TRANSCRIPT OF PROCEEDINGS

HERITAGE REPORTING CORPORATION

Official Reporters

1220 L Street, N.W., Suite 206

Washington, D.C. 20005

(202) 628-4888

contracts@hrccourtreporters.com

IN THE MATTER OF: )

 )

PUBLIC MEETING ON ENERGY )

CONSERVATION STANDARD )

FRAMEWORK -- FLUORESCENT )

LAMP BALLASTS )

Pages: 1 through 121

Place: Washington, D.C.

Date: July 17, 2015
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UNITED STATES DEPARTMENT OF ENERGY

OFFICE OF ENERGY EFFICIENCY & RENEWABLE ENERGY

IN THE MATTER OF: )

 )

PUBLIC MEETING ON ENERGY )

CONSERVATION STANDARD )

FRAMEWORK -- FLUORESCENT )

LAMP BALLASTS )

 )

)

Room 8E-089

James Forrestal Building

1000 Independence Avenue, S.W.

Washington, D.C.

Friday,

July 17, 2015

The parties met, pursuant to the notice, at 

9:05 a.m.

PARTICIPANTS:

MR. DOUG BROOKMAN, Facilitator

MS. LUCY deBUTTS, DOE Lighting Project Manager

MS. MARY ANDERSON, Pacific Gas & Electric

MR. ALEX BOESENBURG, National Electrical

 Manufacturers Association

MS. SARAH BUTLER, DOE General Counsel 

MR. JOHN CYMBALSKY, DOE Appliance Standards 

Program Manager

MS. RACHEL DICKENSON, Navigant Consulting

MR. DOUG ELLIOTT, Pacific Northwest National Lab

MR. CHRIS GRANDA, Appliance Standards Awareness

 Project

MR. S. PEKKA HAKKARAINEN, Lutron Electronics Co.

MR. JOSEPH G. HOWLEY, GE Lighting

MR. CHRIS HOLSTEIN (via telephone), Universal

 Lighting Technologies

MR. AL MENDOZA, Southern California Edison

MR. ERNESTO MENDOZA, Philips

MR. MICHAEL MYER, Pacific Northwest National Lab

MS. ALI MCDONALD, Navigant Consulting
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PARTICIPANTS: (Cont'd)

MS. REBECCA RAINER, Eaton Corporation

MR. CHARLIE STEPHENS, Northwest Energy Efficiency

 Alliance

MR. ANDREW SHORE, Navigant Consulting

MR. BACH TSAN, Southern California Edison

MR. MATTHEW WALKER, Navigant Consulting

MR. DANIEL YOUNG, California Investor-Owned

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

2 (9:05 a.m.)

3 MR. BROOKMAN: Let's get started. Good 

4 morning. Good morning, everyone. Welcome. This is 

5 the U.S. Department of Energy's Public Meeting on 

6 Energy Conservation Standards, the framework meeting 

7 on fluorescent lamp ballasts. Today is Friday,

8 July 17, 2015, here in the Forrestal Building in 

9 Washington, D.C. Welcome to all of you. Good to see 

10 you here this morning. We're going to start with 

11 welcoming remarks from Lucy deButts.

12 MS. deBUTTS: Okay. Great. Okay. Hi, 

13 everybody. Thank you for coming. My name is Lucy 

14 deButts. I am the team lead for the lighting team at 

15 the Appliance Standards Program, and today we are here 

16 to discuss the framework document for fluorescent lamp 

17 ballasts. So, with that, I guess we can discuss the 

18 agenda.

19 MR. BROOKMAN: Thank you. We're going to 

20 start with introductions. You should turn these 

21 microphones both on and off and say your name and 

22 organizational affiliation.

23 MR. A. MENDOZA: Hello. My name is Al 

24 Mendoza. I'm here representing Southern California 

25 Edison and the California IOUs.
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1 MR. BROOKMAN: Thank you.

2 MS. RAINER: Rebecca Rainer with Eaton 

3 Corporation, the Lighting Division.

4 MR. HAKKARAINEN: Pekka Hakkarainen with 

5 Lutron Electronics.

6 MR. BOESENBURG: Alex Boesenburg, National 

7 Electrical Manufacturers Association.

8 MR. HOWLEY: Joe Howley, GE Lighting.

9 MR. YOUNG: Daniel Young representing the 

10 California Investor-Owned Utilities.

11 MS. ANDERSON: Mary Anderson, PG&E.

12 MR. GRANDA: Chris Granda, Appliance 

13 Standards Awareness Project.

14 MR. STEPHENS: Charlie Stephens, Northwest 

15 Energy Efficiency Alliance.

16 MS. BUTLER: Sarah Butler, DOE.

17 MR. BROOKMAN: I think we've figured out how 

18 to make that microphone work, so hopefully it will.

19 MS. MCDONALD: Ali McDonald, Navigant 

20 Consulting.

21 MR. WALKER: Matthew Walker, Navigant.

22 MS. DICKENSON: Rachel Dickenson, Navigant.

23 MR. MYER: Michael Myer, Pacific Northwest 

24 National Laboratory.

25 MR. BROOKMAN: Please.
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1 MR. ELLIOTT: Doug Elliott, Pacific 

2 Northwest National Laboratory.

3 MR. TSAN: This is Bach Tsan, Southern 

4 California Edison, on behalf of California IOUs.

5 MR. BROOKMAN: Thanks to all of you. Nice 

6 to see you this morning. I hope all of you received a 

7 packet of information as you entered the room. I'm 

8 going to do a very brief agenda review. After this 

9 agenda review and a few introductory slides there's an 

10 opportunity for opening remarks, brief summary 

11 comments here at the outset about issues that matter 

12 to you. Following that, we'll move straight into the 

13 content provided in this packet of PowerPoint slides, 

14 an overview discussion on scope of coverage, and 

15 moving on directly from there, market and technology 

16 assessment screening analysis.

17 We'll take a break mid-morning around about 

18 10:15, 10:30 or so. Following that, engineering 

19 analysis, and moving on directly to energy use 

20 analysis, markups analysis, life-cycle cost analysis. 

21 We'll take lunch around about noon or so.

22 Returning from lunch or whenever we get 

23 there, shipments analysis, national impact analysis, 

24 and then finally, NOPR analyses, and as you see in the 

25 agenda, when we arrive at the end of the day today, 
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1 another opportunity for public comment and other 

2 questions that may be still unresolved for you at that 

3 point. Yes? Alex Boesenburg.

4 MR. BOESENBURG: One of my members on the 

5 phone asked if you wouldn't mind reading out the list 

6 of web attendees.

7 MR. BROOKMAN: Web attendees. Okay. I 

8 think we could do that.

9 Emily, do you -- can you hand Emily that 

10 microphone?

11 FEMALE VOICE: I can give him the ability to 

12 see the web attendees.

13 MR. BROOKMAN: That would be better yet. 

14 Okay. So that will now be visible to all the web 

15 attendees?

16 FEMALE VOICE: Yes.

17 MR. BROOKMAN: Okay. Great. So we'll know 

18 who's on the line.

19 All of you I think, many of you at least, 

20 are familiar with the general format and framework for 

21 these meetings. I'd ask for your consideration, 

22 please, if you would speak one at a time. If you'd 

23 say your name for the record each time you speak, it 

24 makes the transcript so much easier to read. And the 

25 Department follows all of this information very 
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1 closely. There will be a complete transcript of this 

2 meeting made available. If you could be concise to 

3 share the air time and keep the focus here. If you 

4 haven't turned your cell phones on silent mode, please 

5 do so at this point.

6 And webinar participants, if you'd keep your 

7 phones on mute and raise your hand to be recognized to 

8 speak. We would welcome your engagement in this 

9 discussion today here in the room. If you raise your 

10 hand to speak, then probably we'll be able to hear you 

11 in the room. That works most of the time these days.

12 And I think everyone at this point knows the 

13 Department is making every effort to make these public 

14 meetings accessible, totally available via the 

15 internet, and that's why this webcast is available.

16 Please, in addition to listening in and 

17 participating today, please make certain if you're 

18 participating via the web to send in your written 

19 comments to the Department of Energy. They track this 

20 stuff very, very carefully and they benefit from 

21 everyone's comments.

22 And now we're going to go to Lucy deButts' 

23 purpose of the public meeting.

24 MS. deBUTTS: Okay. This is Lucy deButts 

25 again. So the purpose of the public meeting, and I 
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1 stated, is to discuss the framework document that DOE 

2 created for the fluorescent lamp ballasts. We would 

3 like to invite comments from the participants in the 

4 room and people on the webinar. We also expect 

5 written comments not just from people on the webinar 

6 but from everybody, all the stakeholders that are in 

7 the room as well. And so hopefully this is going to 

8 be a helpful discussion that will allow us to come up 

9 with a better analysis further in the rulemaking.

10 You will notice that throughout the 

11 presentation we have the issues boxes where we raise 

12 certain issues for discussion. We are not presenting 

13 all the issues that are in the framework document 

14 today. We're just highlighting those that we'd like 

15 to have a very, you know, lively discussion about. 

16 And you'll also notice that the issue boxes, the 

17 numbers of the issues boxes correspond with the 

18 numbering within the framework document. All right?

19 So if you decide to submit written

20 comments -- and we're really, really looking forward 

21 to them -- there's several avenues of doing so. We 

22 also ask you to make sure that the comments include 

23 the rulemaking title, the docket number, and the RIN 

24 number. This can be done via web, email, or postal 

25 courier, and of course, if anybody decides to take a 
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1 trip to DOE, you're more than welcome. Hopefully it's 

2 going to be via web, though.

3 And the comment period closes on August 7, 

4 2015, so we're hoping to get your comments by then. 

5 Thank you.

6 MR. BROOKMAN: As we had said at the outset, 

7 an opportunity for opening remarks, brief summary 

8 statements here at the outset from anyone that wishes 

9 to. Alex Boesenburg?

10 MR. BOESENBURG: Well, thank you, Doug. 

11 Again, I'm Alex Boesenburg of NEMA. We wanted to --

12 I'll just make a quick summary statement and we can 

13 hit some specific points as the comment boxes appear.

14 But, you know, obviously the first thing to 

15 note is that the previous ballast rulemaking only 

16 recently went into effect, so the impacts are still 

17 being understood, and its effect on the market will 

18 have to be analyzed as it folds in.

19 The previous rule was very aggressive, and 

20 as such it, you know, certainly at this time does not 

21 appear that there's any remaining margin on currently 

22 regulated products. We understand that's part of the 

23 reason why the DOE asked for other scope questions, 

24 like 480 volts or dimming ballasts and things like 

25 that.
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1 Specific to dimming ballasts, I'm sure it 

2 will come up in discussion that California proposed 

3 and adopted standards for T8 and T5 dimming ballasts, 

4 and those were very aggressive but we think are not 

5 untenable. But before the DOE seeks to simply 

6 implement the California regulation as written it's 

7 important to note there are some differences in the 

8 definitions and test method in California, which means 

9 if you take the DOE test method that exists today and 

10 the California numbers for ballast performance you'll 

11 have no products for sale in the United States. So 

12 it's a very, very key thing, and so the analysis will 

13 need to be done carefully.

14 I think in the end, if the DOE sets 

15 standards for dimming ballasts nationally using the 

16 DOE test method, that means that the numbers, the 

17 performance numbers will be different, but in the end 

18 it's the same product qualifying. That's my point I 

19 want to make.

20 I do want to raise a concern that I 

21 encourage the DOE not to push any harder into standby 

22 power requirements and lowering those because we can 

23 all read the news and see that the Internet of Things 

24 and connected products are becoming amazingly popular. 

25 And lighting is being looked at as one of those ever 
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1 present things that could become the node for the 

2 smart products in the home or in the office or what 

3 have you, and standby power directly correlates to 

4 that.

5 But lastly, all of this may end up being 

6 somewhat of an academic exercise because NEMA's data 

7 for the last five years for fluorescent ballast sales 

8 -- and I say five years because that's when we think 

9 LEDs started to offset the market -- it's only five 

10 years of data points, but if you do a second degree

11 polynomial fit, standard S curve, that would forecast 

12 the fluorescent ballast market ending in mid-2018. 

13 That's probably not, you know, realistic, but it is 

14 starting to coast out.

15 So that has been -- the effects of SSL have 

16 been taken into account like such as in the metal 

17 halide fixture rule and others, so this is again 

18 another excellent one to step back and say, well, 

19 what's really going to happen since we have this 

20 amazing technology that's becoming more prevalent and 

21 more cost-effective. So we'll look forward to working 

22 with the Department on those predictions.

23 MR. BROOKMAN: Thank you. And of course the 

24 Department will look forward to seeing as much data as 

25 NEMA can provide. Yes. Okay. Other comments here at 
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1 the outset? Preliminary thoughts before we proceed 

2 with this content?

3 (No response.)

4 MR. BROOKMAN: Nothing additional. So then 

5 let's go to the slides that you have before you.

6 MS. deBUTTS: Okay. So I'm going to present 

7 the overview and the scope of coverage. And let's 

8 start with the regulatory history. So EPCA directed 

9 DOE to conduct 2 rulemaking cycles for fluorescent 

10 lamp ballasts and the first rulemaking was completed 

11 in 2000. The second rulemaking we finished, as Alex 

12 said, somewhat recently, in 2011. The 2011 ballast 

13 final rule amended all previous standards, so today's 

14 ballasts are subject to standards outlined in that 

15 rulemaking.

16 Going forward, EISA also directs DOE to 

17 periodically review all of its standards, including 

18 those for fluorescent ballasts, and therefore, within 

19 six years of the publication of the previous rule, in 

20 this case 2011 ballast rule, DOE must publish a notice 

21 of determination that standards do not need to be 

22 amended or need to publish a notice of proposed 

23 rulemaking amending the existing standards or 

24 proposing new ones.

25 This slide gives us an overview of the 
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1 rulemaking, and as you can see, we anticipate that the 

2 preliminary analyses are going to be published in the 

3 fall of 2016, with the NOPR following in October of 

4 2017, which would place it at seven years after the 

5 2011 public final rule, per EISA requirements.

6 And finally, we anticipate that the final 

7 rule is going to come out two years later, making it 

8 October 2019. 

9 And between now and the completion of the 

10 2019 final rule, DOE will consider seven factors in 

11 its analyses that prescribed by EPCA. Some of those, 

12 like economic impact analysis on individual consumers, 

13 are considered in a life-cycle cost analysis. The 

14 economic and energy savings impact on the nation as a 

15 whole will be considered in the national impact 

16 analysis, and economic impact on manufacturers will be 

17 considered in manufacturing impact analysis. DOE will 

18 also consider impacts on utility or performance and 

19 any other factors that Secretary considers relevant.

20 So currently standards only apply to active 

21 mode, which is a primary light-producing via a lamp 

22 mode of ballast. However, EPCA, as Alex mentioned, 

23 requires DOE to look into standards for standby mode 

24 and off mode consumption where relevant.

25 So let's review the definitions for the 
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1 standby mode and the off mode. So the standby mode is 

2 defined as the condition in which an energy using 

3 piece of equipment is connected to the main power 

4 source and offers one or more following user-oriented 

5 or protective functions: facilitating the activation 

6 or deactivation of the other functions by remote 

7 switch, internal sensor or timer, and providing 

8 continuous functions, including information or status 

9 displays or sensor-based functions.

10 The off mode is defined as a condition in 

11 which the energy using piece of equipment is connected 

12 to the main power source and is not providing any 

13 standby or off mode functions. DOE's research 

14 indicates that there are some ballasts that operate in 

15 standby mode, but we did not find any that operate in 

16 off mode.

17 And with that, we would like to welcome 

18 comments on the standby mode of operation and any 

19 information related to the energy use in that mode.

20 MR. BROOKMAN: Charlie Stephens?

21 MR. STEPHENS: Charlie Stephens. We've been 

22 talking about this since DOE has been required to look 

23 at standby mode, but does DOE have any intention at 

24 this point to define network mode in a manner similar 

25 to the EU's definition for standby such that we could 
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1 start looking at products that are actually connected?

2 MS. deBUTTS: At least not in this 

3 rulemaking. Not that I'm aware.

4 MR. STEPHENS: Okay.

5 MR. BROOKMAN: Yes, Daniel?

6 MR. YOUNG: Daniel Young, California IOUs. 

7 So regarding standby mode, a couple comments. Well, 

8 first of all, just to reiterate Alex's point earlier 

9 about the work that's been done in California, so 

10 there's a lot of data that we've collected in the past 

11 two years and we've, you know, just gone through a 

12 whole process and so there's going to be a lot from 

13 that I think is relevant here, especially if dimming 

14 ballasts end up being covered. It sounds like they're 

15 being seriously considered.

16 So regarding standby mode energy use, I 

17 think it's something that's a lot more common with 

18 dimming ballasts than with fixed output ballasts. We 

19 found, you know, quite a few of the dimming ballasts 

20 models that we tested were communications-enabled and 

21 therefore had standby mode energies associated with 

22 it. And we measured that energy use according to the 

23 test procedure that DOE has provided but it is not 

24 currently implementing and, you know, I can share some 

25 of those results, but basically we saw products 
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1 perform anywhere from between 0.3 watts up to 1.9 

2 watts. And we'll of course, you know, docket the data 

3 that we do have and you'll have that for yourselves. 

