COOK: Either way is acceptable. We don't have a problem with the current approach. MR. BROOKMAN: Okay.**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 2 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. MYER: Thank you. MR. BROOKMAN: Thank you. MR. MYER: Finally, on to test measurement and calculations for ballast efficiency. EISA defines ballast efficiency. DOE proposes that ballast efficiency be calculated as the measured output power to the lamp divided by the measured input power to the ballast, or P-out over P-in. The test measurement for metal halide ballasts would require that ballast operating tests be conducted according to the same requirements as set forth in Section 6.10, Ballast Power Loss, of ANSI Standard C82.6-2005. Okay. Continuing on, another request for comment, Item 6. The Department invites comment and data on the applicability of the proposed measurement of ballast power losses in accordance with Section 6.l0 of ANSI Standard C82.6-2005, which requires the use of a true RMS wattmeter with basic accuracy of 0.5 percent. DOE is particularly interested in whether a preferred ballast power loss measurement approach exists within the industry for metal halide lamps. MR. COOK: We really don't have any comment on that one. MR. BROOKMAN: Okay. MR. COOK: We'll have to dig into that one**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 2 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 and include it in the written comments. MR. BROOKMAN: Okay. Thank you, Keith. MR. MYER: Thank you. MR. BROOKMAN: Any other comments on this subject? (No response.) MR. MYER: Okay. That brings us to the standby and off mode test method. Per the agenda, though, Doug, technically we have a break in here. MR. BROOKMAN: I don't think we're ready for a break yet. (Laughter.) MR. MYER: Just keeping with the agenda. MR. BROOKMAN: Thank you. I appreciate that. MR. MYER: I appreciate your guidance on that. (Laughter.) MR. MYER: You all seem rested, so we'll continue moving forward. Proposed Standby and Off Mode Test Method Michael Myer (PowerPoint presentation) MR. MYER: This is the overview on standby and off mode. EPCA in relevant part directs DOE to establish test procedures to include standby mode,**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 2 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 taking into consideration the most current versions of Standards 62301 and 62087 of the International Electrotechnical Commission. 62087 doesn't apply to lighting equipment, so 62301 would be the appropriate IEC portion, and DOE developed a proposed rule consistent with procedures outlined in 62301 and referenced language from ANSI Standard C82.6-2005. EPCA defines three types of modes covering the various operating conditions: active mode, standby mode, and off mode. EPCA defines active mode as the condition in which an energy-using product is connected to a main power source, has been activated, and provides one or more main functions. Basically, if the lamp is operating, the ballast is in active mode. Gary? MR. FERNSTROM: So, in the context of this, a main function is considered powering the lamp and providing light; is that correct? MR. MYER: My interpretation of "main function" is its intended use, so yes. Operating the lamp -- if it had a clock or some other function, I believe that's considered a secondary function. Actually, the standby definition includes some wording about that.**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 2 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. FERNSTROM: Okay. So modes of operation where power may be being demanded yet the lamp is not powered would not be considered active. The reason I'm asking these questions is because this terminology is pretty complicated and confusing, and I'd just like to try and be really clear about it. MR. BROOKMAN: Right. MR. FERNSTROM: It's not just these products but across the whole range of products where we have active, standby, off, and so on modes. MR. COOK: The active mode I'm not as worried about as when we get into the standby mode. That's the one that we've got a lot of concern with. MR. MYER: Okay. MR. COOK: So I'll let you go on and then I'll address my question. MR. MYER: I just want to clarify, actually. So, to reclarify your question so I understand it, you're saying if the lamp is not operating but the ballast is drawing power your interpretation is that is not active mode, correct? MR. FERNSTROM: That's my question. That's not my interpretation. MR. BROOKMAN: Do you have an interpretation?**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 2 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. FERNSTROM: It says one or more main functions. So I just want to be clear that the main function is powering the lamp and there isn't any active mode state that could exist where the lamp is not being powered. MR. BROOKMAN: Keith, go ahead. MR. COOK: This gets very difficult. The reason is, we do produce ballasts today that actually have two lamps attached. And what happens is you have the main metal halide lamp and, if for some reason you have a power outage, then you have a quartz lamp secondary that automatically will come on for emergencies so people can still see to get around in these buildings until the metal halide restrikes. Well, depending upon how you read this definition, it says that it's not in active mode now because you're not driving metal halide lamp any longer. But hold it, I'm providing a safety function here that needs to still be comprehended in these rules and definitions. This is one we've got to work on, I think. MR. BROOKMAN: So, do you -- does that influence the active mode definition or does it influence the others, or all? MR. COOK: Both active and standby, I think.**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 2 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 We have to sort these kind of situations out, I think. MR. BROOKMAN: I see. Can you provide more details now or do you need to do that in your written remarks? MR. COOK: We'll do it in written remarks because they're working on that one. That's a tough

