# TRANSCRIPT OF PROCEEDINGS

HERITAGE REPORTING CORPORATION Offic ial 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, 20151

Heritage Reporting Corporation (202) 628

- 4888 UNITED STATES DEPARTMENT OF ENERGY OFFICE OF ENERGY EFFICIENCY & RENEWABLE ENERGY

IN THE MATTER OF: ) ) PUBLIC MEETING ON ENERGY ) CONSERVATION STANDARD ) FRAMEWORK

-- FLUORES CENT ) LAMP BALLASTS ) ) )

Room 8E

- 089 James Forrestal Building 1000 Independence Avenue, S.W. Washington, D.C.

Friday, July 17, 2015

The parties met, pursuan t 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 Projec t 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 M YER, Pacific Northwest National Lab MS. ALI MCDONALD, Navigant Consulting2

Heritage Reporting Corporation (202) 628

- 4888 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 Utilities3

Heritage Reporting Corporation (202) 628

- 4 888 P R O C E E D I N G S 1

(9:05 a.m.) 2

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

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

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

Energy Conservation Standards, the framework meeting 6

on fluorescent lamp ballasts. Today is Friday, 7

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

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

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

welcoming remarks from Lucy deButts. 11

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

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

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

the A ppliance Standards Program, and today we are here 15

to discuss the framework document for fluorescent lamp 16

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

agenda. 18

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

start with introductions. You should turn the se 20

microphones both on and off and say your name and 21

organizational affiliation. 22

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

Mendoza. I'm here representing Southern California 24

Edison and the California IOUs. 254

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- 4 888 MR. BROOKMAN: Thank you. 1

MS. RAINER: Rebecca Rainer with Eaton 2

Corporation, the Lighting Division. 3

MR. HAKKARAINEN: Pekka Hakkarainen with 4

Lutron Electronics. 5

MR. BOESENBURG: Alex Boesenburg, National 6

Electrical Manufacturers Association. 7

MR. HOWLEY: Joe Howley, GE Lighting. 8

MR. YOUNG: D aniel Young representing the 9

California Investor

- Owned Utilities. 10

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

MR. GRANDA: Chris Granda, Appliance 12

Standards Awareness Project. 13

MR. STEPHENS: Charlie Stephens, Northwest 14

Energy Efficiency Alliance. 15

MS. BUTLE R: Sarah Butler, DOE. 16

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

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

MS. MCDONALD: Ali McDonald, Navigant 19

Consulting. 20

MR. WALKER: Matthew Walker, Navigant. 21

MS. DICKENSON: Rachel Dickenson, Navig ant. 22

MR. MYER: Michael Myer, Pacific Northwest 23

National Laboratory. 24

MR. BROOKMAN: Please. 255

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- 4 888 MR. ELLIOTT: Doug Elliott, Pacific 1

Northwest National Laboratory. 2

MR. TSAN: This is Bach Tsan, Southern 3

California Edison, on behalf of California IOUs. 4

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

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

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

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

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

opportunity for opening remarks, brief summary 10

comments here at the outset about issues that matter 11

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

content provided in this packet of PowerPoint slides, 13

an overview discussion on scope of coverage, a nd 14

moving on directly from there, market and technology 15

assessment screening analysis. 16

We'll take a break mid

- morning around about 17

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

analysis, and moving on directly to energy use 19

analysis, markups analysis, life

- cycle cost analysis. 20

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

Returning from lunch or whenever we get 22

there, shipments analysis, national impact analysis, 23

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

agenda, when we arrive at the end of the day today, 256

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- 4 888 another opportunity for public comment and other 1