4 But, yeah, thanks.

5 MS. deBUTTS: Thank you.

6 MR. BROOKMAN: Thanks, Daniel. Okay. Other 

7 comments on standby mode?

8 (No response.)

9 MR. BROOKMAN: Okay.

10 MS. deBUTTS: All right. Well, then, with 

11 that, let's talk about the metric. So current energy 

12 savings -- sorry. So current energy conservation 

13 standards for fluorescent lamp ballasts are applicable 

14 to active mode energy use and are based on ballast 

15 luminous efficiency, BLE. And DOE actually plans to 

16 continue using the BLE metric for energy conservation 

17 standards rulemaking to regulate active mode energy 

18 use.

19 For standby power, DOE plans to consider an 

20 integrated metric. For example, a standby mode21 capable ballast such as a dimming ballast may draw 

22 additional power in active mode as a result of 

23 additional circuitry in place, to support standby mode 

24 of operations. And with that, we welcome comments on 

25 the metric.
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1 MR. BROOKMAN: Daniel?

2 MR. YOUNG: Daniel Young, California IOUs. 

3 So again, this is based on our experience in 

4 California, but for dimming ballasts we did need to 

5 adopt a new metric, and this relates to the test 

6 procedure issue as well that Alex brought up, but 

7 basically the metric that we adopted for dimming 

8 ballasts in California involves performance at 100 

9 percent, 80 percent, and 50 percent of full light 

10 output. And we used a duty cycle weighted approach to 

11 kind of come up with a single, it's defined as 

12 weighted BLE, and that's ultimately the metric that 

13 was regulated in California as a function of 100 

14 percent lamp arc power.

15 And so again, you know, I echo Alex's 

16 comment that DOE should strongly consider opening a 

17 docket for the test procedure if it wishes to cover 

18 dimming ballasts using a similar format that we did in 

19 California.

20 MR. BROOKMAN: How long has that test 

21 procedure been, have you been using it in California?

22 MR. YOUNG: So the standard was just 

23 adopted, so it's not effective until, gosh, I think 

24 it's early next year. I think 2016, July. So, you 

25 know, right now, as far as I know, we're the only ones 
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1 that have completed testing for those products and, 

2 you know, docketed that information with the Energy 

3 Commission, which we'll share with you as well. I'm 

4 sure manufacturers have done testing of their own, but 

5 I think that's right now the only source of, you know, 

6 one set of data.

7 MR. BROOKMAN: Okay. Please say your name 

8 for the record.

9 MR. E. MENDOZA: Mr. Mendoza from Philips. 

10 If I'm not mistaken, I think the published Title 20 do 

11 not include the dimming procedure last year. Are you 

12 guys going to publish it later? Pretty soon or 

13 something like that?

14 MR. YOUNG: So we docketed data with the 

15 Energy Commission last year. It might have been two 

16 years ago at this point. But that's been publicly 

17 docketed and, you know, we can follow up offline. I 

18 can provide you a link to that, where that data is.

19 MR. BROOKMAN: That was Daniel. Now back to 

20 Ernesto.

21 MR. E. MENDOZA: Yeah. I think I have seen 

22 the document, but what I'm saying is in the Title 20, 

23 as it is published, that I looked yesterday at the 

24 California Energy Commission website, Title 20 is not 

25 there.
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1 MR. YOUNG: I see.

2 MR. BROOKMAN: Yeah. Okay. Alex 

3 Boesenburg.

4 MR. BOESENBURG: Alex Boesenburg, NEMA. 

5 We've been discussing this internally and I spoke to 

6 CEC yesterday, so I think I can make a statement that 

7 clears up any possible confusion. The rulemaking 

8 process for Title 20 for dimming ballasts concluded in 

9 May of this year when the Commission adopted the 15-

10 day language. Right now the only existing guidance is 

11 that, if you will, draft of the new standard. CEC has 

12 not yet published an updated Title 20 reflecting those 

13 changes yet. They made a recent publication which got 

14 some people excited because they thought oh, now the 

15 new 2015 code is out, but it was only a fast track to 

16 get the water-related changes from the previous 

17 rulemaking implemented immediately due to their 

18 crisis.

19 The process has yet to finish percolating 

20 through to fully update Title 20 to include dimming 

21 ballasts, and so the point to make relative to that is 

22 that means that Daniel's data from the proposal 

23 process is the only body of data about how to test a 

24 ballast using the recommended code changes. Because 

25 it's not implemented, it follows my members have not 
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1 been testing their products to it, it follows that the 

2 CEC compliance certification database doesn't have any 

3 data in it yet. So it's pretty scant right now.

4 MR. BROOKMAN: Okay. And will you confirm 

5 since you've talked with them recently what's the 

6 effective date for the new test procedure?

7 MR. BOESENBURG: Ken Ryder is honchoing that 

8 one. He did not have a date to --

9 MR. BROOKMAN: Oh, curious. Interesting.

10 MR. BOESENBURG: Just that it's --

11 MR. BROOKMAN: Okay.

12 MR. BOESENBURG: They're more concerned 

13 about water right now.

14 MR. BROOKMAN: Yeah. Understandable.

15 MR. BOESENBURG: So everything's getting the 

16 attention of water-related first.

17 MR. BROOKMAN: Okay. So final comments on 

18 this subject? Did you also want to queue up, Lucy --

19 MS. deBUTTS: Yeah. I mean, I understand 

20 that you guys want to, asked to look at the test 

21 procedure, but any other additional comments on the 

22 test procedure as well?

23 (No response.)

24 MR. BROOKMAN: Wanted to make sure we 

25 covered that. Yes? Okay? We're all set. We're 
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1 moving on.

2 MS. deBUTTS: Okay. Next let's look at the 

3 scope of coverage for this rulemaking. So the scope 

4 of coverage includes any device that meets the 

5 definition of fluorescent lamp ballasts. However, as 

6 you will see over the next few slides, not all of the 

7 covered ballasts are currently or plan to be subject 

8 to standards.

9 So what is a fluorescent lamp ballast? It's 

10 a device which is used to start and operate 

11 fluorescent lamp by providing a starting voltage and 

12 current and limiting the current during normal 

13 operations. The definition of fluorescent lamp starts 

14 to narrow the scope. It includes 4-foot medium bi-pin 

15 lamps with rated wattage of 25 or greater, T5 standard 

16 output lamps with rated wattage of 25 or greater, and 

17 several others.

18 So, of the covered ballasts, only some are 

19 currently subject to standards. These include 

20 ballasts that operate at or between 120 and 277 volts 

21 and operate lamps that meet the definition of 

22 fluorescent lamp.

23 However, there are three categories of 

24 ballasts that are not subject to standards, and those 

25 are, in general, dimming ballasts are not required to 
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1 comply with standards, although ballasts that operate 

2 certain reduced wattage T12 lamps are included, and 

3 that dates back to the standards directly prescribed 

4 by Congress in 2005.

5 Low frequency or magnetic ballasts designed 

6 to operate T8 lamps in EMI-sensitive environments in 

7 packages containing 10 or fewer ballasts are not 

8 included. And very low ballast factor programmed 

9 start ballasts that operate T8 medium bi-pin lamps are 

10 not required to comply with standards. As we'll 

11 discuss further, DOE is planning to analyze standards 

12 for the first and the third category I just mentioned.

13 In order to propose and adopt standards for 

14 ballasts DOE must find that standards would result in 

15 significant conservation of energy and also be 

16 technologically feasible and economically justified. 

17 So at this time DOE plans to consider analyzing 

18 standards for dimming ballasts, low ballast factor 

19 programmed start ballasts, and ballasts operating at 

20 480 volts. However, magnetic ballasts that operate T8 

21 lamps in EMI-sensitive environments will not be 

22 considered.

23 So let's discuss the justification for 

24 dimming ballast standards. In recent general service 

25 fluorescent lamp rulemaking, DOE determined that about 
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1 8 percent of GSFLs are now operated by dimming 

2 ballasts. This represents growth in dimming ballast 

3 sales since publication of 2011 ballast rule. So 

4 based on the increase in sales of dimming ballasts DOE 

5 plans to analyze the technological feasibility, 

6 economical justification, and potential for energy 

7 savings for dimming ballasts.

8 I know we've already talked about it a 

9 little bit, but we'd like to hear more about the 

10 dimming ballast approach.

11 MR. BROOKMAN: Daniel?

12 MR. YOUNG: Daniel Young, California IOUs. 

13 So, in California, this was mentioned in the framework 

14 document, but Title 24 we believe is having a major 

15 impact on the dimming ballast market in the state. So 

16 the current code essentially states that almost any 

17 application right now for new construction if you're 

18 putting in a fluorescent lamp needs to be dimmable to 

19 four levels, one of which is below 50 percent, which 

20 would make, you know, according to the code almost 

21 close to 100 percent essentially of ballasts -- excuse 

22 me -- lamps in, fluorescent lamps in California that 

23 are operated with a dimming ballast.

24 And so some of that actually applies to the 

25 retrofit market as well. It's to a lesser extent, but 
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1 we think a lot of the retrofit market as well will be 

2 switching to dimming ballasts in California.

3 MR. BROOKMAN: Thank you. Is there a big 

4 market, retrofit market for dimming ballasts? Yeah.

5 MR. YOUNG: Yes. Well, it's hard to know as 

6 clearly, but we believe that there is. And the way 

7 that the California Title 24 code is written now, it 

8 kind of impacts the market differently, and so we 

9 think -- again, the end result is that we think 

10 there's a lot more dimming ballasts being installed 

11 now than there were before the code.

12 MR. BROOKMAN: Thank you. Charlie Stephens?

13 MR. STEPHENS: Yeah. Charlie Stephens, 

14 Northwest Energy Efficiency Alliance. It's highly 

15 likely that in the four states of the Pacific 

16 Northwest those same kinds of requirements will be in 

17 effect by, you know, well before this rule goes into 

18 effect. So it's along with lower lighting power 

19 densities, and it will also likely apply much more 

20 often to existing buildings.

21 MR. BROOKMAN: John Cymbalsky.

22 MR. CYMBALSKY: John Cymbalsky, DOE. Can 

23 the manufacturers comment on how the California market 

24 and the Pacific Northwest market would impact the U.S. 

25 as a whole in terms of the dimming ballasts?
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1 MR. BROOKMAN: Alex Boesenburg.

2 MR. BOESENBURG: Alex Boesenburg, NEMA. 

3 I've made a note to ask my statistical folks if they 

4 can define anything from our data. I'm not sure. 

5 It's again still very early. It's hard to say. I'll 

6 ask them.

7 MR. BROOKMAN: Joe Howley.

8 MR. HOWLEY: Just as a general comment, most

9 retrofits did not include dimming ballasts nationwide. 

10 A typical lamp ballast retrofit is just with the 

11 ballast, with whatever ballast factor they want to use 

12 depending on the light level required, coupled with 

13 the lamp. And sometimes we see controls with them, 

14 but often it's just a simple lamp and ballast 

15 retrofit. The DOE regulations in existence now cover 

16 the efficiencies of those ballasts.

17 But in California there is some turmoil in 

18 the retrofit market right now because of requirements 

19 to go to a dimming ballast and much more advanced 

20 controls. They're having discussions right now about 

21 maybe if they want to adjust that because some 

22 contractors claim it's having a negative effect on the 

23 retrofit market because of all the advanced controls 

24 and dimming ballasts required. So that's still yet to 

25 be played out. There's some proposed solutions to 
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1 that that actually just came out fairly recently.

2 MR. BROOKMAN: John Cymbalsky.

3 MR. CYMBALSKY: Yeah. John Cymbalsky, DOE. 

4 Can you define what you mean by negative effect?

5 MR. HOWLEY: Well, some of the comments, and 

6 I don't have direct knowledge of this, but I'm just 

7 relaying some of the comments I read -- oh, maybe Alex 

8 can talk about some comments.

9 MR. BOESENBURG: Alex Boesenburg, NEMA. I 

10 read through the entire docket for that trying to find 

11 a set of comments that were never logged that I 

12 needed. But the issue is that the current code 

13 requires that when light fixtures are replaced en 

14 masse, i.e., retrofitters going in with energy savings 

15 upgrades, that they include lighting controls as part 

16 of the requirement, which is also current code 

17 language. It just used to be they didn't have to 

18 install controls. They could just do lamp and ballast 

19 replacement. Some folks argued at the time that that 

20 would impact their small, family business type stuff. 

21 Then it became a political issue. A few of those 

22 companies did go out of business.

23 And now the current code proposal is to 

24 relax that with a mixture of either controls 

25 requirements or that the luminaires that go in must be 
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1 X percent, you know, double digit percentages more 

2 efficient than what came out. And as Joe Howley 

3 noted, that's still being played out.

4 For what it's worth, NEMA supported controls 

5 requirements, I mean, you know, promote controls sales 

6 and agreed with the code as it was changed years ago. 

7 And there were just as many comments in favor of 

8 continuing controls requirements from contractors who 

9 had invested in their expertise through training 

10 programs and the like to understand how to do controls 

11 well and economically. And so there's, if you will, a 

12 competing mind set and business model in retrofitters 

13 in California and it's playing out both in the CEC and 

14 politically.

15 MR. BROOKMAN: Alex, when was that code 

16 changed?

17 MR. BOESENBURG: That was the 2013 code. It 

18 became effective mid last year. July last year. So 

19 in the spring hearings there was a lot of pulling of 

20 hair and gnashing of teeth over the subject and so 

21 there was a postponement of changes and it's still 

22 playing itself out.

23 MR. BROOKMAN: Pekka?

24 MR. HAKKARAINEN: Pekka Hakkarainen, Lutron. 

25 A couple of points. The 15-day language is now out 
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1 for Title 24 and it seems that the retrofit 

2 requirements have been relaxed in California, so not 

3 clear what impact that is going to have to the 

4 adoption of dimming ballasts in retrofit applications. 

5 We'll have to see.

6 I also question whether DOE can take credit 

7 for energy savings resulting from a federal dimming 

8 ballast standard since California already has a

9 Title 20 dimming ballast standard, so I'm suggesting 

10 that DOE should only include energy saving projections 

11 from the rest of the country and not in California.

12 MR. BROOKMAN: Okay. Yes? And please say 

13 your name.

14 MR. TSAN: This is Bach Tsan from Southern 

15 California Edison. Just to clarify, the CEC has a 

16 hearing on August 12 about the lighting alterations, 

17 so the 15-day language is out, but the hearing's on 

18 August 12.

19 MR. BROOKMAN: Okay. Thanks for that. 

20 Yeah. Okay.

21 MR. BOESENBURG: Alex Boesenburg. Just a 

22 administrative note. As an assistance to someone 

23 who's not painfully familiar with these proceedings, 

24 you're looking for changes to Section 141.0 of

25 Title 24.
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1 MR. BROOKMAN: Thank you. Okay. That was a 

2 useful conversation. Final comments here before we 

3 move on? John, you're -- no. Okay. Moving on.

4 MS. deBUTTS: We have somebody on the web.

5 MR. BROOKMAN: Oh, yeah. Pardon me. Chris 

6 Holstein. Chris, this note's been sitting here in 

7 front of me for at least five minutes. I apologize. 

8 Chris, you should now be unmuted.

9 MR. HOLSTEIN: Yes, I'm unmuted. Can you 

10 hear me?

11 MR. BROOKMAN: Yes. You sound good.

12 MR. HOLSTEIN: Great. Since I am on the 

13 webinar it's a little difficult to get in and out. So 

14 Chris Holstein with Universal Lighting. If I could go 

15 through a few topics before you go on, if you would be 

16 patient with that, and then I'll be quiet.

17 MR. BROOKMAN: Well, Chris, will they cover 

18 the entire span of this content?

19 MR. HOLSTEIN: Well, 3.1, just Issue 3.1. I 

20 believe 3.1 talks about the dimming in particular.

21 MR. BROOKMAN: Okay. Sounds good. Yeah.

22 MR. HOLSTEIN: But then you also had some 

23 conversation about California that I'd like to speak 

24 about as well. But just on the dimming aspect, it was 

25 noted in your document that in the research in the 
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1 general service fluorescent lamp rule that I believe 

2 you said 8 percent, I think is what's in the document, 

3 of the lamps were using a dimming application.

4 I just want to caution you in that regard 

5 the industry may determine that a dimming application 

6 may not necessarily be something that is being 

7 operated by a dimming ballast. So, for instance, a 

8 lot of occupancy sensors and vacancy sensors are 

9 considered a controlled scenario and that is only run 

10 on a standard program start ballast, which is already 

11 covered by the current rulemaking.

12 If you look at the sales numbers, and I'm 

13 not going to speak of ours particularly on this phone 

14 call, you will see that the actual dimming market is 

15 rather small in comparison to the rest of the market. 

16 So specifically to California, there are regulations 

17 there that push new construction to a set dim 

18 scenario, but that is not the case across the rest of 

19 the United States. Even though California is rather 

20 large, it's still a very small portion of the total 

21 available market.