one. MR. BROOKMAN: ANSI is working on that, huh? MR. COOK: That one they were not looking at, in all honesty. MR. BROOKMAN: Oh, okay. So that is NEMA is working on it? MR. COOK: Yeah. We'll have to include this in our written comments. MR. MYER: Would a ballast that's being advertised with a quartz backup, would that main function -- could a main function also be the quartz backup because it's being differentiated from a standard ballast that only -- I'm just asking for more NEMA's thought on that. MR. COOK: Could be, could be. MR. MYER: Okay. MR. COOK: That might be an easy way to define it. MR. BROOKMAN: Conan.**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 2 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. O'ROURKE: Yeah. I just want to follow up on that. But with whatever part functions you have, there will be efficiencies associated with them. So that will be a hard part. MR. BROOKMAN: Conan, speak into the mic. MR. O'ROURKE: Sorry. There will be efficiencies associated with those primary functions. So if it is on a quartz, what will that efficiency be and will it meet the requirement. Those will be some of the challenges. MR. COOK: Well, the question is, is that really critical. I mean, how often do they actually operate in that mode? It's such a minute period of time typically for most applications, you'll never see it. MR. BROOKMAN: Michael, you said intended use is the -- what causes it in your mind to be defined as a main function. So, going back to Gary's question, you referenced a clock or some ancillary function that would not be included in active? MR. MYER: Actually, I used the clock analogy because it's actually in the standby definition. It says if -- well, we're talking about standby. Let's move into standby. EPCA defines standby as the condition in**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 3 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 which an energy-using product is 1) connected to the main power source, and 2) offers one or more of the following user-oriented or protective functions. aa) is to facilitate the activation or deactivation of other functions by remote switch, internal sensor, or timer, and bb) is continuous functions, including information or status displays, including clocks or sensor-based functions. Keith. MR. COOK: The question is, what if you've got a ballast on controls that -- like a DALI-type control that has to be in a standby mode in order to read any incoming signals. How do you pick up those signals and how do you account for that in the standby mode? MR. MYER: That brings me to my next slide, standby mode. The definition requires a ballast be connected to the power circuits. And so that first part of the definition, the standby wouldn't apply because almost all ballasts are connected to a primary. But if you read the bottom line, DOE interprets this condition as applying to ballasts that are designed to operate in and/or function as a lighting control system where auxiliary control devices send signals. So that would be DALI or -- at this time the**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 3 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Department -- we weren't aware of any DALI ballasts, though we do anticipate at some point there will probably be something like that or an intelligent -- we use "DALI" as some type of a slang for intelligent lighting. It could be other things that are not DALI protocol. MR. COOK: Philips does have one electronic HID ballast that does provide DALI function. MR. MYER: Okay. Thank you for pointing that out. MR. BROOKMAN: So, Keith, the way this is described here, what's your general assessment? MR. COOK: This needs work. (Laughter.) MR. BROOKMAN: Okay. MR. COOK: It's not going to be easy. This is a very difficult area because there are so many different varieties of ballasts and how they operate in these different modes. We've got to think this one through. This one just needs clarification. MR. BROOKMAN: Okay. Gary, do you have any comments at this point? MR. FERNSTROM: Well, just briefly going back to active mode, we think that active mode means when the ballast is operating one or more metal halide**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 3 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 lamps, not a quartz lamp. MR. COOK: Okay. I like that approach. MR. BROOKMAN: That's pretty simple. MR. COOK: Yeah, yeah. I like that. MR. O'ROURKE: This is a comment, too. You could also argue that they could be providing a protective feature, which would meet the standby mode definition, too. MR. COOK: Right. MR. BROOKMAN: That helps clarify it. MR. MYER: I also believe the definition in metal halide lamp ballast defines that it has to operate a lamp operating using metal -- it actually defines metal halide in it. So the quartz operation -- actually, that would exclude the definition. It needs work. (Laughter.) MR. BROOKMAN: Okay. MR. COOK: It's not easy. MR. BROOKMAN: Okay, okay. MR. MYER: Finally, EPCA defines off mode. The condition in which an energy-efficient using -- sorry. Not energy-efficient. An energy-using product 1) is connected to a main power source, and 2) is not providing any standby or active mode.