questions that may be still unresolved for you at that 2

point. Yes? Alex Boesenburg. 3

MR. BOESENBURG: One of my members on the 4

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

of web a ttendees. 6

MR. BROOKMAN: Web attendees. Okay. I 7

think we could do that. 8

Emily, do you

-- can you hand Emily that 9

microphone? 10

FEMALE VOICE: I can give him the ability to 11

see the web attendees. 12

MR. BROOKMAN: That would be better yet. 13

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

attendees? 15

FEMALE VOICE: Yes. 16

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

who's on the line. 18

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

are familiar with the general format and framework for 20

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

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

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

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

Department follows all of this information very 257

Heritage Reporting Corporation (202) 628

- 4 888 closely. There will be a complete transcript of this 1

meeting made available. If you could be concise to 2

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

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

do so at this point. 5

And webinar participants, if you'd keep your 6

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

speak. We would welcome your engagement in this 8

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

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

in the room. That works most of the t ime these days. 11

And I think everyone at this point knows the 12

Department is making every effort to make these public 13

meetings accessible, totally available via the 14

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

Please, in addition to listening in a nd 16

participating today, please make certain if you're 17

participating via the web to send in your written 18

comments to the Department of Energy. They track this 19

stuff very, very carefully and they benefit from 20

everyone's comments. 21

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

purpose of the public meeting. 23

MS. deBUTTS: Okay. This is Lucy deButts 24

again. So the purpose of the public meeting, and I 258

Heritage Reporting Corporation (202) 628

- 4 888 stated, is to discuss the framework document that DOE 1

created for the fluorescent lamp ballasts. We would 2

like to invite comments from the participants in the 3

room and people on the webinar. We also expect 4

written comments not just from people on the webinar 5

but from everybody, all the stakeholders that are in 6

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

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

with a better analysis further in the rulemaking. 9

You will notice that throughout the 10

presentation we have the issues boxes where we raise 11

certain issues for discussion. We are not presenting 12

all the issues that are in the framework document 13

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

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

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

numbers of the issues boxes correspond with the 17

numbering w ithin the framework document. All right? 18

So if you decide to submit written 19

comments

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

to them

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

also ask you to make sure that the comments include 22

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

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

courier, and of course, if anybody decides to take a 259

Heritage Reporting Corporation (202) 628

- 4 888 trip to DOE, you're more than welcome. Hopefully it's 1

going to be via web, though. 2

And the comment period closes on August 7, 3

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

Thank you. 5

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

an opportunity for opening remarks, brief summary 7

statements here at the outset from anyone that wishes 8

to. Alex Boesenburg? 9

MR. BO ESENBURG: Well, thank you, Doug. 10

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

-- 11

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

hit some specific points as the comment boxes appear. 13

But, you know, obviously the first thing to 14

note is that the previous ballast rulemaking only 15

recently went into effect, so the impacts are still 16

being understood, and its effect on the market will 17

have to be analyzed as it folds in. 18

The previous rule was very aggressive, and 19

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

appear that there's any remaining margin on currently 21

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

reason why the DOE asked for other scope questions, 23

like 480 volts or dimming ballasts and things like 24

that. 2510

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- 4 888 Specific to dimming ballasts, I'm sure it 1

will come up in discussion that California proposed 2

and adopted standards for T8 and T5 dimming ballasts, 3

and those were very aggressive but we think are not 4

untenable. But before the DOE seeks to simply 5

implement the California regu lation as written it's 6

important to note there are some differences in the 7

definitions and test method in California, which means 8

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

the California numbers for ballast performance you'll 10

have no products f or sale in the United States. So 11

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

need to be done carefully. 13

I think in the end, if the DOE sets 14

standards for dimming ballasts nationally using the 15

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

p erformance numbers will be different, but in the end 17

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

want to make. 19

I d o want to raise a concern that I 20

encourage the DOE not to push any harder into standby 21

power requirements and lowering those becaus e we can 22

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

and connected products are becoming amazingly popular. 24

And lighting is being looked at as one of those ever 2511

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- 4 888 present things that could become the node for the 1