22 And then, in reference to the retrofit 

23 market in California, it did significantly decline 

24 with the inclusion of the control scenario. A number 

25 of retrofitters and contractors went out of business 
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1 because of the increased cost of the controls.

2 And then there's a loophole in the standard, 

3 in the current Title 24 from what they consider a 

4 modification in place where there is no -- you do not 

5 trigger the code if you just replace the lamps in 

6 California, so a lot of retrofitters have gone to 

7 strictly replacing the fluorescent lamps with a linear 

8 LED lamp so they don't trigger the code. So that 

9 retrofit market in California is significantly 

10 different from what you may have imagined the last 

11 time you all did an analysis for the prior ruling.

12 MR. BROOKMAN: Okay. Thank you, Chris.

13 Final comments right here before we move on? 

14 Yes, Chris?

15 MR. GRANDA: Chris Granda, Appliance 

16 Standards Awareness Project. I think what we've been 

17 hearing is that the future holds the distinct 

18 possibility of increasing diversity in terms of types 

19 of products and functionality in this product category 

20 that we're looking at. I think it's worth mentioning, 

21 as everybody's aware, this is all in the context of a 

22 industry-wide shift to solid state lighting as well.

23 And what we're concerned about is a 

24 situation that could result where as the shift to the 

25 new technology paradigm takes place with also higher 
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1 cost drivers and light sources in the solid state 

2 arena that we end up having a long-lived sub-product 

3 category of fluorescent ballasts with enhanced 

4 capability which may or may not get used but also 

5 involves substantial standby losses and other energy 

6 efficiencies more or less built in by the millions.

7 MR. BROOKMAN: Uh-huh.

8 MR. GRANDA: So as we look at the evolution 

9 of this product category and hopefully the transition 

10 away from fluorescent ballasts to solid-state lighting 

11 eventually because we believe that there will be 

12 substantial savings involved with that, that we don't 

13 end up making it the lowest common denominator both in 

14 terms of price and performance.

15 MR. BROOKMAN: Okay. Thank you. Final 

16 comments here?

17 (No response.)

18 MR. BROOKMAN: Okay.

19 MS. deBUTTS: All right. Next DOE plans to 

20 evaluate the justification for excluding from 

21 standards low ballast factor 4-foot T8 medium bi-pin 

22 program start fluorescent lamp ballasts.

23 In 2011 ballast rule, DOE found that some 

24 low ballast factor program start ballasts operate 

25 lamps at current below minimum ANSI standard levels, 
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1 requiring cathode heating to maintain lamp life. DOE 

2 found that none of the program start ballasts tested 

3 during the previous rulemaking were able to meet the 

4 max tech efficiency levels analyzed at the program 

5 start product class. For these reasons, DOE exempted 

6 these low ballast factor program start ballasts from 

7 standards in the previous rulemaking.

8 So we are welcoming comments on DOE's intent 

9 to continue to exclude this ballast from standards and 

10 would like to have any relevant shipment information.

11 MR. BROOKMAN: Yes, Chris?

12 MR. GRANDA: Chris Granda, ASAP. This is 

13 one of the exemptions that particularly concerns us, 

14 is the possibility for a loophole going forward for 

15 one of these potentially low-cost, durable market 

16 niches for inefficient equipment. And we're very 

17 interested to see what kind of market data might be 

18 available and how the changes in sales of these 

19 products happen over time.

20 MR. BROOKMAN: Okay. Thank you. It's good 

21 to note.

22 Joe? Joe Howley.

23 MR. HOWLEY: It's something that industry 

24 has to look at a little more carefully. Joe Howley, 

25 GE. We've supported this exemption in the past and 
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1 perhaps we'll continue to do so. We need to have a 

2 little more analysis on this at this point.

3 MR. BROOKMAN: Okay. Thanks, Joe.

4 Daniel?

5 MR. YOUNG: Daniel Young, California IOUs. 

6 Just a comment here I think on the technological issue 

7 of the cathode heating. It's something that dimming 

8 ballasts have to work with as well, so just a comment 

9 that there may be some opportunity to work with data 

10 that we get from the dimming ballast side if, you 

11 know, if DOE does end up going down that route and 

12 using that perhaps to do something about these as 

13 well.

14 MR. BROOKMAN: Okay.

15 MS. deBUTTS: Thank you.

16 MR. BROOKMAN: Thank you.

17 MS. deBUTTS: Okay. So next DOE is also 

18 considering evaluating energy conservation standards 

19 for ballasts that operate at 480 volts. Currently, 

20 only ballasts with input voltage at or between 120 and 

21 277 volts are required to comply with standards. This 

22 480 volt ballasts, including 4-foot medium bi-pin T8 

23 and 4-foot standard output and high output T5, are 

24 used primarily in the industrial sector.

25 So, with that, DOE welcomes comments on our 
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1 proposal to set standard, analyze standards for the 

2 ballasts that operate at 480 volts.

3 MR. BROOKMAN: Yes, Chris?

4 MR. GRANDA: Chris Granda, ASAP. I actually 

5 have a question about this. Is a 480 volt ballast 

6 essentially a product for new construction in industry 

7 at this point requiring specialized wiring I assume?

8 MR. BROOKMAN: Ernesto, please.

9 MR. E. MENDOZA: I just comment to your 

10 question. This is required both in new construction 

11 and also for replacement on all factories. But I 

12 don't know, and I don't know it's a valid question, 

13 out of the total energy market, the 480 volt, how big 

14 it is. I don't know if we're speaking here something 

15 that is really small. 480 volts typically is 

16 industrial where we have very big machines and other 

17 things and lighting is not even a notch in what 

18 matters. So I don't know.

19 MR. BROOKMAN: But you would confirm it's 

20 largely an industrial application?

21 MR. E. MENDOZA: Yeah.

22 MR. BROOKMAN: Yeah. Okay. Chris Holstein 

23 has another comment. Chris, please.

24 MR. HOLSTEIN: Yeah. Sorry. Could we go 

25 back to the 140 milliamp exclusion really quickly? I 
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1 just wanted to address a comment that was made that 

2 that is possibly a low cost, down and dirty loophole, 

3 and I want to assure you that it's not.

4 So, if you have to operate at the low 

5 ballast factor level, there's a number of things you 

6 have to do from a technology perspective with the 

7 ballast to allow it to work. So it includes higher 

8 OCV, open current voltage. You have to add flicker 

9 control as well as cathodes. I mean, all of these 

10 things add cost to the product.

11 The market's fairly small and any increase 

12 in the efficiency that you would try to gain would 

13 offset any energy savings you receive from that 

14 ballast light composition. And with current resources 

15 mostly devoted to solid-state lighting, if you 

16 increase the efficiency rating of those products, most 

17 likely you'll have to compete those through the 

18 market.

19 MR. BROOKMAN: Okay. Chris, if you could 

20 provide that as a written comment in detail, I think 

21 that would be helpful.

22 MR. HOLSTEIN: I do have a written comment, 

23 but I have another comment while I'm on the phone for 

24 the current conversation --

25 MR. BROOKMAN: Why go ahead. Please. Yeah. 
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1 Go.

2 MR. HOLSTEIN: -- on the 480 volt.

3 MR. BROOKMAN: Uh-huh.

4 MR. HOLSTEIN: The 480 volt market, once 

5 again, that's another small market. That product as 

6 well has added circuits within it to allow it to work 

7 in that environment. That environment is typically 

8 like a heavy industrial market and it has what we call 

9 dirty power, which is highly transient. There's a lot 

10 of other things that you can do to a line that cause 

11 this product to just be destroyed if they don't have 

12 the extra circuitry in order to be able to accommodate 

13 that. You're talking about a heavy industrial market 

14 that is small, that has added functionality within the 

15 product to allow it to work in those environments and 

16 which with this is not as good. They need to look at 

17 further the increase in efficiencies.

18 And once again, this is Chris with Universal 

19 Lighting. We would say that the exclusion to stay on 

20 the 140 milliamp and below low ballast factor would 

21 not promote any efficiency movement on the 480 volt 

22 market.

23 MR. BROOKMAN: Okay. Some of that was kind 

24 of breaking up just a tad, but if you would include 

25 those in your written comments, that would be helpful.
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1 MR. HOLSTEIN: I will.

2 MR. BROOKMAN: Thank you. Additional 

3 comments here on this subject? Joe Howley?

4 MR. HOWLEY: Yeah. Just we would support 

5 Chris's comments that these are both very small market 

6 segments that probably would not generate a lot of 

7 energy savings and Chris's other point that the 

8 industry is really working on solid-state lighting 

9 today. And given the nature of these products being 

10 such, so small and such a niche product, we would not 

11 want to expend any time and effort redesigning these 

12 types of products for higher efficiency levels.

13 MR. BROOKMAN: Al Mendoza.

14 MR. A. MENDOZA: Al Mendoza with Southern 

15 California Edison. Just wanted to make a general 

16 comment in reference to NEMA's earlier comments about 

17 how there is a belief that solid-state technology 

18 might replace fluorescent ballast technology.

19 In California, there is at the moment a high 

20 demand for LED tubes, but interestingly, customers 

21 want to use LED tubes with existing ballasts, so with 

22 both non-dim and dimming ballasts. And so that might 

23 -- we should give some consideration as to how this 

24 might actually extend, you know, the usability of 

25 ballasts into the future. And so, with LED tubes 
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1 being very good at dimming, then we should look at the 

2 possibility of the dimming even below 50 percent.

3 MR. BROOKMAN: Okay. Joe Howley.

4 MR. HOWLEY: So Joe Howley. You know, we 

5 view that as a short-term situation in the market 

6 right now. It depends how you define short-term. But 

7 right now there's a lot of existing fixtures out there 

8 that are designed for fluorescent. They're not 

9 designed for LED, but LED systems are in the short 

10 term being designed to try to operate on the 

11 fluorescent systems. But long term we would expect 

12 these systems to switch over to dedicated LED systems. 

13 So what you're seeing I think is a short-term 

14 phenomena that will exist for I'm not sure how many 

15 more years as the market transitions to LED.

16 MR. BROOKMAN: In the commercial sector you 

17 presume there's this change-out of lighting systems 

18 every 10, 15 years? Yeah? Okay.

19 MR. HOWLEY: Exactly. So the next cycle 

20 will be new LED fixtures, dedicated LED fixtures. In 

21 the meantime, though, you'll have this kind of short22 term retrofitting going on.

23 MR. BROOKMAN: Okay. Yes? Al, please.

24 MR. A. MENDOZA: Yeah. You're probably 

25 right about that, but also what we're seeing is that 
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1 customers, you know, they're looking for an 

2 inexpensive solution. So a lot of customers don't 

3 want to spend the money in replacing the entire 

4 system, so they will first look at alternatives, which 

5 first, you know, we'll look at replacing just the 

6 lamps.

7 MR. BROOKMAN: Yeah. Okay. Thank you. 

8 Yes? Charlie Stephens?

9 MR. STEPHENS: Charlie Stephens. I think we 

10 can -- we're probably going to have some data that we 

11 can share before the rulemaking is over, but there's a 

12 lesson I think here in the fact that more than 10 

13 percent of the lamp sales out there are T12 lamps, and 

14 most of those products are magnetically ballasted 

15 today. And, you know, some of these things hang 

16 around for quite a while. Ten or 11 percent of the 

17 lamps out there is not an insignificant number, so I 

18 think we can count on these things being there for 

19 actually quite a very long time. I don't see the 

20 economy supporting a lot of expensive retrofits 

21 anytime soon.

22 MR. BROOKMAN: Charlie, are magnetic 

23 ballasts available in the market?

24 MR. STEPHENS: A ballast lasts a long time, 

25 you know, longer than the lamps typically. So, you 
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1 know, you can change the lamps several times with one 

2 ballast, unless it's in an environment that it taxes 

3 the whole system. But, you know, we're seeing a lot 

4 of them still out there.

5 MR. BROOKMAN: Okay.

6 MR. STEPHENS: I see them where I go every 

7 week.

8 MR. BROOKMAN: Okay. So final comments here 

9 to Joe Howley.

10 MR. HOWLEY: Just, yeah, I think we estimate 

11 electromagnetic ballasts in a typical operating 

12 application probably has a 20-year life. So 20 years 

13 ago when they were installed, you know, some of them, 

14 the old ones are still operating, and some of them 

15 operate in cooler environments, so they last a little 

16 bit longer than the normal, but you're just seeing the 

17 trailing edge of those systems. They will eventually 

18 die, but you're at the very end of them.

19 MR. BROOKMAN: Pekka?

20 MR. HAKKARAINEN: Interesting discussion, 

21 but it doesn't change the fact that industry data 

22 shows that fluorescent lamp shipments are declining at 

23 an accelerating rate and DOE's regulations can only 

24 affect shipments.

25 MR. BROOKMAN: Okay. Thank you. Final 
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1 comments here? We're about to move on.

2 (No response.)

3 MR. BROOKMAN: Okay.

4 MS. deBUTTS: Well, since we started talking 

5 about magnetic ballasts, so as we remember, the 

6 electronic ballast technology was needed to meet the 

7 standards for the 2011 final rule. However, DOE 

8 exempted ballasts for EMI-sensitive environments 

9 because EMI could pose a safety concern, and that was 

10 best mitigated by the magnetic ballast technology.

11 These safety concerns still exist, and 

12 therefore, DOE plans to continue excluding these 

13 magnetic T8 fluorescent lamp ballasts from 

14 consideration for standards in this rulemaking. We 

15 would like to know what you guys think about that.

16 MR. BROOKMAN: Chris?

17 MR. GRANDA: Chris Granda, ASAP. To the 

18 extent that there continues to be concern about 

19 electromagnetic interference from any technology, the 

20 exclusion seems to make sense. I think our concern 

21 is, one, how broadly EMI-sensitive environments are 

22 defined; first of all, where the administrative 

23 authority to do that lies and whether the FCC has 

24 regulatory jurisdiction there; and then finally, also 

25 just the method of sales and shipments to try and 
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1 restrict leakage of EMI-labeled product into other 

2 applications.

3 MS. deBUTTS: Okay. Thank you.

4 MR. BROOKMAN: Joe Howley.

5 MR. HOWLEY: Joe Howley. Just industry 

6 would still strongly support this exemption. It's 

7 very low volume sales, very niche, but where you need 

8 it. You know, this is the best solution for those 

9 particular kinds of problems, but it is not a large 

10 product sales category at all. It's very small. 

11 Thank you.

12 MR. BROOKMAN: Okay. Chris, you want to 

13 follow on?

14 MR. GRANDA: Well, I just want, I want to 

15 say that this is exactly the kind of situation that 

16 we're concerned about, where a product that is 

17 currently very low sales balloons into something much 

18 larger to fill a demand for a low cost, primarily 

19 retrofit product.

20 MR. BROOKMAN: Okay. Ernesto?

21 MR. E. MENDOZA: Two comments to address 

22 Chris comments. One, for purposes of electromagnetic 

23 sensitive areas, those are very specific customers, 

24 nuclear power plants and military bases. They make 

25 very clear the statement in their request that they 
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1 have EMI sensitivity that need to be addressed.

2 And surprising as it is, because all the 

3 changes with LED and the cost of electronics, now 

4 magnetics is not anymore a cheap solution. It tends

5 to be more expensive as the production has been 

6 dropping down. It is becoming actually a premium 

7 product. So I think the concern that will be taking 

8 over the electronic ballast or LED, it will just not 

9 happen because price.

10 MR. BROOKMAN: Yes, Chris?

11 MR. GRANDA: Chris Granda, ASAP. If I may, 

12 a follow-up question. My understanding was that the 

13 characteristic of the ballasts that made it low EMI 

14 was the frequency, so are you saying that there are 

15 solid-state low frequency ballasts that are developed 

16 to satisfy this market niche?

17 MR. E. MENDOZA: No, not today. I don't 

18 know if there will be in the future. Most of the LED 

19 drivers today are accommodated power supplies anyway, 

20 so for all of these markets the best solution today 

21 remains to be magnetic ballast. Future may change, 

22 you know, but as today, that's the preferred solution.

23 MR. BROOKMAN: Additional comments?

24 (No response.)

25 MR. BROOKMAN: Okay.
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1 MS. deBUTTS: And the last issue on the 

2 scope of coverage. We would like to welcome comments 

3 on additional fluorescent lamp ballasts that we may 

4 not have discussed here and, you know, market 

5 information or shipment information that you can 

6 provide that would contribute to the rulemaking. That 

7 would be more than welcome.

8 MR. BROOKMAN: So this would be the catch9 all category. Any other information that you think at 

10 this point would be useful for the Department, let's 

11 hear about that now.

12 MR. HOLSTEIN: This is Chris Holstein on the 

13 phone from Universal Lighting Technologies.

14 MR. BROOKMAN: Yes, Chris?

15 MR. HOLSTEIN: I just wanted to state that 

16 from our perspective, I mean, 100 percent of our 

17 effort is on solid-state lighting. After the last DOE 

18 ruling on linear fluorescent lamp ballasts that was 

19 just effective in November, that pretty much has 

20 whittled the market down to where everybody is the 

21 same. The efficiency levels were compressed so much 

22 that there's really no differentiation. So at this 

23 point everybody's going to use solid-state lighting 

24 from a manufacturer's perspective, as well as the 

25 customer's, so I don't see any reason to look for any 
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1 other products in this particular category. Nothing 

2 to me since the last ruling that we spent the last two 

3 years trying to get our products in line with have 

4 measured that.