**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 3 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 DOE considered this definition in the context of metal halide ballasts and believes that off mode does not apply to any metal halide ballast, dimmable or non-dimmable, because off mode describes a condition that commercially available ballasts do not attain. MR. BROOKMAN: So, comments on this definition. MR. COOK: I agree with that. MR. BROOKMAN: Thank you, Keith. Thank you. Additional comments? (No response.) MR. BROOKMAN: Okay. MR. MYER: Continuing on, request for comment. The Department invites comment on its approach for assessing metal halide ballast operation in active mode, standby mode, and off mode, as those terms are defined in EPCA. In particular, DOE invites comment on its tentative conclusion that off mode does not apply to metal halide lamp ballasts at this time and therefore should not be included as part of the proposed test measure procedure. MR. BROOKMAN: We've been addressing active, standby, and off as we've been going along. Perhaps there are some summary comments or additional comments at this time?**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 3 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. COOK: I think we already covered them. MR. BROOKMAN: Covered them. Yes, Gary? Okay. MR. MYER: Thank you. Moving forward, the test method and measurements. It's somewhat straightforward for measuring standby power. A signal is sent to the ballast instructing it to reduce light output to zero percent. The main input power to the ballast is measured and then the control signal path is measured. MR. COOK: We've got a problem there, and that is, in some ballasts the signal is actually done over the main line. MR. MYER: We will actually -- we have a diagram for a power line carrier. Is it not power line carrier? MR. COOK: It is power line carrier. MR. MYER: Okay. Can we -- MR. COOK: It won't work, though. That's what our concern is. So, anyway, go on. MR. BROOKMAN: You think the way you've got it diagrammed will meet his concern? MR. MYER: Honestly, I jumped the gun. I was just saying we had something. I don't know what his concerns are at the moment.**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 3 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Laughter.) MR. BROOKMAN: That's why I asked. MR. MYER: So I apologize for saying we had something. MR. COOK: The problem is being able to separate the power between the two, between the signal and the main. MR. MYER: When we show the signal for power line carrier -- or, the diagram, I would like to greater discuss this. MR. COOK: Yeah. MR. MYER: Thank you. So the test measurement of input power. The measurement of input power to the ballast for the main electricity supply during standby mode is based on the approach in ANSI Standard C82.6-2005, Section 6. This is very similar to what is being used for the ballast efficiency. It's essentially power in. It's the same one. Thus the test measurements of the ballast input power would be required to be conducted in accordance with the appropriate sections of the current industry test method. MR. BROOKMAN: Let's pause for just a moment here. Keith. MR. COOK: I'm rereading the comments again.**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 3 6 What happens is, a lot of times the power line control signal is a series of very short bursts, of milliseconds. And for us to be able to measure that is going to be nearly impossible just because of the sensitivity of the equipment involved to do this. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. O'ROURKE: Just a quick comment. MR. BROOKMAN: Conan. MR. O'ROURKE: Yeah. We will be able to measure it but it's not going to contribute too much power. MR. COOK: No. MR. O'ROURKE: Very little amount of time. MR. COOK: Yeah, milliseconds. MR. O'ROURKE: So it's probably not going to be much of an issue on it actually using much power. MR. MYER: Would it use more than a watt? MR. COOK: No. Oh no. It would be milliwatts. MR. MYER: Okay. MR. FERNSTROM: So it's -- MR. BROOKMAN: Gary, thank you. MR. FERNSTROM: It's not the signal that we're so much concerned about measuring, it's the standby power of the equipment designed to receive the signal, that's listening.**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 3 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. O'ROURKE: This is Conan again. In response to that, we just wanted to make sure that there wouldn't be an opportunity where a significant amount of power would be supplied by the control signal that wasn't accounted for. That was just mainly what this was an attempt for. MR. BROOKMAN: Okay. MR. MYER: Continuing on, measurement, ballast control signal power. So, as proposed in 10 C.F.R. 431.324(c), the proposed test procedure would direct manufacturers to address measurement of the ballast control signal power. As DOE understands it, there are four possible ways to deliver a control signal. One is a dedicated AC control signal wire. A second is a DC control signal wire. The third is the power line carrier control signal wire over the main supply input wires, and the fourth is a wireless control signal. DOE estimates that the power supply to a ballast using wireless signal would be very small, well below one watt, making it hard to measure and unlikely to appreciably impact the ballast power. MR. BROOKMAN: The consumption. Keith. MR. COOK: We agree with that consumption. MR. BROOKMAN: Okay. Gary.