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

have you, and standby power directly correlates to 3

that. 4

But lastly, all of this may end up being 5

somewhat of an academic exercise because NEMA's data 6

for the last five years for fluorescent ballast sales 7

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

LEDs started to offset the market

-- it's only five 9

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

polynomial fit, standard S curve, that would forecast 11

the fluorescent ballast market ending in mid

- 2018. 12

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

starting to coast out. 14

So that has been

-- the effects of SSL have 15

been taken into account like such as in the metal 16

halide fixture rule and others, so this is again 17

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

what's real ly going to happen since we have this 19

amazing technology that's becoming more prevalent and 20

more cost

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

with the Department on those predictions. 22

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

Department will look forward to seeing as much data as 24

NEMA can provide. Yes. Okay. Other comments here at 2512

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- 4 888 the outset? Preliminary thoughts before we proceed 1

with this content? 2

(No response.) 3

MR. BROOKMAN: Nothing additional. So then 4

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

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

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

start with the regulatory history. So EPCA directed 8

DOE to conduct 2 rulemaking cycles for fluorescent 9

lamp ballasts and the first rulemakin g was completed 10

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

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

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

ballasts are subject to standards outlined in that 14

rulemaking. 15

Going forward, E ISA also directs DOE to 16

periodically review all of its standards, including 17

those for fluorescent ballasts, and therefore, within 18

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

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

of determination that standards do not need to be 21

amended or need to publish a notice of proposed 22

rulemaking amending the existing standards or 23

proposing new ones. 24

This slide gives us an overview of the 2513

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- 4 888 rulemaking, and as you can see, we anticipate that the 1

preliminary a nalyses are going to be published in the 2

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

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

2011 public final rule, per EISA requirements. 5

And finally, we anticipate that the final 6

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

October 2019. 8

And between now and the completion of the 9

2019 final rule, DOE will consider seven factors in 10

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

like economic impact analysis on individual consumers, 12

ar e considered in a life

- cycle cost analysis. The 13

economic and energy savings impact on the nation as a 14

whole will be considered in the national impact 15

analysis, and economic impact on manufacturers will be 16

considered in manufacturing impact analysis. DOE will 17

also consider impacts on utility or performance and 18

any other factors that Secretary considers relevant. 19

So currently standards only apply to active 20

mode, which is a primary light

- producing via a lamp 21

mode of ballast. However, EPCA, as Alex mention ed, 22

requires DOE to look into standards for standby mode 23

and off mode consumption where relevant. 24

So let's review the definitions for the 2514

Heritage Reporting Corporation (202) 628

- 4 888 standby mode and the off mode. So the standby mode is 1

defined as the condition in which an energy using 2

piece of eq uipment is connected to the main power 3

source and offers one or more following user

- oriented 4

or protective functions: facilitating the activation 5

or deactivation of the other functions by remote 6

switch, internal sensor or timer, and providing 7

continuous f unctions, including information or status 8

displays or sensor

- based functions. 9

The off mode is defined as a condition in 10

which the energy using piece of equipment is connected 11

to the main power source and is not providing any 12

standby or off mode functions . DOE's research 13

indicates that there are some ballasts that operate in 14

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

off mode. 16

And with that, we would like to welcome 17

comments on the standby mode of operation and any 18

information related to the energy use in that mode. 19

MR. BROOKMAN: Charlie Stephens? 20

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

talking about this since DOE has been required to look 22

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

this point to define network mode in a man ner similar 24

to the EU's definition for standby such that we could 2515

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- 4 888 start looking at products that are actually connected? 1

MS. deBUTTS: At least not in this 2

rulemaking. Not that I'm aware. 3

MR. STEPHENS: Okay. 4

MR. BROOKMAN: Yes, Daniel? 5

MR. YOUNG: Daniel Young, California IOUs. 6

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

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

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

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

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

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

that I think is relevant here, especially if dimming 13

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

being seriously considered. 15

So regarding standby mode energy use, I 16

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

dimming ballasts than with fixed output ballasts. We 18

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

models that we tested were communications

- enabled and 20

therefore had standby mode ene rgies associated with 21

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

test procedure that DOE has provided but it is not 23

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

of those results, but basically we saw products 2516

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- 4 888 perform anywhere from betw een 0 .3 watts up to 1.9 1