5 MR. BROOKMAN: Okay. Okay. Thank you. 

6 Other comments?

7 (No response.)

8 MR. BROOKMAN: Nothing additional.

9 MS. deBUTTS: All right. Next is going to 

10 be Rachel Dickenson presenting market and technology 

11 assessment and screening analysis.

12 MS. DICKENSON: Okay. Hello. My name is 

13 Rachel Dickenson. I'm with Navigant. And we will 

14 discuss the market and technology assessment and 

15 screening analysis.

16 So one of the main elements of the market 

17 and technology assessment is establishing product 

18 classes. DOE divides covered products into classes by 

19 the type of energy used, the capacity of the product, 

20 or any other performance related features that require 

21 different standard levels, such as features affecting 

22 consumer utility. DOE then establishes separate 

23 energy conservation standards for each product class.

24 DOE is considering maintaining the product 

25 classes for ballasts currently subject to standards. 
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1 This table shows the current product classes for 

2 fluorescent lamp ballasts. The product classes are 

3 currently divided based on starting method, lumen 

4 package, sign ballast, and residential versus 

5 commercial. Additional product classes may be needed 

6 if DOE considers standards for additional categories 

7 of ballasts. For example, as discussed, DOE is 

8 considering analyzing standards for additional dimming 

9 fluorescent lamp ballasts given their market growth.

10 If standards are considered for these 

11 additional dimming ballasts, DOE may consider 

12 establishing separate product classes for them with 

13 such factors as residential versus commercial lamp 

14 type operated by the ballast; method of dimming, such 

15 as continuous dimming, step dimming, zero to 10 volt 

16 dimming control; or standardized control interfaces, 

17 such as the digitally addressable lighting interface.

18 So DOE has three requests for comment on the 

19 fluorescent lamp ballast product classes. First, DOE 

20 welcomes comment on the product class divisions it is 

21 considering for fluorescent lamp ballasts. In 

22 particular, DOE welcomes comment on appropriate class23 setting factors for the dimming ballasts, the low 

24 ballast factor program start ballast, and the 480 volt 

25 fluorescent lamp ballasts.
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1 MR. BROOKMAN: Let's deal with that one 

2 first and see if we have any comments there.

3 Daniel?

4 MR. YOUNG: Daniel Young, California IOUs.

5 So just to comment on how California dealt with the 

6 dimming ballasts. So essentially we set one single 

7 product class for all dimming ballasts and defined a 

8 standard based as a function of measured lamp arc 

9 power. You know, we think that might be appropriate 

10 here, but we would also encourage DOE to look at other 

11 factors that might allow for more stringent standards 

12 for certain products.

13 So, for instance, we tested some T5 ballasts 

14 and found that generally they seemed to be a little 

15 bit more efficient than the T8 ballasts, so that might 

16 be an opportunity. And also whether or not it's a 

17 digitally controlled ballast. We didn't see anything 

18 in our data, but, you know, again, we were somewhat 

19 limited by just time in getting the data together and 

20 the number of ballasts we could test, but with DOE's 

21 resources we would hope that you guys can look at that 

22 a little bit closer and perhaps find an opportunity 

23 there as well.

24 MR. BROOKMAN: So the question here that you 

25 see for two class setting factors, low ballast and 480 
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1 volt fluorescent. Comments there? Any additional 

2 comments? Pekka?

3 MR. HAKKARAINEN: Pekka Hakkarainen, Lutron. 

4 Just a small comment that DALI is specifically 

5 mentioned here as a digital protocol. It's not 

6 necessarily the only protocol that's implemented in 

7 these ballasts that require some standby power 

8 consumption, so I just wanted to make that point.

9 MR. BROOKMAN: Thank you. Okay. Yes? 

10 Alex?

11 MR. BOESENBURG: Alex Boesenburg, NEMA. 

12 I'll follow on to Pekka's comment. I've been trying 

13 to gather data on this and it's proven challenging, 

14 but I want to suggest that DOE, if they are going to 

15 dive into the power requirements of networked products 

16 I'll just call it, a catch-all term, some of these 

17 protocols are, you know, open such that, by which I 

18 mean based on the commissioning or the specific 

19 functionality built into that particular design, they 

20 can have varying standby and full mode power 

21 consumptions. DALI, you can have a DALI product that 

22 has very low standby because it's been told to be 

23 doing a very small task. You can have a DALI product 

24 that uses a lot of power. And we're struggling with 

25 coming up with one number to fit because it can be 
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1 situation dependent or set by the consumer and made to 

2 order. And I don't have the answer today, but I want 

3 to throw that out there for consideration.

4 MR. BROOKMAN: Thank you. Charlie Stephens?

5 MR. STEPHENS: Charlie Stephens. I think I 

6 can second Alex's comments there. Our involvement in 

7 luminaire level lighting control has kind of taught us 

8 the same thing, which is why I asked the question 

9 earlier of DOE about their intentions to look at 

10 network standby, because if you decide to regulate 

11 dimming ballasts, I don't know how you can possibly 

12 avoid that.

13 MS. deBUTTS: Thank you for your comments. 

14 This is Lucy deButts. We'll definitely take a look 

15 into it. We heard you before, but, again, you know, 

16 not at this time, not in this rulemaking. Maybe a 

17 little later.

18 MR. BROOKMAN: Let's move on to the other 

19 issue boxes, Rachel.

20 MS. DICKENSON: Okay. Next DOE welcomes 

21 comment on any other class-setting factors that should 

22 be considered in the analysis.

23 MR. GRANDA: Yes. Chris Granda, ASAP. I 

24 guess a question and a comment. The initial division 

25 between commercial and residential classes as I 
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1 understand was driven by the lower number of hours of 

2 use for residential. Was it correct that that 

3 division was driven by a lower number of hours of use 

4 and the incremental cost that was involved with 

5 achieving a higher BLE versus that lower number of 

6 hours of use? I'm looking historically now.

7 MR. WALKER: Yeah. This is Matthew Walker 

8 from Navigant. In the previous rule it was really the 

9 difference in efficiency that drove the difference. 

10 The efficiency of the two products was different and 

11 they were used for different purposes. They had a 

12 different utility. A residential ballast meets 

13 different FCC EMI requirements, for example.

14 MR. GRANDA: Okay. I guess we would 

15 encourage DOE to look at the sort of underlying 

16 rationale for having a different classification for 

17 residential ballasts, and given current price trends 

18 and availability of technology and the functionality 

19 of the product, as Matthew mentioned, to see whether 

20 having a lower efficiency standard for the residential 

21 products is still justified.

22 MR. BROOKMAN: Okay. Charlie Stephens?

23 MR. STEPHENS: Yeah. Charlie Stephens from 

24 NEEA. I would second that as an owner of a house 

25 that's full of commercial ballasts and that work quite 
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1 well and have no obvious impact on anything in the 

2 house. I was willing to pay the extra cost. Yes, the 

3 residential ones are cheaper, but I don't see any 

4 material difference in application in a building 

5 between these two things quite frankly.

6 MR. BROOKMAN: Yes. I saw Ernesto first.

7 MR. E. MENDOZA: Just to mention residential 

8 ballasts are subject to a different FCC rule, is more 

9 stringent, and some customers are very sensitive. 

10 They may have radios at home, maybe radio stations 

11 now. They may have different sensitive equipment that 

12 require this extra protection. So unfortunately we 

13 have to build our products for the two different 

14 markets. We will be happy if the only rule were the 

15 commercial one, but FCC requires to have these two, so 

16 as of today we have to produce the second product. 

17 Even though most customers may be satisfied with the 

18 commercial product, we have to do the residential and 

19 include additional filtering for EMI purposes.

20 MR. BROOKMAN: Pekka?

21 MR. HAKKARAINEN: Pekka Hakkarainen, Lutron. 

22 Ernesto Mendoza made my point. I have nothing to add.

23 MR. BROOKMAN: That's some discipline for 

24 you. Alex?

25 MR. BOESENBURG: Alex Boesenburg, NEMA. I 
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1 would add to what Ernesto said, expand on it. In 

2 terms of as this rulemaking proceeds and we get into 

3 other regulatory impacts, NEMA and our compatriots to 

4 the north, Electrofed Canada, have been in discussions 

5 with FCC and Industry Canada for the past 18 months 

6 regarding revisions to emissions requirements for 

7 lighting products in North America. It's not a quick 

8 conversation, but we expect to enter into binational 

9 negotiations and study into what is the appropriate 

10 emissions limit. It's mostly about factoring in 

11 solid-state lighting appropriately, but Industry 

12 Canada for one want to revise all of the lighting 

13 requirements or at least relook, and so we've been 

14 working hard to make sure that it's done in a 

15 binational atmosphere.

16 That will take a few years, but if this 

17 rulemaking takes a few years, one of the updates I'll 

18 be bringing to the milestone events of DOE's rule is 

19 what we know about or what we expect to happen in 

20 terms of North American emissions requirements. And 

21 as Ernesto -- my tie-in to Ernesto's statement is if 

22 emissions requirements become more stringent across 

23 the board, that added functionality and filtering will 

24 cause impacts on price and also impacts on efficiency. 

25 But we can't tell you where it's going yet today.
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1 MR. BROOKMAN: Okay. Let's queue market 

2 assessment.

3 MS. DICKENSON: Okay. Now for this catch4 all comment request, DOE welcomes information on the 

5 shipments, product feature and efficiency trends, 

6 distribution channels, and estimates of market shares 

7 for ballasts considered in this rulemaking.

8 MR. BROOKMAN: Daniel?

9 MR. YOUNG: Daniel Young, California IOUs. 

10 Again, a comment on dimming ballast efficiency trends. 

11 So I think maybe this goes without saying at this 

12 point, but we definitely found that the ballasts don't 

13 all perform the same when they're dimmed. So, in 

14 other words, you know, you could have two products 

15 that are similarly efficient at 100 percent, but when 

16 you test them down at 50 percent or below, they're no 

17 longer the same. Or I should say 50 percent or 

18 anywhere in between 50 percent and 100 percent. They 

19 can be off by a pretty significant margin, up to we've 

20 found anywhere from three to five watts per lamp. And 

21 so just to highlight the need to evaluate their 

22 efficiency throughout the dimming range and not just 

23 at 100 percent, which again would require a separate 

24 test procedure or an amended test procedure.

25 MR. BROOKMAN: Okay. Thanks. Yes? 
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1 Rebecca?

2 MS. RAINER: Yes. Rebecca Rainer, Eaton. I 

3 would not want to go into details on shipments or 

4 product features or distribution channels in this 

5 meeting, but I would welcome a manufacturer's 

6 interview at any of our facilities in the States.

7 MR. BROOKMAN: Thank you. And, yes, Alex, 

8 as a natural follow-on, please.

9 MR. BOESENBURG: Alex Boesenburg, NEMA. I 

10 alluded to NEMA shipments information in my opening 

11 remarks, and I do have an indexed graph if that's the 

12 right way to phrase it that we will submit with our 

13 written comments, and I've made about six notes just 

14 so far to go back and whip my statisticians with. 

15 We'll provide as much as we can.

16 MR. BROOKMAN: Okay. Thank you. Ernesto?

17 MR. E. MENDOZA: Just seconding my 

18 colleagues, just to make it very dramatic. We used to 

19 run five ballast factories. Now we run only one.

20 MR. BROOKMAN: Thank you. Rebecca?

21 MS. RAINER: Just to add to my comment and 

22 clarify something. My company does not manufacture 

23 ballasts. We are a luminaire manufacturer that 

24 actually uses these components.

25 MR. BROOKMAN: Yeah. Thanks.
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1 MR. HOLSTEIN: Yes. This is Chris Holstein 

2 on the line with Universal Lighting Technologies. 

3 Just to echo some of the manufacturers' views as well 

4 from the manufacturer interviews that we've done in 

5 the past, and I will include some shipment information 

6 with my written comments as well. But to kind of 

7 follow Ernesto's lead, we at one point had four 

8 ballast factories, and today we operate one.

9 MR. BROOKMAN: Okay. Thank you.

10 This is a catch-all category. You can see 

11 what's listed there. Shipments, product feature, 

12 efficiency trends, distribution channels, estimates of 

13 market share. NEMA's going to come forward with data. 

14 Any additional final comments before we move on?

15 (No response.)

16 MR. BROOKMAN: Okay.

17 MS. DICKENSON: So now we'll move on to 

18 discussing the technology options that improve the 

19 energy efficiency of the product. So, in this 

20 instance, options that improve the ballast luminous 

21 efficiency or BLE. The table on this and the 

22 following slide provides the preliminary list of 

23 technology options DOE has identified.

24 For example, on this slide, an improved 

25 circuit design, one technology option is to substitute 
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1 discrete components with an integrated circuit.

2 And on this slide for using improved 

3 components, one technology option is using diodes with 

4 lower losses.

5 It should be noted that DOE is aware that 

6 moving from magnetic ballasts to electronic ballasts 

7 or changing the starting method from rapid start to 

8 instant start improves the BLE, but DOE does not 

9 expect these changes to continue to be viable 

10 technology options for this rulemaking given that due 

11 to market trends and DOE energy conservation standards 

12 the magnetic ballasts and rapid start ballasts are no 

13 longer sold for the categories of ballasts under 

14 consideration for standards.

15 So, in Issue 4.4, DOE welcomes comment on 

16 the preliminary technology options identified in this 

17 section and DOE welcomes comment on whether there are 

18 additional technology options that it should consider.

19 MR. BROOKMAN: Daniel?

20 MR. YOUNG: Daniel Young, California IOUs.

21 So, again for dimming ballasts we found that cathode 

22 cutout and I guess better performing cathode cutout 

23 made a big difference on ballast efficiency, and so 

24 you'll see that in the data in the reports that we 

25 docket, but just stating that for the record.
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1 MR. BROOKMAN: Thank you. Ernesto?

2 MR. E. MENDOZA: I think most of these 

3 comments in the document are well known by the 

4 industry. I can tell you I wrote my first paper on 

5 cathode cutout in 1985. So we know these things. We 

6 know about using cool transistors and lower impedance 

7 values and capacitors.

8 I honestly believe that the fluorescent 

9 ballast technology supplies maximum today. To go to a 

10 higher level of technology we need to reinvest in 

11 completely different technology, and I think the 

12 industry is invested in doing better LED lighting as 

13 opposed to trying to redefine the use for fluorescent. 

14 I think we will be wasting time and money because the 

15 treatment of fluorescent lamps and therefore ballasts 

16 is still decaying very fast.

17 MR. BROOKMAN: Okay. Alex?

18 MR. BOESENBURG: Alex Boesenburg, NEMA. I 

19 would follow on to Mr. Young's comments about cathode 

20 cutout. As we commented to the California rulemaking 

21 proceedings and will comment to the DOE proceeding, 

22 cathode cutout is an intellectual property heavy area, 

23 and one manufacturer took out a patent regarding their 

24 treatment of cathode cutout, so someone else wanting 

25 to also sell dimming ballasts or a ballast that 
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1 employs cathode cutout came up with a different way to 

2 do it, patented it, and so everybody's got one. And 

3 it's a very interwoven kind of situation, and the DOE 

4 must exercise caution favoring one over another 

5 inadvertently, and that's where the DOE's analysis 

6 will want to be focused and carefully consider all 

7 that.

8 Another point made in California and I'll 

9 refer the DOE to is that filament heat sometimes is 

10 done very conservatively on purpose to help prolong 

11 lamp life, particularly in the field when you see 

12 combinations between different manufacturers' 

13 products. The manufacturer of the fluorescent lamps 

14 differ from the manufacturer of the ballast. So some 

15 ballast manufacturers who are targeting, who don't 

16 make a lamp, so don't want their product to work with 

17 everybody's, try to make a very robust product that 

18 doesn't inadvertently kill off lamps, for instance. 

19 So the success in the field can come at a cost of 

20 additional performance features such as that, so to 

21 focus strictly on efficiency you lose sight of things 

22 like that.

23 MR. BROOKMAN: Yes, Daniel?

24 MR. YOUNG: Daniel Young, California IOUs. 

25 Just to briefly respond to that, I think, Alex, you're 
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1 talking about the LL-9 document that kind of defines 

2 the band of "acceptable" cathode heating for lamps and 

3 ballasts to work well together.

4 So we looked at that standard and made some 

5 concerted assumptions and we came up with a band of 

6 about 5.6 watts per lamp of kind of allowable cathode 

7 heating between what you should be using and what you 

8 could be using I guess. And so we see that as the 

9 full range I guess of achievable efficiency that's 

10 defined within that document, certainly recognizing 

11 that not all manufacturers have access to every piece 

12 of technology that would allow you to get from the 

13 best to the worst or vice versa rather. But 

14 nonetheless there is quite some wiggle room there that 

15 we think that can lead to significant savings.