**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 3 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. FERNSTROM: This is Gary. The point of confusion I have here is whether we're talking about the power contained in the signal or the power contained or utilized by the receiver to hear the signal. I don't think a wireless receiver would necessarily have a power demand well below one watt. MR. COOK: Most of them do anymore. They're very low wattage, very low wattage. MR. O'ROURKE: Just a clarifying comment. MR. BROOKMAN: Conan, yes. MR. O'ROURKE: This is Conan. It would still be drawing power, though. The receiver would be drawing power as part of the input to the ballast. So you would see that power, if it was large, being drawn from the input ballast in the input measurement because it can't get the power wirelessly on the receiver side. It would be powered by something in the ballast. So we would be able to capture that on the input power measurement. MR. BROOKMAN: As defined in this test procedure. MR. O'ROURKE: Correct. MR. COOK: It would still show up in your efficiency calculations. MR. FERNSTROM: Would it show up both in the**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 3 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 active and standby mode measurements? MR. COOK: Yes. MR. O'ROURKE: Yes, it would. MR. BROOKMAN: Yes, it would. Okay. MR. FERNSTROM: Thank you very much. MR. BROOKMAN: Okay. MR. MYER: Anyway, we're kind of working our way through this here. Moving on, proposed definitions for control signals. An alternating control signal is supplied to the ballast using additional wiring for the purpose of controlling the ballast and putting the ballast in standby mode. A DC control signal is a direct current signal that is supplied to the ballast using additional wiring for the purpose of controlling the ballast and putting the ballast in standby mode. MR. BROOKMAN: Let's pause here. Keith. MR. COOK: I guess I'm not clear on where power line control comes in, then. MR. MYER: Next slide. Can you come to all my presentations? (Laughter.) MR. MYER: Power line carrier signal is defined as a signal that is supplied to the ballast using the input ballast wiring for the purpose of**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 4 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 controlling the ballast and putting the ballast in standby mode. And a wireless control signal is defined as a wireless signal that is radiated to and received by the ballast for the purpose of controlling the ballast and putting the ballast in standby mode. MR. BROOKMAN: So let's pause here and consider all four of these definitions and see if we have comments on those. MR. COOK: It looks reasonable to me. I'd agree with it. MR. BROOKMAN: Okay. Thanks, Keith. And of course, if NEMA or if Philips wants to elaborate in their comments, that would -- the Department would really appreciate that. MR. COOK: Yeah, no problem. MR. BROOKMAN: Okay. MR. MYER: Continuing on with the diagrams, this is the proposed test setup for measuring the standby power of a metal halide ballast with an AC control signal. So you have the ballast in the center here, and on the right you have your lamp. You have your input power diagrammed here on the left and your control signal alternating current on the bottom. And again, remember the steps. The first**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 4 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 thing the ballast does is tells the lamp to go to zero percent output. Then the input power is measured, and then the control signal power would be measured. MR. BROOKMAN: Gary. MR. FERNSTROM: I have an artistic comment. (Laughter.) MR. BROOKMAN: I've got marking pens if you want to use the flip chart. MR. FERNSTROM: No, I don't think I want to mark on the screen. The lamp is shown base down. MR. MYER: Thank you for -- (Laughter.) MR. MYER: I was trying to come up with some other -- yeah, thank you. I like it. But, yes. MR. BROOKMAN: Thank you very much. Keith. MR. COOK: This chart we did have some problems with. If you're looking at power line control, how that applies to this one and being able to measure the difference between the power line control and your input power. MR. O'ROURKE: This is just the AC one. MR. MYER: There is a power line diagram in a second -- MR. COOK: Okay, okay. MR. BROOKMAN: So, Conan, say it into the**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 4 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 microphone. MR. O'ROURKE: Sorry. This is just the AC power one. We'll show you the power line carrier one in a couple slides. MR. BROOKMAN: Okay. MR. COOK: Okay. MR. BROOKMAN: So then, that's Slide 44. Are we ready to move to the next one, then? MR. COOK: Still the same problem, though. MR. MYER: Moving on to Slide 45, this is the proposed test setup and measurement for DC control signal. It's very similar. You have your ballast, your lamp, which will be next time shown base up, input power, and your DC signal. MR. BROOKMAN: I don't understand the problem you're referencing, Keith. MR. MYER: It has to do with -- MR. COOK: The next one. MR. BROOKMAN: Okay. MR. MYER: Finally, moving on to the diagram for test setup and standby power, you have your ballast and your lamp and your input power, and with power line carrier, the control signal is being sent over the same input wire, though you would actually filter out 60 hertz.