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

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

But, yeah, thanks. 4

MS. deBUTTS: Thank you. 5

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

comments on standby mode? 7

(N o response.) 8

MR. BROOKMAN: Okay. 9

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

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

savings

-- sorry. So current energy conservation 12

standards for fluorescent lamp ballasts are applicable 13

to active mode e nergy use and are based on ballast 14

luminous efficiency, BLE. And DOE actually plans to 15

continue using the BLE metric for energy conservation 16

standards rulemaking to regulate active mode energy 17

use. 18

For standby power, DOE plans to consider an 19

integrated metric. For example, a standby mode

20

capable ballast such as a dimming ballast may draw 21

additional power in active mode as a result of 22

additional circuitry in place, to support standby mode 23

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

the metric. 2517

Heritage Reporting Corporation (202) 628

- 4 888 MR. BROOKMAN: Daniel? 1

MR. YOUNG: Daniel Young, California IOUs. 2

So again, this is based on our experience in 3

California, but for dimming ballasts we did need to 4

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

procedure issue as well that Alex broug ht up, but 6

basically the metric that we adopted for dimming 7

ballasts in California involves performance at 100 8

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

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

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

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

was regulated in California as a function of 100 13

percent lamp arc power. 14

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

comment that DOE should strongly consider opening a 16

docket for the test procedure if it wishes to cover 17

dimming ballasts using a similar format that we did in 18

California. 19

MR. BROOKMAN: How long has that test 20

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

MR. YOUNG: So the standard was just 22

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

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

know, right now, as far as I know, we're the only ones 2518

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- 4 888 that have completed testing for those products and, 1

you know, docketed that information with the Energy 2

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

sure manufacturers have done testing of their own, but 4

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

one set of data. 6

MR. BROOKMAN: Okay. Please say your name 7

for the record. 8

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

If I'm not mistaken, I think the published Title 2 0 do 10

not include the dimming procedure last year. Are you 11

guys going to publish it later? Pretty soon or 12

something like that? 13

MR. YOUNG: So we docketed data with the 14

Energy Commission last year. It might have been two 15

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

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

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

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

Ernest o

. 20

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

the document, but what I'm saying is in the Title 2 0

, 22

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

California Energy Commission website, Title 2 0 is not 24

there. 2519

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- 4 888 MR. YOUNG: I see. 1

MR. BROOKMAN: Yeah. Okay. Alex 2

Boesenburg. 3

MR. BOESENBURG: Alex Boesenburg, NEMA. 4

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

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

clears up any possible confusion. The rulemaking 7

process for Title 2 0 for dimming ballasts concluded in 8

May of this year when the Commission adopted the 15

- 9

day language. Right now the only existing guidance is 10

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

not yet published an updated Title 2 0 reflecting those 12

changes yet. They made a recent public ation which got 13

some people excited because they thought oh, now the 14

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

get the water

- related changes from the previous 16

rulemaking implemented immediately due to their 17

crisis. 18

The process has yet to fini sh percolating 19

through to fully update Title 20 to include dimming 20

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

that means that Daniel's data from the proposal 22

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

ballast using the recommended cod e changes. Because 24

it's not implemented, it follows my members have not 2520

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- 4 888 been testing their products to it, it follows that the 1