16 And so just for a little bit of context, 

17 when we developed the California standards, we did 

18 come up with levels that all the major manufacturers 

19 had products that were able to meet, and so we didn't 

20 see that as an issue of we were now cutting out a 

21 significant number of manufacturers to only allow the 

22 one or two that had the right IP to do it.

23 And also just to highlight that the standard 

24 in California rather is not -- there's no prescriptive 

25 requirement for cathode heating. That's just the one 
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1 technology option that we saw as kind of an immediate 

2 opportunity that had a pretty significant impact on 

3 energy use.

4 MR. BROOKMAN: Okay. Ernesto?

5 MR. E. MENDOZA: I wish to echo Alex's input 

6 that we need to watch carefully that we will not be 

7 limiting technologies. We have a ballast that the 

8 patent just expired, and it's a very interesting 

9 gadget because the first thing that it do, the 

10 ballast, is look at the filament impedance of the 

11 specific lamp and then it adjusts the cathode heating 

12 for the specific lamp, its age, manufacturer, and 

13 other factors. But of course to have this 

14 intelligence built in there isn't energy consumption. 

15 So this type of advanced technology will be actually 

16 restricted because it consumes more energy than a 

17 regular dimming ballast. So these are type of 

18 considerations I guess when we go to the classes that 

19 we may consider into.

20 MR. BROOKMAN: Okay. Pekka?

21 MR. HAKKARAINEN: Pekka Hakkarainen, Lutron. 

22 So I would just like to sort of take a step back here 

23 and look at the California building code requirement 

24 for the use of dimming ballasts. That building code 

25 requirement does not currently exist in the rest of 
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1 the country, so if anything is going to drive dimming 

2 ballast sales, it's going to be the California market 

3 and California already has adopted a dimming ballast 

4 standard. So I question the need for having any other 

5 standard, any stricter standard than that considered 

6 because none of us are going to make just California 

7 only dimming ballasts or rather specifically for the 

8 California market and separate products for the rest 

9 of the country. It's just going to be one product in 

10 the overall declining fluorescent market.

11 MR. BROOKMAN: Okay. Okay. Additional 

12 comments here?

13 (No response.)

14 MR. BROOKMAN: Okey doke.

15 MS. DICKENSON: So for the screening 

16 analysis, DOE will screen out technology options based 

17 on four criteria. DOE will look at first the 

18 technological feasibility, that is, whether the 

19 technology is commercially available or in a working 

20 prototype; second, the practicability to manufacture, 

21 install and service, meaning that it's possible to 

22 achieve mass production and reliable installation and 

23 servicing of a technology in commercial products on a 

24 scale necessary to serve the market; three, that it 

25 does not have adverse impacts on utility to consumers 
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1 or availability; and four, that it does not have 

2 adverse impacts on health or safety.

3 Those technology options not screened out by 

4 these four criteria are called design options and are 

5 considered as possible methods of improving efficiency 

6 in the engineering analysis.

7 In the 2011 ballast rule, DOE screened out 

8 using laminated sheets of amorphous steel to create 

9 the core of the inductor as this method results in the 

10 ballast failing to be practical to manufacture, 

11 install, and service and has adverse impacts on 

12 product utility. DOE will consider screening out the 

13 use of laminate sheets of amorphous steel in this 

14 rulemaking, consistent with the screening analysis of 

15 the 2011 ballast rule.

16 And in Issue 5.1, DOE welcomes comment on 

17 the applicability of the four screening criteria to 

18 the technology options described in this section, 

19 including whether it will still be appropriate to 

20 screen out the use of laminated sheets of amorphous 

21 steel.

22 MR. BROOKMAN: And 5.2?

23 MS. DICKENSON: In 5.2, DOE welcomes comment 

24 on how the screening criteria will apply to any 

25 additional technology options.
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1 (Pause.)

2 MR. BROOKMAN: We need a comment on 

3 amorphous steel for sure.

4 (Laughter.)

5 MR. BROOKMAN: Ernesto?

6 MR. E. MENDOZA: Yeah. We play with these 

7 issues with the steel for a long time, both the 

8 magnetic ballast, and it really doesn't make them an 

9 effective work product, so I think we're going to 

10 stick with amorphous for magnetic ballasts.

11 For electronic ballasts, kind of a moot 

12 discussion I guess.

13 MR. BROOKMAN: Okay. Additional comments, 

14 screening factors and applicability to technology 

15 options? Joe? Joe Howley.

16 MR. HOWLEY: Joe Howley. So I think the 

17 bottom line is it's still appropriate to answer the 

18 specific question to screen out amorphous steel for 

19 these products.

20 MR. BROOKMAN: Thanks for the clarity.

21 MR. HOWLEY: Sure.

22 MR. BROOKMAN: Yeah. Okay. Final comments 

23 here on these two?

24 (No response.)

25 MR. BROOKMAN: Let's take a break. We're 
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1 really making good progress here. I really appreciate 

2 the quality of the comment, really excellent. 

3 Everybody's really on their game today. Much 

4 appreciated on a Friday morning.

5 Ten twenty now by the clock on the wall. 

6 Let's take a 15-minute break.

7 (Whereupon, a brief recess was taken.)

8 MR. BROOKMAN: We're going to hear again 

9 from Rachel.

10 MS. DICKENSON: Okay. Now we will discuss 

11 the engineering analysis. And this slide shows step 

12 by step the general methodology DOE plans to use for 

13 the engineering analysis.

14 The first step is to choose the 

15 representative product classes. DOE then selects 

16 baseline ballasts for each representative product 

17 class to use as reference points. And then for each 

18 baseline ballast DOE identifies more efficient 

19 substitutes based on design options determined in the 

20 screening analysis. DOE then develops efficiency 

21 levels that range from the baseline to the maximum 

22 technologically feasible efficiencies. DOE scales 

23 these results to the non-representative product 

24 classes, which are the product classes that were not 

25 directly analyzed. Finally, DOE determines the 
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1 relationship between BLE and end user price. The 

2 results of these analyses are also used downstream for 

3 the life-cycle cost analysis, the national impact 

4 analysis, and the manufacturer impact analysis.

5 And I'll go over each of these steps in a 

6 little more detail. So, as mentioned, DOE will not 

7 analyze every product class. Instead it will choose 

8 representative product classes on which it will focus 

9 its analytical efforts, and these are typically chosen 

10 based on high market volume.

11 The next step is selecting a baseline 

12 ballast for each representative product class. The 

13 baseline ballast is what DOE believes to be the most 

14 common, least efficient ballast within each 

15 representative product class. For products that do 

16 not have existing standards, DOE plans to select the 

17 most common least efficient ballast. For products 

18 that have standards, DOE plans to select the most 

19 common, least efficient ballast that just meets those 

20 standards.

21 So, in Issue 6.1, DOE welcomes comment on 

22 the appropriate baseline for ballasts already subject 

23 to standards.

24 MR. BROOKMAN: Ernesto?

25 MR. E. MENDOZA: Maybe just to say the 
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1 obvious. If there is a rule, it cannot exceed the 

2 ballasts that do not meet the rule, so the baseline 

3 would be of course the minimum that meet the rules. I 

4 think that's correct.

5 MR. BROOKMAN: Okay. It's useful, I think 

6 you know, to confirm what you might think would be 

7 assumed in a record establishing matter like this.

8 Joe Howley?

9 MR. HOWLEY: Yes. Joe Howley. The other 

10 thing maybe as we're stating obvious points is that 

11 the last ballast rulemaking was very aggressive. So 

12 for the ballasts that are regulated right now, they 

13 already are at max tech, and there's nowhere else the 

14 industry can see it taking those. It's a declining 

15 product category now. There's no new investment or 

16 research going on in this category as we work to move 

17 everything to LED technology. So your regulated 

18 product technologies are sort of your minimum and 

19 maximum right now. There's nowhere else to go in that 

20 regulated category right now.

21 MR. BROOKMAN: Anything additional here?

22 (No response.)

23 MR. BROOKMAN: Let's queue the next one.

24 MS. DICKENSON: Okay. So Issue 6.2, should 

25 DOE analyze standards for the new categories of 
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1 ballasts, including the additional dimming, the low 

2 ballast factor program start, or the 480 volt 

3 fluorescent lamp ballast? DOE welcomes comment on the 

4 appropriate baseline ballast types and efficiency 

5 values in those categories.

6 MR. BROOKMAN: Charlie Stephens.

7 MR. STEPHENS: To go with Joe's obvious 

8 comments again.

9 MR. BROOKMAN: You understand what I'm 

10 saying here. It's good to have stuff that you presume 

11 to be obvious in the record. It's important. Keep 

12 going.

13 MR. STEPHENS: Yeah. Obviously, if you're 

14 going to consider looking at dimming ballasts, the 

15 first thing you're going to have to do is decide on 

16 how you're going test them and how you're going to 

17 decide how efficient they are. So I would suggest 

18 that early on you need to make the decision about 

19 whether you're going to have a serious look at dimming 

20 ballasts.

21 MR. BROOKMAN: Okay. Additional comments? 

22 Yes, Daniel.

23 MR. YOUNG: Daniel Young, California IOUs. 

24 And again, stating the obvious, I think the next step 

25 from there if you do decide to take a serious look at 
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1 dimming ballasts is to take a serious look at what 

2 California did on dimming ballasts and consider that 

3 not just for the test procedure but also perhaps as 

4 the baseline product.

5 MR. BROOKMAN: Okay. Good. We're ready to 

6 move on I think.

7 MS. DICKENSON: So DOE will select a higher 

8 efficiency replacement for each baseline ballast by 

9 considering technologies not eliminated in the 

10 screening analysis. DOE plans to consider the lamp 

11 and ballast system to account for total system energy 

12 consumption and system light output. To identify 

13 replacements, DOE plans to utilize a database of 

14 commercially available ballasts and BLE compliance 

15 data in the Compliance Certification Management 

16 System.

17 After identifying the more efficient 

18 substitutes for each baseline ballast, DOE develops 

19 efficiency levels based on three factors: first, the 

20 design options associated with the specific ballast; 

21 second, the ability of the ballast to comply with the 

22 efficiency level of a given product class across 

23 wattages; and three, the maximum technologically 

24 feasible efficiency level or max tech.

25 DOE anticipates developing efficiency levels 
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1 using an equation that relates the total lamp arc 

2 power operated by a ballast to the BLE.

3 So, in Issue 6.3, DOE welcomes comment on 

4 the methodology it is considering to select the higher 

5 efficiency ballast designs.

6 And Issue 6.4, DOE welcomes comment on its 

7 proposed methodology of establishing efficiency 

8 levels, including the form of an equation that relates 

9 the average total lamp arc power to the BLE.

10 And Issue 6.5, DOE welcomes comment on the 

11 use of compliance data when establishing the 

12 efficiency levels.

13 MR. HOLSTEIN: Yeah. This is Chris Holstein 

14 from Universal Lighting Technologies. Just quickly, 

15 in your framework document, this is relevant to Issue 

16 6-3. In your framework document, you spoke about 

17 modeling, and we would like to caution against turning 

18 to models as system efficient. We ran into this issue 

19 in the magnetic HIB ruling as well where the 

20 efficiency levels were modeled into an 

21 unmanufacturable product. So we know from experience 

22 that this does not always equate to something that can 

23 be manufactured at a high quality manufacturing 

24 facility. I just want to caution against that.

25 MR. BROOKMAN: Chris, if you could put those 
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1 comments in writing, particularly the limitations 

2 lessons that came from that earlier modeling 

3 experience, I think that would be useful.

4 Okay. Additional? Yes. Chris?

5 MR. GRANDA: Chris Granda, ASAP. Just a 

6 technical question I guess. With the point that DOE 

7 analyzes lamp and ballast system to account for total 

8 system energy consumption, system light output, is 

9 that with a referenced lamp or with the ballast 

10 manufacturer's specified lamp? Particularly if the 

11 ballast manufacturer is also a lamp manufacturer.

12 MR. WALKER: This is Matthew Walker of 

13 Navigant. I can take that one too. This would just 

14 be based -- this is not based on any one particular 

15 lamp. This would be, I guess you could call it a 

16 reference lamp. You know, if the ballast has a 0.88 

17 ballast factor, then the lamp watts would be changed 

18 accordingly. It really just means that in this 

19 rulemaking we're going to account for the ballast 

20 losses associated with the ballast as well as the 

21 energy that's delivered to the lamp. Of course, the 

22 energy that's delivered to the lamp isn't going to be 

23 changed as a result of this rulemaking. We're just 

24 talking about the way the energy will be accounted 

25 for.
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1 MR. GRANDA: We would encourage the use of 

2 reference lamp.

3 MR. BROOKMAN: Okay. Daniel?

4 MR. YOUNG: Daniel Young, California IOUs. 

5 So, again, for dimming ballasts, we recommend that DOE 

6 take a look at, we'll be docketing the data for all 

7 the testing that we did on dimming ballasts, so just 

8 as a heads up from what's coming. It's 5 tests of 

9 one-lamp T8 ballasts, 15 two-lamp T8 ballasts, 10 

10 three-lamp ballasts; 4 four- lamp ballasts, and seven 

11 T5 ballasts, 15 of which had digital controls. And so 

12 we'll docket the results that we got from there, which 

13 is basically tests from 100 percent full light output 

14 down to the minimum dimming level where the lamp was 

15 still producing light.

16 And as another comment just on our approach, 

17 you know, basically again this is highlighting that we 

18 don't think that all products dim the same way and 

19 that's where we think the opportunity for savings is 

20 or a big part of the opportunity is. And so, when we 

21 first set out to look for data, there was, as folks 

22 have mentioned, none according to the test procedure 

23 that we've created, which tells you kind of 

24 performance below 100 percent which we think is again 

25 important. And so we started with the CEE list of 
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1 ballasts, which has 180 I think dimming ballasts, and 

2 from there is where we picked most of the ballasts in 

3 our test set. But again, we'll be docketing that and 

4 so you'll have that to look at.

5 MR. BROOKMAN: Okay. Thank you.

6 You see the three comment boxes there. 

7 Additional comments related to these boxes?

8 (No response.)

9 MR. BROOKMAN: Nothing additional here? 

10 Alex Boesenburg.

11 MR. BOESENBURG: I'll just make one 

12 observation. The CEE list is also the NEMA premium 

13 qualification list because we were allied with CEE at 

14 that time. I guess we still are, but that program is 

15 transitioning thanks to the previous DOE rule. So, to 

16 put it in context, that was a list of high performance 

17 products from which a few were selected. So we would 

18 encourage DOE to evaluate a more broad range of 

19 product.

20 MR. BROOKMAN: Okay. That's useful. Thank 

21 you. Okay.

22 MS. DICKENSON: All right. DOE will next 

23 develop efficiency levels for the product classes not 

24 directly analyzed by scaling from the levels 

25 determined for the representative product classes. To 
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1 do so, DOE plans to develop scaling factors by 

2 comparing the BLE of ballasts in representative 

3 product classes to the BLE of ballasts in non4 representative product classes.

5 In Issue 6.7, DOE welcomes comment on the 

6 methodology to scale energy conservation standards to 

7 product classes not directly analyzed.

8 (No response.)

9 MR. BROOKMAN: No comments on scaling? 

10 Okay.

11 MS. DICKENSON: Okay. In the pricing 

12 analysis, DOE establishes a relationship between BLE 

13 and end user price. In this rulemaking, DOE may 

14 conduct a pricing analysis through a product tear-down 

15 cost assessment to identify the manufacturer 

16 production cost. The manufacturer production cost 

17 would be marked up to the manufacturer's selling 

18 price. Then the manufacturer's selling price would be 

19 marked up to a retail price in the markups analysis. 

20 DOE may also use blue books and retail data to develop 

21 the end user retail pricing directly.

22 In Issue 6.6, DOE welcomes comment on the 

23 pricing methodology and in particular the feasibility 

24 of using product tear downs to develop the pricing.

25 MR. BROOKMAN: Daniel?
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1 MR. YOUNG: Daniel Young, California IOUs. 

2 Again, comment here on dimming ballasts. So just to 

3 note that the California Energy Commission and the 

4 IOUs actually used a slightly different method for 

5 understanding cost-effectiveness, both of which, you 

6 know, ended up being very cost-effective for dimming 

7 ballasts. So just encouraging you to review both the 

8 CEC methodology or the developed kind of, more similar 

9 to this kind of tear down approach and the IOU 

10 approach, which is more of a statistical analysis of 

11 ballast price in the market.

12 MR. BROOKMAN: Okay. Good. Thanks.

13 MR. HOLSTEIN: Yeah. This is Chris Holstein 

14 at Universal Lighting. We would just recommend that a 

15 lot of this conversation happen in the manufacturing 

16 interviews. I know that in the past you've been very 

17 open with Navigant in these conversations as well as 

18 the other manufacturers in the room.

19 Tear down here, you get caught with still 

20 the use of plotting where it is, it would be hard for 

21 you all to do the tear down and have an accurate 

22 understanding of what the costs are related to the 

23 product.

24 MR. BROOKMAN: Okay. Thanks, Chris.

25 Moving on.
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1 MS. DICKENSON: Okay. In Issue 6.8, DOE 

2 welcomes comment on proprietary designs it should be 

3 aware of for the fluorescent lamp ballasts that are 

4 subject to this rulemaking.