**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 4 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. O'ROURKE: The question -- I'll try and clarify it. MR. BROOKMAN: Conan, say your name. MR. O'ROURKE: Conan. I'll try and clarify it for Keith. MR. BROOKMAN: Thank you. MR. O'ROURKE: You would have to high-pass filter this in order to make the measurement properly. So you could get rid of the 60 hertz power and just measure whatever the high frequency signal is. MR. COOK: Whatever is left. MR. O'ROURKE: Right. MR. COOK: And if you have any distortions, you may end up picking up some of that, too. MR. O'ROURKE: Correct. MR. BROOKMAN: Okay. Thank you, Keith. Any additional thoughts or comments on this diagram, Slide 46? MR. MYER: You still expect this to be less than one watt, though. The power line is going to be -- MR. COOK: It's extremely small, yeah. MR. MYER: Thank you. Moving forward, request for comment. The Department invites comment on its approach to apply the standby mode provisions of this test procedure to all**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 4 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 metal halide lamp ballasts and incorporate some form of electronic circuit that enables the ballast to communicate with and be part of a lighting control system. Although all metal halide ballasts would be subject to the test procedure generally, only these types would be subject to the test procedure standby mode power consumption provisions. MR. BROOKMAN: So, additional comments at this time? (No response.) MR. MYER: Moving forward, Item 10, request for comment. The Department invites comments on its proposed test method and measurements for metal halide ballasts which provide the step-by-step procedure and circuit diagrams necessary for measuring the power in watts consumed by the main power input to the ballast and the control signal wire, if any. MR. COOK: We'll include this in our written comments. MR. BROOKMAN: Okay. Thank you, Keith. MR. MYER: Continuing on, combining measurements and burden. DOE proposes that the test measure would direct manufacturers to take two required measurements, again the main input power and the control signal power, in standby mode.**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 4 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 The proposed test measure procedure does not tell manufacturers how to combine these values or to use them in equations pertaining to energy efficiency. DOE intends to study best how to use these measurements of standby mode power consumption in a separate rulemaking to review and possibly amend the energy conservation standards which DOE is required to complete by January 1 of 2012 pursuant to EISA 2007. Okay. Moving forward, DOE notes that the proposed test measure is designed to produce results that measure standby power in an accurate and repeatable manner and should not be unduly burdensome on manufacturers to conduct. DOE believes that these objectives would be met by the proposed test procedure, particularly given that it is based upon IEC Standard 62301 and follows testing approaches used in ANSI Standard C82.6-2005. MR. BROOKMAN: Keith. MR. COOK: Keith Cook, Philips. I guess this does raise the question as to, I assume that you're going to be gathering this information up in order to assess it. Have you thought about what your sampling is and which ballasts it's going to apply to and all that kind of stuff? MR. MYER: We'll address samples, actually,**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 4 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 shortly, but I believe all ballasts -- I mean, the ballasts were addressed earlier on. It applies to all metal halide ballasts 150 watts to 500 watts, inclusive, except for the one exempted ballast that was mentioned there. MR. COOK: There are just so many variations. That's what I'm just concerned about. Looking at high-volume runners -- MR. MYER: I don't believe that EISA requires it. There's nothing, I believe, that is exempted from a volume or the most dominant class. If it's manufactured and meets these parameters, I believe it has to be tested. MR. BROOKMAN: Will you restate that, Michael? EISA requires what? MR. MYER: Again, EISA 2007 requires ballast efficiency standards for 150 watts to 500 watts, inclusive, except for that one that's very specific, 150 watts, 480 volts. There is the 480-volts electronic ballast or the 150-watt wet location ballast that is exempted. That was in the earlier slides. MR. BROOKMAN: All others are expected to be covered. MR. MYER: That is my understanding. MR. COOK: I understand, but see, that's**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 4 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 where it gets to be burdensome. A lot of times you'll end up producing a ballast where the only thing that's different is a bracket or something like that, and you produce just a few a year or something like that. MR. MYER: The definition of basic model and some of the testing requirements might address some of your concerns. MR. COOK: Okay. MR. BROOKMAN: Okay. So, address that in your comments. MR. COOK: Oh yeah. MR. BROOKMAN: Okay. Additional comments, then, on this slide, combining measurements and burden? (No response.) MR. MYER: Moving on to reporting requirements, DOE considered four factors in developing sample size. Again, this is what DOE considered. The actual sample size will be discussed shortly. So the sample size should provide highly statistical valid probability that a basic model is tested and meets the applicable standards, providing a highly statistically valid probability that a