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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 

 

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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 

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

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 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. 

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MR. MYER: Michael Myer, Pacific Northwest 

National Laboratory. 

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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 

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1 proposed ballast efficiency test method. 

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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. 

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1 Okay. Gary, anything from you? No? Okay. 

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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 

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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 

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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. 

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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 

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completed by the middle of this year. They expect to 

have everything finished by mid 2009. 

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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 

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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 

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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 California 

to 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? 

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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. 

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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 

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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 

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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 

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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. 

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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. 

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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? 

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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 

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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, 

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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 

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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. 

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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 

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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, 

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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. 

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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? 

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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. 

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 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. 

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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 

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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 

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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 

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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. 

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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? 

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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. 

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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. 

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 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. 

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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. 

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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. 

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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 

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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 

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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 

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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 

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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. 

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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 

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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. 

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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, 

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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 

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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 

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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 

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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 

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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. 

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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 

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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 

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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. 

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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 

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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 -- 

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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 

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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 

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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 

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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 

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makes it easier for the people who manage our docket to 

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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. 

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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 

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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.) 

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1 REPORTER'S CERTIFICATE

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 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. 

 

16 Wendy Greene 17 

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 Official Reporter 

Dated: December 24, 2008 

EERE-2008-BT-TP-0017 COMMENT 11