5 MR. BROOKMAN: Alex already mentioned one 

6 group of these. Joe Howley, please?

7 MR. HOWLEY: Just a similar comment to 

8 Chris's, is that this kind of information would be 

9 better provided during the manufacturing interviews, 

10 not during this forum.

11 MR. BROOKMAN: Okay.

12 MS. DICKENSON: In Issue 6.9, DOE welcomes 

13 comment on the regulatory burdens or changes that 

14 should be considered in the engineering analysis.

15 MR. BROOKMAN: Anything additional that DOE 

16 is not anticipating that you see add any additional 

17 burden?

18 (No response.)

19 MR. BROOKMAN: Nothing? Okay.

20 MS. DICKENSON: All right. And the final 

21 issue. DOE welcomes comment on any other issues that 

22 could affect the engineering analysis.

23 MR. BROOKMAN: Okay.

24 MS. DICKENSON: All right. I'll pass it 

25 over to Michael Myer.
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1 MR. MYER: Good morning. I'm Michael Myer. 

2 I'm with Pacific Northwest National Laboratory, and 

3 I'll be presenting a series of different previews of 

4 analyses that we will be doing using engineering 

5 inputs. First up will be energy use and market 

6 markups analysis.

7 The purpose of the energy use analysis is to 

8 determine the annual energy use for all efficiency 

9 levels by product class. It's a pretty 

10 straightforward process, taking the input power to the 

11 ballast times the operating hours and you get the 

12 energy usage. We of course develop operating hours by 

13 sector, whether it be residential, commercial, or 

14 industrial. We would draw on data sources such as the 

15 lighting market characterization, residential energy 

16 consumption survey, the commercial building energy 

17 consumption survey, as well as the manufacturing 

18 energy consumption survey. The table below shows 

19 sample operating hours for both the 2000 and the 2011 

20 ballast rules, just as a similar process that we've 

21 done in many other rules.

22 In addition to the energy use analysis, the 

23 input power is also related to such things as reduced 

24 wattage lamps, and we'll have an issue on that in a 

25 second asking about the prevalence of those lamps. 
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1 We've also discussed today TLEDs or tubular LEDs and 

2 how they might affect some of the energy usage, and so 

3 we'll have an issue on that in a second.

4 The first two questions or issues. Issue

5 7-1, the energy use operating profile. DOE welcomes 

6 comment on the approach DOE has taken to determine the 

7 operating profiles for fluorescent lamp ballasts in 

8 this rule. Further, DOE welcomes comment on whether 

9 the end use operating profiles are different for the 

10 various types of fluorescent ballasts under 

11 consideration for standards and, if so, how.

12 MR. BROOKMAN: Joe Howley?

13 MR. HOWLEY: I think for your reduced power 

14 ballasts, the 480 volt, it's probably going to be 

15 pretty similar to the types of operating hours you 

16 have here.

17 I think when you enter the realm of dimming 

18 ballasts it's a whole different scenario going on. 

19 You probably have additional questions asking about 

20 dimming ballasts, but dimming ballasts would most 

21 likely be set up for controls, which is why people are 

22 using them, and they probably would have more frequent 

23 on-off control, operating at lower energy mode 

24 control. And so it wouldn't be as straightforward as 

25 just the input power times the operating hours to get 
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1 energy use. It's going to be a lower energy use 

2 profile, which is probably going to be difficult to 

3 determine exactly, but it will be lower than full 

4 output 100 percent of the time like you'd have on 

5 these other ballast types.

6 MR. MYER: Thank you. And we'll have an 

7 issue where I'd like to ask a couple more in a second 

8 about dimming ballasts. Thank you.

9 MR. BROOKMAN: Pekka?

10 MR. HAKKARAINEN: Nothing at the moment.

11 MR. BROOKMAN: Okay. Then the next issue 

12 box?

13 MR. MYER: Issue 7.2, reduced wattage lamps. 

14 DOE welcomes comment on the wattage of reduced wattage 

15 fluorescent lamps typically installed as well as what 

16 proportion of reduce wattage lamps are installed. DOE 

17 also welcomes comment on the prevalence of tubular 

18 LEDs operating on fluorescent lamp ballasts.

19 MR. BROOKMAN: Charlie Stephens.

20 MR. STEPHENS: Charlie Stephens from NEEA. 

21 We've been collecting data on lamp sales in our part

22 of the world anyway for quite a little while now and 

23 we continue to collect it, so we'll provide what data 

24 we have on various lamp wattages and types in the 

25 course of the rulemaking.
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1 MR. BROOKMAN: Thank you. Joe Howley?

2 MR. HOWLEY: Yes. I mean, NEMA can discuss 

3 this as well in terms of reduced wattage versus full 

4 wattage lamps. I will mention that on dimming systems 

5 often full wattage lamps are used because they dim the 

6 best due to various technical reasons, and it provides 

7 a more fuller range from high light output to low 

8 light output on these dimming systems, but it more has 

9 to do with the dimmability. As you move into these 

10 reduced wattage lamps of 28 watt and 25 watt, they get 

11 more and more difficult to dim over a wider range, and 

12 so they don't tend to be used as often on those 

13 systems. It obviously doesn't apply to the 480 volt.

14 The reduced current ballasts may or may not 

15 be paired with a reduced wattage lamp. It just 

16 depends on exactly what the light output is that 

17 they're trying to achieve with that system.

18 And then tubular LEDs I guess is your last 

19 question. That was not very popular at all a couple 

20 years ago, but it is becoming more popular, as 

21 mentioned by a few others just recently here in the 

22 last, you know, 12 to 18 months. So it is an area 

23 where we're staring to see more use. It's still very 

24 low as a percentage of overall installed base, but it 

25 is increasing at this time.
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1 MR. BROOKMAN: Okay. Thank you.

2 MR. MYER: When you say very low, less than 

3 10 percent, less than 5 percent?

4 MR. HOWLEY: I don't know the exact numbers, 

5 but I would imagine it is in the less than 5 percent 

6 range at this point.

7 MR. MYER: And then this goes back to 

8 Charlie's question, when we say tubular LEDs, are we 

9 thinking in the 15 to 18 watt range? And I don't know 

10 if your data captures tubular LEDs as well, but if GE, 

11 when you make your comments, and/or NEMA, if you could 

12 speculate on what the typical wattage of the tubular 

13 LEDs or anyone else submitting data. It would be 

14 appreciated.

15 MR. BROOKMAN: Al Mendoza?

16 MR. A. MENDOZA: Yes. SCE is also 

17 collecting data on LED tubes on fluorescent ballasts. 

18 We're conducting some testing of our own. We'll be 

19 happy to share the data when it comes.

20 MR. BROOKMAN: It's underway and it will be 

21 available?

22 MR. A. MENDOZA: My best guess is it will be 

23 available later this year.

24 MR. BROOKMAN: Okay.

25 MR. A. MENDOZA: But we can take a look at 
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1 the -- we can analyze the current data we have and 

2 hopefully we'll be able to submit comments on time for 

3 this.

4 MR. BROOKMAN: Great. Ernesto?

5 MR. E. MENDOZA: In this case for the TLEDs 

6 or the tubular LEDs, the only thing that is true is 

7 that any number we have today, let's say 15 watts, 

8 will be wrong on the next one, will be 14 and 12. So 

9 LEDs are still evolving, so for the same light output 

10 package we just keep reducing wattage almost every 

11 quarter. So I'm not sure, it will be a very complex 

12 model I'm sorry to say because the realities, wattages 

13 are dropping down very fast.

14 MR. BROOKMAN: Okay.

15 MR. HOLSTEIN: Yeah. This is Chris Holstein 

16 with Universal Lighting on the phone.

17 MR. BROOKMAN: Yeah.

18 MR. HOLSTEIN: Just to address both of these 

19 as well. Back to the comments of the other 

20 manufacturers, to bring this back to the ballast part 

21 of the rulemaking, the usage of reduced wattage lamps, 

22 as I stated, is typically not going to happen in the 

23 dimming range, but these are the first and easiest 

24 step from an energy efficiency move in the market.

25 Be aware that the ballasts that are in these 
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1 lamps have to have added circuitry to be able to run 

2 them successfully. They have to be able to correct 

3 the flicker so that you don't have a lamp that is 

4 shaking I guess from a light perspective. OCVs are 

5 higher. So there's a lot more circuitry that has to 

6 be added to the ballasts allowed to run these lamps 

7 on.

8 And then in the market of TLEDs, the tubular 

9 LEDs, be aware that the ballasts were never designed 

10 to run a tubular LED light. Today the requirement is 

11 by UL for the lamp manufacturers to certify the 

12 ballast that runs the lamp. It's very easy to see 

13 what the primary application is relevant to the UL 

14 file and if you look at the UL file for these lamps or 

15 the UL file for the ballasts, the tubular LED lamps 

16 are not listed in the UL file. So please keep that in 

17 mind as well.

18 MR. BROOKMAN: Okay. Thank you. Yes. 

19 Ernesto?

20 MR. E. MENDOZA: One practical comment or 

21 issue. We as a ballast manufacturer, we know we 

22 design a ballast for 32 watt EPCA, for instance. We 

23 not necessarily know if it will be used with a 15, 14, 

24 17 or whatever TLED. So for reporting, it's very 

25 difficult for us to report. We will be able to report 
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1 for the 32 watt T8, which is what we design, but we 

2 don't know if somebody else is pairing with TLEDs and, 

3 if so, which ones you want us to report.

4 I think for practical purposes even though 

5 something is happening in the marketplace, we not 

6 necessarily recommend a fluorescent ballast to be 

7 paired with TLEDs. So practically, for reporting, 

8 will be a difficulty.

9 MR. BROOKMAN: Yes. Pekka?

10 MR. HAKKARAINEN: Pekka Hakkarainen from 

11 Lutron. I'm having a little bit of difficulty 

12 understanding the relevance of this point for the 

13 rulemaking because TLEDs would normally be used with 

14 ballasts that are already installed, which the 

15 rulemaking cannot affect. So other than trying to 

16 figure out some market share of products that are 

17 used, TLED and ballast combinations, and using that to 

18 estimate energy savings or lack thereof, I can't 

19 imagine that an end user would purchase a TLED and a 

20 fluorescent ballast in a new system. They would be 

21 going directly to an LED system. So I'm not quite 

22 sure that I understand this whole point.

23 MR. BROOKMAN: Okay. But it's useful, your 

24 comment's useful.

25 Final comments here?
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1 (No response.)

2 MR. MYER: Moving on. The previous 2011 

3 rule also included a portion for occupancy sensors. 

4 We will be continuing to look at that in this possible 

5 rule. So the idea is that occupancy sensors reduce 

6 the overall operating hours of the fluorescent 

7 ballast. In this case, in the 2011 rule, it was 

8 assigned that they were only used in the commercial 

9 application and it reduced them from roughly about 

10 3700 hours to in this case about 2700 hours.

11 At this time, for Issue 7.3, DOE welcomes 

12 comment on the typical space types operated by 

13 occupancy sensors. Also DOE welcomes any data on the 

14 energy savings related to the use of occupancy 

15 sensors. DOE welcomes data on the proportion of 

16 fluorescent ballasts used with occupancy sensors. And 

17 DOE welcomes any data on the effects of occupancy 

18 sensor use on the operating profiles for fluorescent 

19 lamp ballasts in this rule.

20 (No response.)

21 MR. BROOKMAN: Nothing here. Okay.

22 MR. MYER: Continuing on to the issues. 

23 Back to the dimming ballast question. Issue 7.4, DOE 

24 welcomes comment on the use of dimming ballasts, the 

25 types of ballasts and the type of lamps typically 
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1 dimmed, applications in which dimming occurs, and the 

2 output setting of the dim ballasts when in use, 

3 typical energy savings for dimming ballasts, and 

4 market share of dimming ballasts in use.

5 MR. BROOKMAN: Yes. Chris? Pardon me. 

6 Daniel.

7 MR. YOUNG: Daniel Young, California IOUs. 

8 Again, for dimming ballasts, we would recommend that 

9 you review the documents that the California IOUs have 

10 docketed with the Energy Commission when developing 

11 the rulemaking. And in that you'll find that we have 

12 assumptions on duty cycles for dimming ballasts that 

13 are -- again, this is a little bit California specific 

14 because it's designed to kind of marry with the Title 

15 24 standards in California, but we do have assumed 

16 duty cycles for different operating modes, and that is 

17 ultimately what was used to develop the weighted BLE 

18 metric, which is based on performance at 100 percent, 

19 80 percent, and 50 percent light output. So we would 

20 request that DOE review those documents which we'll 

21 docket.

22 MR. BROOKMAN: Okay. Joe?

23 MR. HOWLEY: Just a comment that you may 

24 already be aware of, that Lawrence Berkeley Labs did 

25 like a meta study a few years ago that looked at all 
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1 kinds of controls and dimming applications that might 

2 be useful to look at to see where the various 

3 applications came out. Every one is different, so 

4 there's no like this will always produce this amount 

5 of savings. They're all over the board if you read 

6 those studies.

7 MR. BROOKMAN: Pekka?

8 MR. HAKKARAINEN: Pekka Hakkarainen, Lutron. 

9 Just to echo what Joe just said, there are numerous 

10 studies, both published peer reviewed studies as well 

11 as manufacturer case studies, covering commercial 

12 applications for dimming systems. I'm not aware of 

13 much for residential applications, however.

14 MR. BROOKMAN: Okay. Thanks. Yes. Charlie 

15 Stephens?

16 MR. STEPHENS: To answer Pekka's question, 

17 we have at least some data on residential by fixture, 

18 by room, by type, by wattage, and DOE already has that 

19 data.

20 MR. BROOKMAN: Excellent. Okay. Yes.

21 MR. MYER: Finally, 7.6 seems to be 

22 addressed a little bit already. DOE welcomes comment 

23 on any data sources used to calculate the operating 

24 hours of fluorescent ballasts and energy savings 

25 related to the use of dimming ballasts.
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1 MR. BROOKMAN: Any additional data sources 

2 comment here? No? Okay.

3 MR. HAKKARAINEN: Pekka Hakkarainen, Lutron. 

4 Just to comment that we will provide some references 

5 in written comments.

6 MR. BROOKMAN: Thank you. Thank you, Pekka.

7 End use profiles.

8 MR. MYER: Issue 7-5. DOE welcomes comment 

9 on the use of operating hours profile for fluorescent 

10 ballasts in this rule. Further, DOE welcomes comment 

11 on whether the end use operating profiles are 

12 different for the various types of fluorescent lamp 

13 ballasts under consideration for standards in this 

14 rulemaking and, if so, how.

15 MR. HOWLEY: So Joe Howley. I think I've 

16 already mentioned this once, but they're different in 

17 that if they can dim they're going to have a different 

18 operating profile than if they're static. So the low 

19 ballast factor ballasts you're looking at are going to 

20 be pretty static and similar to the other ballast 

21 rulemaking, as is the 480 volt, which is primarily an 

22 industrial application. I'd just make comment there, 

23 that would be more geared towards industrial operating 

24 hours. But the dimming ballasts are going to have a 

25 different operating use profile. They're typically 
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1 put in more advanced systems that have controls on 

2 them that have a lot of, you know, different things 

3 going on, including fewer operating hours or operating 

4 in a dim mode versus just a standard static system.

5 MR. BROOKMAN: Okay. Yes. Daniel?

6 MR. YOUNG: Daniel Young, California IOUs. 

7 Just to echo that, certainly with the dimming ballasts 

8 if you're just operating them the same way you would a 

9 fixed output ballast, you're not doing it right, and 

10 that again highlights kind of the importance of 

11 understanding how they perform when they're dimmed 

12 because they don't perform the same way, and that's 

13 what we found in our testing. So, if DOE is 

14 considering doing ballasts again, we would highly 

15 suggest that the test procedure be revisited as well.

16 MR. BROOKMAN: Okay. Yes. Chris?

17 MR. GRANDA: Chris Granda, ASAP. I want to 

18 support Joe's and Daniel's comment and just note that 

19 a source of data on the duty cycle for the different 

20 ballasts may be available from some of the larger 

21 commercial energy efficiency programs which have to 

22 develop that in order to do their cost/benefit 

23 analysis. I don't know whether the California IOUs 

24 have to do that, but I know that National Grid does 

25 and Efficiency Vermont does as well.
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1 MR. BROOKMAN: Okay. Great. Final comments 

2 here?

3 (No response.)

4 MR. BROOKMAN: Okay.

5 MR. MYER: Moving on, the next analysis 

6 would be the markup analysis. The purpose is to 

7 estimate actual user purchase price for manufacturer 

8 selling price of baseline and higher efficiency 

9 product designs.

10 Method. We're going to identify different 

11 distribution channels and estimate the share of said 

12 distribution channels. Also we're going to estimate 

13 markup values for each level in the identified 

14 distribution channel.

15 This slide shows the graph from the 2000 and 

16 2011 ballast rules just for a point of reference. Two 

17 different channels, one being a ballast shipped with a 

18 fixture, the other one where it's a replacement 

19 ballast. In the 2000 and 2011 ballast rules, it was 

20 essentially assumed that about 63 percent of ballasts 

21 were shipped as part of fixtures and 37 were used in 

22 the replacement market. We will of course conduct new 

23 research to verify these values, but this is a 

24 historical marker.