manufacturer preliminarily found to be in noncompliance will actually be in noncompliance, minimizing manufacturers' testing time and costs, assuring**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 4 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 compatibility with other sampling plans. MR. BROOKMAN: Gary. MR. FERNSTROM: What is "highly statistically valid"? MR. O'ROURKE: This is Conan. That would be testing everything. (Laughter.) MR. FERNSTROM: But I mean, you could put a quantitative -- MR. O'ROURKE: Right. He goes on in a little bit to discuss this further. He was just saying these are the considerations that he started out with. MR. MYER: Thank you. MR. BROOKMAN: Let's then get the rest of the definition, or the rest of the description. MR. MYER: Okay. Moving to basic model, DOE proposes a definition for basic model with respect to metal halide ballasts -- I'm sorry? MR. BROOKMAN: Excuse me. I'm sorry. Now I got confused. I thought you were moving -- is basic model a part of the sample size discussion? MR. MYER: Well, what it needs is that we need to define basic model and then we can discuss the sample size so everyone knows what a basic model is. MR. BROOKMAN: You haven't yet at least**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 4 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 defined sample size in any sort of a statistical convention that we'd understand. MR. MYER: That is correct. MR. BROOKMAN: Okay. Keep going. MR. MYER: So, a review of the definition of basic model. DOE proposes a definition for basic model. With respect to metal halide ballasts, all units of a given type of metal halide ballast or class thereof that 1) are rated to operate a given lamp wattage and type, 2) have essentially identical electrical characteristics, and 3) have no differing electrical, physical, or functional characteristics that affect energy consumption. MR. O'ROURKE: This is Conan again. Keith, to your question, if it's a bracket issue it shouldn't change. MR. COOK: Right, right. I agree. MR. BROOKMAN: Thank you. That's helpful. Okay. So then, additional comments on these eight terms that the Department is proposing to add? MR. MYER: Oh, you moved on to -- MR. BROOKMAN: Oh, sorry. I moved to the comment. MR. MYER: So that moves us into a request for comment. Item 9, the Department invites comment on**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 5 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 its definition for the following eight terms that it is proposing to add to 10 C.F.R. Part 431: AC control signal, active mode, basic model, DC control signal, off mode, power line carrier control signal, standby mode, and wireless control signal. MR. COOK: We'll provide something in written comments on that. MR. BROOKMAN: Thank you, Keith. Okay. Let's proceed. MR. MYER: Moving forward, we're turning to units to be tested and sample size. DOE considered three alternatives for specification of test sample size for metal halide ballast equipment: 1) test every unit to determine with 100 percent certainty that each one complies with the statute; 2) test a predetermined number of units to yield a high level of statistical confidence; and 3) test until a determination can be made that a basic model does or does not comply. And again, we're going to move forward. These are just, again, our approaches. MR. BROOKMAN: And the previous slide, Number 52, that talks about factors for developing sample size requirements, and this talks about alternatives for specification.**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 5 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. MYER: Yes. MR. BROOKMAN: Okay. The intermediary slides messed me up. Go ahead. MR. MYER: Keith, do you -- MR. COOK: Well, I guess I don't see any difference between Numbers 1 and 3. MR. O'ROURKE: Three isn't necessarily 100 percent testing. This is Conan again. MR. COOK: Well, it does. MR. O'ROURKE: No, it tests [until you can tell one way or another if it passes] -- say you come up with a number that, say, you test 90 of them, right, and it shows that the confidence is [ 5 percent ]-- is such that you're below the efficacy requirement. MR. COOK: Okay. MR. O'ROURKE: Then you could say at that point I've determined that it does or does not meet the standard. So you wouldn't have to test everything necessarily. MR. COOK: Well, you do until you can prove it fails. It's 100 percent until it fails. MR. O'ROURKE: I guess you would be starting with a number somewhere larger than four and something less than 100. MR. MYER: I guess the way I understand these**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 5 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 three are, one is absolute, you're going to test everything; two, we're going to come up with a number that we think is statistic; three is a different approach where we don't know what the number is at the time. But I can understand why you're saying -- MR. O'ROURKE: This is Conan again. You have to test enough that you can get your confidence interval down to show that it is above the limit. And you [can stop when the determination is reached] -- that isn't testing everything necessarily. MR. COOK: Okay. That's not the way I read it, but okay. MR. BROOKMAN: It's your intention to not force them to test everything. MR. MYER: It's a middle position. MR. BROOKMAN: So then, Keith, if there's a way that you can figure to supply the information -- the definition so that you don't have to test everything, the Department -- MR. COOK: Right. That would be extremely burdensome. MR. BROOKMAN: Yeah. (Laughter.) MR. BROOKMAN: But there's all this statistical convention kind of stuff, right, with**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 5 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 sampling size and confidence levels, right? Isn't there some way you can reference that kind of stuff? MR. COOK: Well, yeah. MR. BROOKMAN: Yeah. Okay. I'm trying to -- it's been a long time since I've had those statistics courses, but okay. MR. MYER: This actually moves on to the units to be tested, the actual sampling procedure. So DOE proposes randomly selecting and testing a sample of production, not fewer than four of a representative model. A simple average of values would be calculated and become the mean of the sample. For each representative model, a sample of sufficient size -- again, no less than four -- would be selected at random and tested to ensure that the calculated value of energy efficiency is no less than 1) the lower of the mean of the sample, or 2) the lower of 99 percent confidence limit of the mean of the entire population of that basic model divided by a coefficient applicable to the representative value. MR. COOK: I have to think that one through. MR. BROOKMAN: Yeah, let's just pause for a moment there and see if anything comes out now. MR. MYER: The first point is saying you're going to take a sample size and that becomes your mean.**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 5 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I think that's the easy one for everyone to get. It gets a little harder after you move on down to -- MR. COOK: Number 2 is the one that's -- MR. BROOKMAN: Go ahead, Conan. MR. O'ROURKE: This is Conan. I just want to give some clarification. This language was selected from what's already there for some of the fluorescent ballasts and for the mercury vapor ballasts that were in there. So this isn't something new. It's just trying to adapt to what's already out there for other ballast types and applying it to metal halide. MR. BROOKMAN: Gary. MR. FERNSTROM: So, Conan, I understand what a 99 percent confidence limit is, but what does it mean when you divide it by the coefficient applicable to the representative value? MR. COOK: Yeah. MR. O'ROURKE: I can't comment that I can explain that myself, either. That's a question that we're trying to get an answer to about the second half of that. MR. BROOKMAN: But you say that is from a definition that's in the fluorescent -- MR. O'ROURKE: In other ballasts. MR. FERNSTROM: Okay. Well, I'd be delighted**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 5 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 to understand what that means because my knowledge doesn't go that far. (Laughter.) MR. BROOKMAN: Okay. So, how does that information get supplied to those that are interested in obtaining it? Linda Graves. MS. GRAVES: Yes. Well, your comments are considered and we will respond to all significant comments in the next iteration of this rulemaking. But we will take it in and respond to it that way. MR. BROOKMAN: Thank you. Okay. So then, additional comments on this slide, Slide 56? And final comment, perhaps, on that slide? (No response.) MR. MYER: Moving forward, request for comment. The Department invites comment and data on the accuracy and applicability of the proposed sampling for metal halide ballasts. The Department seeks comment on whether an alternative sampling method exists that might be more appropriate for metal halide ballasts. MR. COOK: I'm assuming that we'll have access to this presentation, right? MR. BROOKMAN: Right. Yeah. MR. COOK: We'll gladly --**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 5 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. BROOKMAN: Linda Graves. MS. GRAVES: Linda Graves, yes. We will post the slides on the webpage after this meeting. MR. BROOKMAN: Thank you. So then, I think we've covered that as best we can at this point. MR. MYER: Continuing on, submission of data. DOE proposes that the manufacturer or other entity conducting tests on behalf of the manufacturer provide a certification report for each basic model that would include the following information: 1) the equipment type, 2) the manufacturer's name, 3) the private labeler's name, if applicable, and 4) the manufacturer's model number. The report would be required to certify that the testing was completed in accordance with the applicable test requirements prescribed in 42 USC 6293(b) of EPCA, as amended. MR. BROOKMAN: Is this any different than what they do now? MR. MYER: I'm sorry. What the manufacturer does now? MR. BROOKMAN: Yes. MR. MYER: Well, at the moment, the manufacturer is not submitting a report. I mean, they're asking for a report, but it's not -- MR. BROOKMAN: I was thinking consistent with**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 5 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 other ballasts. MR. COOK: The data is consistent. MR. MYER: Yes. MR. BROOKMAN: Okay. That's what I wanted to know. Okay. As a benchmark. So, okay. Additional comments, Keith, on this? MR. COOK: No. This is acceptable to us. MR. BROOKMAN: Okay. MR. MYER: Request for comment. Item 12, the Department invites comment on the potential impact of applying data requirements described in other DOE test procedures for products and equipment subject to energy conservation standards as it applies to metal halide ballasts. DOE seeks comment on whether an alternative set of submission requirements exists that might be more appropriate for metal halide ballasts. MR. BROOKMAN: Okay? MR. COOK: That's fine, yes. MR. BROOKMAN: Okay. Thank you, Keith. MR. MYER: Enforcement provisions. Once a federal energy conservation standard becomes effective for metal halide ballasts, the enforcement of the appropriate application of the testing procedure for this equipment would be subject to enforcement of the efficiency requirements and verification of the**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 5 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 documented testing. DOE proposes to apply to metal halide ballasts the same basic requirements for enforcement currently in place for other lighting equipment. DOE will review the testing certification. MR. BROOKMAN: Is the next slide linked? MR. MYER: Yes. MR. BROOKMAN: Why don't you go with that one, then. MR. MYER: Enforcement provisions. If DOE receives written information about the performance of metal halide ballasts indicating that one or more basic models may not be in compliance with energy conservation standards, DOE may conduct independent testing of those basic models. The results of this testing would serve as the basis for any enforcement actions related to the application of these metal halide ballast test procedures. MR. BROOKMAN: So, why don't you read the comment box, then. MR. MYER: Request for comment. Item 13, the Department invites comment on the potential impact of applying the enforcement provisions described in other DOE test procedures for products and equipment subject to energy conservation standards as they apply to metal**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 5 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 halide ballasts. MR. BROOKMAN: So let's just pause and give you a chance to reread these slides here. Yes, Keith? MR. COOK: Yeah, it's fine. MR. BROOKMAN: This is essentially the same as for other ballasts. MR. COOK: Yeah, this is what you'd expect. MR. BROOKMAN: Yeah. Okay. MR. COOK: No surprises. MR. BROOKMAN: Okay. MR. MYER: Closing remarks. At this time I'm going to return the presentation to Linda and Doug. Conclusions and Closing Remarks Linda Graves MS. GRAVES: Linda Graves. I guess, lastly, we'd just check with you. Do you have any other statements you would like to make? (No response.) MS. GRAVES: Okay. Then, in that case, really the last thing is that we welcome your comments. The notice that is posted on our webpage has all the details of how to provide comments, but I would just point out that we would like you to be sure and identify the topic and either include the docket number or the regulatory identification number. We have a lot**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 6 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 of different lighting rulemakings in progress. It makes it easier for the people who manage our docket to keep that clear. And you know that you can submit your comments electronically or by mail or by courier. MR. COOK: Excuse me, Linda. To make things a little easier, do you know exactly what the webpage is that this will be posted in? MR. O'ROURKE: Michael, can you go to the next slide? MR. MYER: It's on the first -- MS. GRAVES: I realize that we forgot to put it on this handout. MR. MYER: It's on the very first slide in very, very light color. At the bottom, under where it says D.C. MR. COOK: Oh, I didn't even realize that was there. MR. MYER: It's one of those PowerPoint things that the link had been selected and so it changed color. MR. COOK: Okay. I see. MR. MYER: And the following -- and the last slide -- but that's where the URL for that is found in this presentation.**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 6 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. GRAVES: If you received the original email when I sent out the notification to all the stakeholders in my lighting e-mail list, that was where the link was. MR. COOK: Okay. MS. GRAVES: I will send out another e-mail when the notice is actually published in the Federal Register. There has been a backup in getting notices published at the Federal Register, so DOE has officially issued the notice but the Federal Register publication of the notice is what actually triggers the counting of the 75-day comment period.So when that happens, I will send out an email to everyone letting you know the public comment period has started and the Federal Register will actually specify what the 75-day ending date is. So that will be in the e-mail message, and we will also swap out the actual Federal Register notice onto the webpage. Any other questions? (No response.) MS. GRAVES: In that case, I want to thank you very much for coming. This was extremely useful input to the Department. Clearly, stakeholders are quite knowledgeable on this topic, and I think that's**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 6 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 why we had such an expedited meeting. Thank you very much. MR. BROOKMAN: Thank you. We have an evaluation form. If you'd take 30 seconds to fill them out, that would be helpful to the Department. (Whereupon, at 12:30 p.m., the meeting was adjourned.)**EXECUTIVE COURT REPORTERS, INC. (301)**  **565-0064** 6 3 **REPORTER'S CERTIFICATE** 1 2 3 4 5 6

7 8 9 10 11 12 13 14 15 This is to certify that the attached proceedings before: **UNITED STATES DEPARTMENT OF ENERGY** In the Matter of: **PUBLIC MEETING ON ENERGY CONSERVATION PROGRAM FOR CERTAIN COMMERCIAL AND INDUSTRIAL EQUIPMENT: TEST**  **PROCEDURES FOR METAL HALIDE BALLASTS** 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.



### Wendy Greene 16 17

18 Official Reporter

Dated: December 24, 2008