25 Essentially markup is applied at each arrow 
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1 in the process and the markups analysis would develop 

2 what the appropriate markup is at each phase as well.

3 Issue 8-1, DOE seeks comment on the 

4 distribution channels and each share for distribution 

5 channel described in this document as it applies to 

6 the fluorescent lamp ballasts under consideration for 

7 standards.

8 MR. BROOKMAN: Joe Howley?

9 MR. HOWLEY: Joe Howley. The channels 

10 appear to be appropriate. They're similar to the last 

11 ballast rulemaking.

12 The mix of fixture ballasts versus 

13 replacement ballasts may not be the same. There 

14 appears to be a slow-down in the amount of pure lamp 

15 and ballast retrofits that are going on these days as 

16 the LED market is activating. So we haven't looked at 

17 this, we don't know what the number is, but that may 

18 not be the same split as it was three years ago.

19 MR. BROOKMAN: Thank you. Okay. I was

20 wondering if California has data on this.

21 MR. HOLSTEIN: This is Chris Holstein.

22 MR. BROOKMAN: Chris, go ahead.

23 MR. HOLSTEIN: I was going to say I'll 

24 provide comments in the written comments. They're not 

25 the same because they were in the last ballast rule. 
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1 They're significantly different from what's 

2 publicized.

3 MR. BROOKMAN: That will be very helpful. 

4 Thanks, Chris.

5 Okay. Additional comments here?

6 (No response.)

7 MR. BROOKMAN: Okay. Nothing.

8 MR. MYER: Okay. Continuing on. Then we

9 would move into the life-cycle cost analysis and the 

10 payback period analysis. The purpose is to assess the 

11 economic inputs of different efficiency levels on the 

12 consumers of fluorescent lamp ballasts. The method is 

13 the life-cycle cost is equal to the install cost plus 

14 your operating costs. Results are expressed in LCC 

15 savings and payback period, which is expressed in a 

16 period of years.

17 Inputs are broken down in calculation 

18 methodology, so essentially we're going to look at a 

19 series of different things, such as the product 

20 purchase price, which is taking the manufacturer's 

21 selling price and adding on markups; the installation 

22 costs, labor and materials to actually install said 

23 products; maintenance costs incurred by the consumer 

24 for preventative maintenance of the products; any 

25 potential repair or replace damaging of manufacturing 
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1 component costs. Obviously the energy costs 

2 associated with operating the product. The discount 

3 rate, which is essentially the cost of capital or 

4 finance costs for residential sectors. And then 

5 finally the product lifetime, which will be borne out 

6 of catalogs and literature sources, technical reports 

7 and industry inputs.

8 We would also look at a no-new-standards 

9 case efficiency distribution. No-new-standards 

10 distribution is the distribution of the market share 

11 for each efficiency level for product classes in the 

12 absence of an amended DOE standard. If market share 

13 data is not available by efficiency level, DOE may 

14 develop no-new-standards efficiency distributions 

15 based on available models.

16 We're also going to conduct a Monte Carlo 

17 simulation. The idea here is that we will do a large 

18 number of samples, 10,000 or more as an example, where 

19 different parameters are modified to see the end 

20 results.

21 The LCC, LCC savings and payback period, are 

22 expressed in the form of mean or median values, and 

23 the LCC results are also presented in the form of 

24 estimated percentage of consumers that are adversely 

25 affected by amended standards.
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1 That brings us to the next set of issues, 

2 Issue 9-1. DOE welcomes input on the electricity 

3 prices to be used in this analysis.

4 MR. BROOKMAN: Chris.

5 MR. GRANDA: Chris Granda, ASAP. I'm just 

6 noting the obvious. I think we're entering into a 

7 period of potentially greater uncertainty with regards 

8 to electricity prices due to things like the Clean 

9 Power program and the rapidly developing market for 

10 distributed generation. And so an analysis method 

11 that takes that uncertainty into account, whether 

12 that's, you know, a sensitivity analysis with 

13 different prices or what have you, would be 

14 appropriate.

15 MR. BROOKMAN: Okay. Thanks.

16 MR. MYER: Issue 9-2, discount rates. DOE 

17 welcomes input on the planned approaches for 

18 estimating discount rates for consumers of fluorescent 

19 ballasts under consideration.

20 (No response.)

21 MR. BROOKMAN: No additional comments on 

22 discount rates, so I think most of you are familiar 

23 with the way DOE typically does discount rates. Okay. 

24 Nothing additional.

25 MR. MYER: Continuing into Issue 9-3, cost 
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1 input. DOE welcomes comment on how to develop 

2 installation, maintenance and, if applicable, repair 

3 costs for fluorescent ballasts. In particular, DOE 

4 will -- energy conservation standards affect useful 

5 lifetimes of the ballasts and/or the fluorescent lamps 

6 operated by those ballasts. If the lamps operated by 

7 the more efficient ballasts would be affected, then 

8 DOE invites comments from interested parties on 

9 whether relamping practices would change as a result.

10 MR. BROOKMAN: Nothing here? Joe.

11 MR. HOWLEY: I guess the only thing I'll 

12 mention -- this is Joe Howley from GE -- is that while 

13 generally when you dim incandescent systems you do 

14 greatly increase the lamp life, that generally is not 

15 the case with fluorescent systems. You don't 

16 generally increase the lamp life. In fact, if it's 

17 not dimmed properly, you could actually reduce the 

18 lamp life depending on how the cathodes are treated in 

19 the dimming process. But there wouldn't be any 

20 increase in lamp life to be factored in.

21 MR. BROOKMAN: Okay. Yes? Ernesto?

22 MR. E. MENDOZA: I'm just curious. When you 

23 are talking here on repair costs, it's repair costs of 

24 the system or the ballast? I don't know anybody who 

25 repair ballasts nowadays.
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1 MR. MYER: Michael Myer, PNNL. Echoing Joe 

2 Howley's comment from GE, in the previous rules, we 

3 assumed nobody repaired ballasts. That was the 

4 previous assumption, and we will at this point, 

5 especially based on Joe's comment, not continue to 

6 assume that people repair ballasts. So, yeah, that 

7 repair cost is for the ballasts. The maintenance cost 

8 would be servicing of the lamp system in case you have 

9 to replace the ballast or replace the lamp in a normal 

10 operation. And that's where group and spot would come 

11 in this question. But thank you for the question.

12 MR. BROOKMAN: Did we do lifetimes yet or 

13 no?

14 MR. MYER: No.

15 MR. HOLSTEIN: This is Chris with Universal 

16 Lighting Technologies.

17 MR. BROOKMAN: Yes.

18 MR. HOLSTEIN: The only thing I would add to 

19 that is some of the technology suggestions. If 

20 there's push of the volume of the product as we go 

21 down this path to make the products bigger, it would 

22 significantly change the maintenance costs.

23 MR. MYER: So keep in -- Chris, Michael 

24 Myer. As I'm understanding this, if the form factor 

25 of the ballast changed, that could then result in a 
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1 change in maintenance costs?

2 MR. HOLSTEIN: Yes, sir.

3 MR. MYER: Thank you for clarifying.

4 MR. BROOKMAN: Okay. It won't fit, will it? 

5 I mean, the little screw mounts won't -- right -- the 

6 little -- right. Okay. That's fine.

7 MR. MYER: Thank you very much. Moving into 

8 Issue 9-4, ballast lifetimes. DOE welcomes comment on 

9 the appropriate fluorescent ballast lifetimes for the 

10 ballasts under consideration.

11 MR. BROOKMAN: Any difference in lifetimes 

12 looking ahead?

13 (No response.)

14 MR. BROOKMAN: No comment here. Okay.

15 MR. MYER: Okay. Building on the life-cycle 

16 cost analysis and the payback period analysis, we 

17 would then conduct a shipments analysis and national 

18 impact analysis. The shipments analysis, the purpose 

19 is to project future shipments by product class. DOE 

20 typically projects based on a 30-year period, starting 

21 at the compliance date of the standard. We will build 

22 on any previous rule data that existed. We will also 

23 be calculating it on historical shipments, retirements 

24 of previously installed ballasts, as well as other 

25 appropriate data sources. DOE may use different 
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1 shipment projections in the standards case and the no2 new-standards case depending on information available.

3 Part of the shipment analysis, we would look 

4 at three different scenarios, one being new 

5 construction. That means essentially the ballast is a 

6 part of a new fixture going into construction. We 

7 would potentially use growth projections to determine 

8 commercial and industrial equipment sectors. Again, 

9 this is done in a 30-year compliance period.

10 The other thing we would look at is 

11 replacements. This refers to new ballasts that are 

12 installed each year to replace ballasts that have 

13 failed. And then we'd also look at retrofits, which 

14 mean the ballasts replace existing during renovation. 

15 The retrofit replacement may occur before the actual 

16 ballast has failed.

17 Issue 10-1, data on source for shipments. 

18 DOE welcomes recommendations on sources of data that 

19 would provide information on shipments of fluorescent 

20 ballasts by product class. In addition, DOE welcomes 

21 comment on recommendations on how it might 

22 characterize long-term trends and efficiency of 

23 fluorescent ballasts for the no-new-standards case 

24 projection.

25 MR. BROOKMAN: Charlie.
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1 MR. STEPHENS: Charlie Stephens, NEEA. 

2 You've got a real handful here in this one, as we've 

3 all discussed in all the lighting rulemakings, when it 

4 comes to the displacement rate of this technology with 

5 the newer ones. Right now what we see in our 

6 marketplace is that the LED replacements tend to be 

7 something maybe not quite an order of magnitude more 

8 expensive, but they're very expensive compared to the 

9 incumbent technology. So we don't expect that to 

10 remain the case. The prices will come down 

11 eventually.

12 But it seems to me that to some extent early 

13 on in the market your relative shipment rates of the 

14 different technologies will depend on their price 

15 relationship and the price elasticity I guess you 

16 could say of people's interest in LED technology. So 

17 do you have some means for testing alternative 

18 scenarios here depending on how the prices of LED 

19 products evolve over time?

20 MR. MYER: At this time we are just 

21 collecting data. But it is a fluorescent lamp 

22 ballast. And while we understand other technologies 

23 might play a role in how fluorescent ballasts are 

24 affected in the marketplace, we're only focusing on 

25 the efficiency of the fluorescent ballasts, the 
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1 projection of fluorescent ballast efficiency over 

2 time.

3 MR. STEPHENS: Yeah, I understand that. But 

4 you have them laid out as new construction and 

5 replacements. And what I'm saying here is that the 

6 numbers of ballasts going into new construction will 

7 be impacted by -- since you're not looking at all of 

8 them and you're only looking at one subset, that those 

9 numbers will change depending on how the price of LEDs 

10 change because in new construction people would prefer 

11 to use the LEDs in many cases if they're cheap enough.

12 MR. MYER: Yes.

13 MR. STEPHENS: But if they're not, maybe 

14 they won't. So I'm wondering how you're going to 

15 account for, you know, how that's going to shift 

16 depending on how the alternative technology comes out 

17 in these various sectors.

18 MR. MYER: Michael Myer, Pacific Northwest 

19 National Laboratory. Yes. We have in the past and I 

20 believe in this previous fluorescent ballast rule, for 

21 example, looked at different shipment profiles. So we 

22 will look at different things and take into account 

23 how we develop those profiles. It might be the price 

24 relation to LEDs as well as other factors. So we can 

25 look at different growth cycles for new construction.
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1 MR. BROOKMAN: Yes, Charlie. Oh, Joe. Go 

2 ahead.

3 MR. HOWLEY: Yes. Well, Joe Howley, GE. I 

4 was looking at I think the other side of that, 

5 Charlie, where if this produced a very expensive 

6 fluorescent dimming ballast it is just going to 

7 accelerate new construction to go to LED if they want 

8 a dimmed system. They simply will just give up on 

9 fluorescent dimming ballasts. So it would be an 

10 equation where if the standard produced very high 

11 cost, there would be no savings from it because the 

12 product would simply shift almost immediately to LED 

13 dimming. So that should be factored somehow into the 

14 analysis.

15 MR. BROOKMAN: Okay. You want to follow on, 

16 Pekka?

17 MR. HAKKARAINEN: Pekka Hakkarainen, Lutron. 

18 What Joe is describing is a theoretical scenario that 

19 will never take place anyway because no one is going 

20 to make the higher-cost dimming ballast.

21 MR. BROOKMAN: Charlie.

22 MR. STEPHENS: Yeah. Charlie Stephens. I 

23 was just looking at the existing scenario that 

24 California looked at essentially. They looked at a 

25 range of dimming ballasts that exist. They can be 
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1 tested. Some of them are more efficient than others. 

2 They have a price. We know what the price is today. 

3 What we don't know is we don't know what the price of 

4 LEDs is going to be next week or next year or in five 

5 years, so that's the much bigger variable.

6 I think if DOE were to, for instance, set a 

7 standard for dimming ballasts that eliminated half of 

8 them, well, the other half are still out there. We 

9 know what the prices are. People are buying them. 

10 But we still don't know what the prices of the LEDs 

11 are going to be. So it's a bit of a crapshoot really 

12 in trying to figure out what the future looks like in 

13 this circumstance. I don't envy DOE the task of 

14 trying to figure this out, but there ought to be some 

15 sort of a scenario look at this that has -- not that 

16 it's just a scenario that says, yeah, shipments could 

17 be this or this. It's why would shipments do this or 

18 this, because these things are all related.

19 MR. BROOKMAN: Yeah. Ernesto.

20 MR. E. MENDOZA: Yeah, I agree with you. 

21 It's very difficult to see the future. But our 

22 experience is the first LED lamps came out at about 

23 $40. Today they are $2. So the only thing I'm unsure 

24 is it will be lower cost in the future. So that's for 

25 sure. And I echo also Pekka's scenario. I don't 
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1 think we're going to pre-design ballasts for higher 

2 efficiency. The rule requires for higher efficiency. 

3 Most probably those ballasts will not exist.

4 MR. BROOKMAN: Rebecca?

5 MS. RAINER: Yeah. I think some of these 

6 questions really would be better answered in the 

7 manufacturers' --

8 MR. BROOKMAN: Okay. Yeah.

9 MS. RAINER: -- visits, and we can share our 

10 data and what we see the future to be.

11 MR. BROOKMAN: Great. Thank you for 

12 reiterating that. Daniel?

13 MR. YOUNG: Daniel Young, California IOUs. 

14 So a question for DOE. If the situation that Joe 

15 describes happens where the rule makes products more 

16 expensive, can DOE look at savings that occur through 

17 kind of this market shift to the more efficient LEDs?

18 MR. MYER: Michael Myer, PNNL. DOE tends to 

19 focus the analysis on what are the results of 

20 improving one technology, not as a result of other 

21 interactions of different technologies.

22 MR. YOUNG: Right. But I guess by improving 

23 this one technology you're -- I mean, really it's --

24 you're looking at the application for commercial 

25 lighting say. And if you've reduced commercial 
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1 lighting energy use, you know, isn't that a good 

2 thing, and wouldn't you want to take credit for those 

3 savings?

4 MR. MYER: I'm going to defer to our written 

5 comments in the next phase rule. I don't want to 

6 assume how DOE likes to take credit for different 

7 actions.

8 MR. BROOKMAN: Pekka.

9 MR. HAKKARAINEN: Pekka Hakkarainen, Lutron. 

10 I think it would be prudent for DOE to assume that 

11 all the dimming ballasts that are going to be 

12 available after the rule becomes effective are already 

13 in the market.

14 MR. BROOKMAN: Okay. Chris, you had a 

15 question, comment?

16 MR. GRANDA: No.

17 MR. BROOKMAN: Okay. We're about to move 

18 on. Are we ready?

19 MR. MYER: Yeah. Issue 10-2, accounting 

20 methodology. DOE welcomes comment on the accounting 

21 methodology described in the framework document for 

22 each of the fluorescent ballasts under consideration.

23 MR. BROOKMAN: Nothing here?

24 MR. HOLSTEIN: This is Chris Holstein, 

25 Universal Lighting Technologies. I just wanted to 
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1 bring out on the framework document there's some 

2 things there that I believe are flawed that talk about 

3 the increasing retrofit market, it talks about the 

4 increasing rebate market. That is not what we see 

5 today. I know in the framework document it does say 

6 that you're using information from the last ruling to 

7 do that.

8 But from industry numbers, which will be 

9 prepared by me in the written comments as well as for 

10 manufacturers, there's no indication of any product 

11 category here. Every segment in the ballast market we 

12 have new construction converted into solid stage 

13 lighting, and by the time this rulemaking is 

14 implemented in 2017, I would say that nearly 90 to 95 

15 percent of this market will receive solid-state 

16 lighting. Replacement market and offense load, I'm 

17 not aware of any rebate today on the 4X side after the 

18 efficiency ruling and the efficiency levels that you 

19 have today, which would be for all new solid-state 

20 lighting.

21 And you've already talked about retrofits. 

22 I mean, the retrofit market today doesn't -- I mean, 

23 there's very, very little fluorescent retrofitting 

24 going on. Someone one is making a change. Every

25 manufacturer has a retrofit kit with LED. That is 
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1 what we see in the market and that's where it's going. 

2 So everybody who uses LED, don't go in with the 

3 assumption that all systems are created equally 

4 because it's not.

5 MR. BROOKMAN: Okay. Thank you. Yes, 

6 Daniel.

7 MR. YOUNG: Daniel Young, California IOUs. 

8 Just a note on there. So, you know, while I'm not 

9 going to, you know, try to predict the future for all 

10 fluorescent shipments, I will just caution that the 

11 percentage of dimming ballasts in the fluorescent 

12 market, we expect that to increase, and due to very 

13 recent standards, such as the Title 24 standard that 

14 just went into effect last July. So a lot of those, 

15 you know, market effects maybe haven't been felt yet, 

16 but we do expect, again, relative to where they are 

17 today and where they have been, the number of 

18 shipments or the percentage of shipments that are 

19 dimming ballasts, we expect that to go up.

20 MR. BROOKMAN: Okay. Thanks.

21 MR. MYER: Issue 10-3, standards affecting 

22 shipments. DOE welcomes comment on how any potential 

23 new or amended concentration standards for fluorescent 

24 ballasts might affect shipments. DOE also invites 

25 information about market pull programs that currently 
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1 exist to promote the adoption of more efficient 

2 ballasts.

3 MR. BROOKMAN: I think we've received some 

4 comment on this. Do we have anything additional at 

5 this point? Mary?

6 MS. ANDERSON: So California is looking at 

7 our programs to try to see if there are additional 

8 things we can do help support the market push-pull. 

9 And nothing public, but in the next month or so I 

10 should have information on potentially additional 

11 items that we will be doing to support these 

12 rulemakings.

13 MR. BROOKMAN: I'm not sure I understood 

14 you, Mary. In a month you might have what?

15 MS. ANDERSON: We will have -- I think we 

16 may have a new potential rebate program --

17 MR. BROOKMAN: I see.

18 MS. ANDERSON: -- that could help to do 

19 that. But we're still under development.

20 MR. BROOKMAN: Got you. Chris?

21 MR. GRANDA: Chris Granda, ASAP. After 

22 residential lighting, commercial lighting programs of 

23 all type are the largest energy efficiency program 

24 category in terms of savings, have been historically, 

25 and for many utilities or program providers they are 
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1 the breadwinner, if you will.

2 MR. BROOKMAN: Or the easiest.

3 MR. GRANDA: And the easiest, yeah, in a lot 

4 of cases. So there's, you know, rich sources of 

5 information available at the utilities that run these 

6 programs. They all involve some kind of reporting 

7 obviously. But I think the overall comment that ASAP 

8 would like to make is that, you know, in the dynamic 

9 situation that we're in, as standards take effect, but 

10 also as the technology paradigm for this market sector 

11 changes, legacy market niches for obsolete 

12 technologies can have big energy efficiency costs 

13 associated with them, and understanding even when they 

14 end up being relatively small percentages of the 

15 overall market, they can have large numbers of 

16 kilowatt hours associated with them if they endure for 

17 a long period of time in the marketplace. And there's 

18 definitely some -- we've had some experience with that 

19 in other product categories.

20 MR. BROOKMAN: Okay. Charlie?

21 MR. STEPHENS: Yeah. Charlie Stephens. 

22 We're reevaluating all of our commercial lighting 

23 programs and commercial building programs in the 

24 Northwest right now, and we're struggling in a lot of 

25 places with cost-effectiveness, our own cost-
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1 effectiveness criteria. When you don't need power 

2 because things aren't growing, you know, cost3 effectiveness becomes a bit of a challenge. So we're 

4 going to have to achieve whatever savings there are at 

5 lower cost in a lot of cases and be more clever and 

6 sometimes more targeted in what we go after.

7 As Chris just mentioned, there are some 

8 older legacy systems out there that while the market 

9 is small, if you can figure out how to get at it, the 

10 savings can be large per building or per project. But 

11 to a great extent we're struggling a little bit with 

12 the costs that we see. Controls, for instance, have 

13 become very costly, and they don't always work. So 

14 we're having -- our own spaces are an example of that. 

15 But we're struggling a little bit with what to do and 

16 how to make it cost-effective. So I can't 

17 unfortunately say right now what directions we may be 

18 going in. We'll do something, but we don't know what 

19 it is yet.

20 MR. BROOKMAN: Okay. Yes, please, your 

21 name.

22 MR. TSAN: This is Bach Tsan from Southern 

23 California Edison. I'm just looking at our solutions 

24 directory for programs, and there is not necessarily 

25 for energy efficiency, but there are some rebates for 
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1 demand response in regards to dimming ballasts. I'll 

2 share through Daniel that particular program.

3 MR. BROOKMAN: Okay. Thank you. Next?

4 MR. MYER: The next would be national impact 

5 analysis. National impact analysis looks at the 

6 overall effects at the national level in the form of 

7 an NES, which is National Energy Savings, and net 

8 present value is the total cost across the country. 

9 It takes into account inputs and outputs from the LCC 

10 as well as shipments to develop an annual series of 

11 national energy and economic effects.

12 It aggregates the cost of energy use in 

13 years in the analysis period. It's reported in 

14 primary and full-fuel cycle savings, and the NPV is in 

15 billions of dollars. It accounts for time, value, 

16 money through defined discount rates.

17 Inputs for calculating the NPV are the 

18 installed and operating costs, as I mentioned, that 

19 were garnered in the LCC: projected shipments; 

20 electricity price projections; HVAC, heating, 

21 ventilation, and air conditioning price

22 projections -- interactions, I'm sorry, I should say; 

23 a fixed discount rate of 3 and 7 percent; and any 

24 potential rebound effect.

25 Issue 11-1, data sources for NIA. DOE 
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1 welcomes data on sources it anticipates using to 

2 develop inputs for the National Impact Analysis.

3 MR. BROOKMAN: Anything additional here or 

4 anything that might be novel?

5 (No response.)

6 MR. BROOKMAN: Nothing additional, okay.

7 MR. MYER: Issue 11-2, the NIA model. DOE 

8 welcomes comments on the NIA spreadsheet models it 

9 plans to use for estimating national impacts for 

10 fluorescent ballasts.

11 MR. BROOKMAN: Yes, Daniel.

12 MR. YOUNG: Daniel Young, California IOUs. 

13 So actually just a question. Can we ask DOE to 

14 provide certain kind of interim values, like maybe 

15 statewide savings or perhaps unit savings in their 

16 spreadsheet models?

17 MR. MYER: I'm sorry. Statewide savings? 

18 Michael Myer, PNNL. And what was the second one?

19 MR. YOUNG: Like unit savings. Sometimes 

20 it's there, sometimes it's there but hard to find. 

21 You know, it makes things a lot easier for us 

22 sometimes when we want to analyze things either just 

23 for our own, you know, statewide understanding of the 

24 impacts or just kind of checking the various 

25 calculations or proposed levels. So just kind of 
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1 asking for some interim results presented or 

2 highlighted in the spreadsheet models that makes it 

3 easier for us to find what we're looking for I guess. 

4 Can we, you know, provide a set of requests I guess 

5 and then ask you to do that?

6 MS. deBUTTS: We can look into it. If you 

7 send us the information of what you're actually 

8 looking for, we can just analyze and see if we can 

9 actually do that.

10 MR. YOUNG: Great. Thank you.

11 MR. MYER: And Michael Myer. When you say 

12 interim, you're not suggesting between phases. It's 

13 more just subset of the total data.

14 MR. YOUNG: Right.

15 MR. MYER: Just putting it down differently.

16 MR. YOUNG: Right.

17 MR. MYER: And unit meaning if 30 million 

18 units are shipped, what is it per piece.

19 MR. YOUNG: Exactly.

20 MR. MYER: Great. I just wanted to make 

21 sure I understood everything. Thank you.

22 MR. BROOKMAN: Okay. Additional thoughts, 

23 comments here? Let's go ahead, Mike.

24 MR. MYER: We addressed 11-2 --

25 MR. BROOKMAN: Yeah.
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1 MR. MYER: -- with Daniel's comment. At 

2 this point, I will turn the presentation to my 

3 colleague, Rachel Dickenson, to discuss the future 

4 NOPR analyses.

5 MS. DICKENSON: Okay. I'll just briefly 

6 discuss some of the analyses that DOE plans on 

7 conducting in the NOPR stage of the rulemaking.

8 The manufacturer impact analysis serves 

9 three main functions. First, it assesses the impacts 

10 of standards on manufacturers. Second, it identifies 

11 and estimates impacts on manufacturer subgroups that 

12 may be more severely affected than the industry as a 

13 whole. And third, it examines the direct employment 

14 impacts, manufacturing capacity, and cumulative 

15 regulatory impact on the industry.

16 To do this, DOE will analyze industry cash 

17 flow and industry net present value through a 

18 quantitative model called the GRIM. DOE will also 

19 interview manufacturers to refine inputs to this model 

20 and address qualitative issues. All data and 

21 information shared is aggregated prior to the use in 

22 the rulemaking analysis.

23 So manufacturer impact consists of three 

24 phases. The first starts during the preliminary 

25 analysis in which DOE will create a basic industry 
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1 profile and conduct the initial interviews. Then 

2 during the NOPR DOE develops a strawman GRIM in phase 

3 two, followed by interviews and assessment of direct 

4 employment competition in the field of regulatory 

5 burden in phase three.

6 And here are some of the other analyses the 

7 DOE will conduct in the NOPR stage. They include the 

8 consumer subgroup analysis where DOE analyzes the 

9 consumer effects on various national consumer 

10 subgroups that might be adversely affected by 

11 potential standards; the utility impact analysis, 

12 which determines the impact on the general capacity of 

13 utilities as a result of potential standards; the 

14 employment impact analysis, which covers indirect 

15 employment impacts resulting from shifts in costs or 

16 changes in income due to potential standards. And 

17 this is different from the employment impact analysis 

18 conducted in the manufacturer impact analysis, which 

19 assesses the direct employment, which are the changes 

20 in the employment numbers as plants that produce the 

21 covered products.

22 The emissions analysis is where DOE will 

23 estimate the reduction in power sector emissions of 

24 carbon dioxide, nitrogen oxide, sulfur dioxide, and 

25 mercury due to the potential standards. And DOE also 
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1 assesses the monetary benefits of reducing carbon 

2 dioxide and nitrogen oxide emissions due to potential 

3 standards.

4 The regulatory impact analysis looks at the 

5 impacts of non-regulatory alternatives that could 

6 improve the energy efficiency or reduce the energy 

7 consumption of the products covered in this 

8 rulemaking.

9 So first, DOE welcomes comment on what, if 

10 any, consumer subgroups are appropriate in considering 

11 standards for the fluorescent lamp ballasts.

12 (No response.)

13 MS. DICKENSON: DOE also welcomes input from 

14 interested parties on its plan to use the NEMS-BT to 

15 conduct the utility impact analysis.

16 (No response.)

17 MS. DICKENSON: Okay. And DOE welcomes 

18 feedback on its planned approach for assessing the 

19 national employment impacts, both direct and indirect.

20 (No response.)

21 MS. DICKENSON: Finishing up, DOE seeks 

22 comment on its approach to conduct the emissions 

23 analysis for the products that would be under 

24 consideration for standards in this rulemaking.

25 (No response.)
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1 MS. DICKENSON: And DOE requests comment 

2 about the approach it plans to use for estimating the 

3 monetary benefits associated with the emissions 

4 reductions.

5 (No response.)

6 MR. BROOKMAN: We went through those kind of 

7 rapidly. These are downstream significantly. Any 

8 additional comments, thoughts on any of these 

9 consumer, utility, employment, emissions, and 

10 monetizing, and globally regulatory impact analysis 

11 generally? Alex Boesenburg.

12 MR. BOESENBURG: Alex Boesenburg, NEMA. I 

13 have a general comment about the impact analysis. In 

14 the past, usually the way we get to see the results of 

15 the analysis is in the TSD spreadsheets. However, 

16 when we attempt to understand the dynamics of the 

17 impacts and how they're felt, since most of the 

18 spreadsheet is locked, we really -- we can adjust a 

19 few fields here and there for discount rates or 

20 whatever, but it doesn't actually help us understand 

21 in a way that we can therefore substantively and 

22 productively and constructively comment on how we 

23 think an analysis or an impact might -- its assessment 

24 could be improved or something.

25 You know, we just -- it's very hard to --
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1 there's a lot of data there, but we can't actually do 

2 much with it. So we'd like to, you know, ask the DOE 

3 to consider or come up with a more proactive way to 

4 discuss analysis. And as more of a real world example 

5 of this is often when we have TSD or NOPR analysis, 

6 someone from Navigant or LBNL or PNNL is up there and 

7 they say that, well, it looks like the impact is going 

8 to be kind of like this. And one of the manufacturers 

9 will ask, well, why is that? Did you talk about

10 the -- did you look at this way. So, oh, no, no, we 

11 assume that would never happen. And the manufacturer 

12 says, no, no, no, we always do it that way. What are 

13 you talking about?

14 These assumptions aren't documented, and so 

15 we never know if someone went ahead to make a decision 

16 to go left or right and made the right one. And so 

17 that's just one example. We turn this stuff over 

18 occasionally, but only Easter eggs when we happen to 

19 stumble across one, and I think we can do something 

20 different, something better, and we'd like to ask you 

21 to consider that.

22 MS. deBUTTS: Thanks, Alex. Lucy deButts 

23 with DOE. I understand the concern. There are 

24 certain rules that we have to abide by when we place 

25 documents in a docket. So, you know, I don't know 
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1 exactly if that's the issue there as well. We'll have 

2 to check. But also that's why it's useful to have the 

3 meetings like that when we actually have the 

4 conversation with the manufacturers to discuss our 

5 TSDs and analysis that's presented there. But we'll 

6 see what we can do as well.

7 MR. BROOKMAN: Yeah. It sounds like you're 

8 seeking a tool that's more flexible or more 

9 transparent or something.

10 MR. BOESENBURG: Yes. That's a good way to 

11 sum it up.

12 MR. BROOKMAN: But it may be hard to do.

13 MS. deBUTTS: In some cases, it is, but, you 

14 know, again, we'll try. We'll see what we can do.

15 MR. BOESENBURG: We're sensitive that one of 

16 the reasons some of this stuff is locked is because 

17 you're protecting the data, and we applaud that. But 

18 at the same time, there is -- you know, there is -- if 

19 there is a way to protect the manufacturers' 

20 confidentiality and the data, which I am obliged to do 

21 myself, but still help understand the machinations of 

22 the model, it would be very helpful.

23 MS. deBUTTS: Okay. Thanks.

24 MR. BROOKMAN: Okay. So, as we promised 

25 this morning, yet another opportunity for closing 
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1 remarks or any other material that we haven't covered 

2 sufficiently by your thoughts to date. Ernesto.

3 MR. E. MENDOZA: Ernesto Mendoza from 

4 Philips Lighting. On the case, specific case of 

5 dimming ballasts, the use is different than the fixed 

6 output ballasts. They are always part of a system. 

7 You may have a very simple control, or you may have a 

8 more compressed control, but it's always a system. So 

9 I don't know if it need to include in the model from 

10 the DOE the systems approach, the total efficiency 

11 that the system will achieve as opposed to only the 

12 ballast.

13 The concern I have is we can start limiting 

14 the energy use of the ballast. Then if we need to do 

15 additional control information and communications, 

16 we're just going to put an extender box to the ballast 

17 that would consume power than if all this intelligence 

18 would be inside of the ballast. So the total 

19 efficiency will go down in the system where we will 

20 have a higher ballast efficiency. So my suggestion is 

21 to consider in the modeling the systems approach as 

22 opposed as only the ballast efficiency.

23 MR. BROOKMAN: Okay. Additional comments 

24 here as we move toward closure, final comments on the 

25 day?
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1 (No response.)

2 MR. BROOKMAN: Nothing additional at this 

3 time. So then back to Lucy, Lucy deButts, for closing 

4 remarks.

5 MS. deBUTTS: Well, again, thank you, 

6 everyone, for coming. And it seems like we're going 

7 to get a lot of data that could be useful for our 

8 rulemaking. This is again the slide on how to submit 

9 the comments. We are looking forward to them, and 

10 with that, thanks again.

11 (Whereupon, at 11:48 a.m., the meeting in 

12 the above-entitled matter was concluded.)
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REPORTER'S CERTIFICATE

DOCKET NO.: N/A

CASE TITLE: Public Meeting on Energy Conservation

Standard Framework - Fluorescent

Lamp Ballasts

HEARING DATE: July 17, 2015

LOCATION: Washington, D.C.

I hereby certify that the proceedings and 

evidence are contained fully and accurately on the 

tapes and notes reported by me at the hearing in the 

above case before the U.S. Department of Energy, 

Office of Energy Efficiency & Renewable Energy.

Date: July 17, 2015

David Jones

Official Reporter

Heritage Reporting Corporation

Suite 206

1220 L Street, N.W.

Washington, D.C. 20005-4018