CEC compliance certification database doesn't have any 2

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

MR. BROOKMAN: Okay. And will you confirm 4

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

effective date for the new test procedure? 6

MR. BOESENBURG: Ken Ryder is honchoing that 7

one. He did not have a date to

-- 8

MR. BROOKMAN: Oh, curious. Interesting. 9

MR. BOESENBURG : Just that it's

-- 10

MR. BROOKMAN: Okay. 11

MR. BOESENBURG: They're more concerned 12

about water right now. 13

MR. BROOKMAN: Yeah. Understandable. 14

MR. BOESENBURG: So everything's getting the 15

attention of water

- related first. 16

MR. BROOKMAN: Okay. So final comments on 17

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

-- 18

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

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

procedure, but any other additional comments on the 21

test procedure as well? 22

(No response .) 23

MR. BROOKMAN: Wanted to make sure we 24

covered that. Yes? Okay? We're all set. We're 2521

Heritage Reporting Corporation (202) 628

- 4 888 moving on. 1

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

scope of coverage for this rulemaking. So the scope 3

of coverage includes any device that meets the 4

defini tion of fluorescent lamp ballasts. However, as 5

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

covered ballasts are currently or plan to be subject 7

to standards. 8

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

a device which is used to start and oper ate 10

fluorescent lamp by providing a starting voltage and 11

current and limiting the current during normal 12

operations. The definition of fluorescent lamp starts 13

to narrow the scope. It includes 4

- foot medium bi

- pin 14

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

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

several others. 17

So, of the covered ballasts, only some are 18

currently subject to standards. These include 19

ballasts that operate at or between 120 and 277 volts 20

and operate lamps that meet the definition of 21

fluorescent lamp. 22

However, there are three categories of 23

ballasts that are not subject to standards, and those 24

are, in general, dimming ballasts are not required to 2522

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- 4 888 comply with standards, although ballasts that operate 1

certain reduced wattage T12 lamps are included, and 2

that dates back to the standards directly prescribed 3

by Congress in 2005. 4

Low frequency or magnetic ballasts designed 5

to operate T8 lamps in EMI

- sensitive environments in 6

packages containing 10 or fewer ballasts are no t 7

included. And very low ballast factor programmed 8

start ballasts that operate T8 medium bi

- pin lamps are 9

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

discuss further, DOE is planning to analyze standards 11

for the first and the third category I just me ntioned. 12

In order to propose and adopt standards for 13

ballasts DOE must find that standards would result in 14

significant conservation of energy and also be 15

technologically feasible and economically justified. 16

So at this time DOE plans to consider analyzin g 17

standards for dimming ballasts, low ballast factor 18

programmed start ballasts, and ballasts operating at 19

480 volts. However, magnetic ballasts that operate T8 20

lamps in EMI

- sensitive environments will not be 21

considered. 22

So let's discuss the justificatio n for 23

dimming ballast standards. In recent general service 24

fluorescent lamp rulemaking, DOE determined that about 2523

Heritage Reporting Corporation (202) 628

- 4 888 8 percent of GSFLs are now operated by dimming 1

ballasts. This represents growth in dimming ballast 2

sales since publication of 2011 ballast r ule. So 3

based on the increase in sales of dimming ballasts DOE 4

plans to analyze the technological feasibility, 5

economical justification, and potential for energy 6

savings for dimming ballasts. 7

I know we've already talked about it a 8

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

dimming ballast approach. 10

MR. BROOKMAN: Daniel? 11

MR. YOUNG: Daniel Young, California IOUs. 12

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

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

impact on the dimming bal last market in the state. So 15

the current code essentially states that almost any 16

application right now for new construction if you're 17

putting in a fluorescent lamp needs to be dimmable to 18

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

would make, yo u know, according to the code almost 20

close to 100 percent essentially of ballasts

-- excuse 21

me

-- lamps in, fluorescent lamps in California that 22

are operated with a dimming ballast. 23

And so some of that actually applies to the 24

retrofit market as well. It 's to a lesser extent, but 2524

Heritage Reporting Corporation (202) 628

- 4 888 we think a lot of the retrofit market as well will be 1

switching to dimming ballasts in California. 2

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

market, retrofit market for dimming ballasts? Yeah. 4

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

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

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

kind of impacts the market differently, and so we 8

think

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

there's a lot more dimming ballasts bei ng installed 10

now than there were before the code. 11

MR. BROOKMAN: Thank you. Charlie Stephens? 12

MR. STEPHENS: Yeah. Charlie Stephens, 13

Northwest Energy Efficiency Alliance. It's highly 14

likely that in the four states of the Pacific 15

Northwest those same kinds of requirements will be in 16

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

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

densities, and it will also likely apply much more 19

often to existing buildings. 20

MR. BROOKMAN: John Cymbalsky. 21

MR. C YMBALSKY: John Cymbalsky, DOE. Can 22

the manufacturers comment on how the California market 23

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

as a whole in terms of the dimming ballasts? 2525

Heritage Reporting Corporation (202) 628

- 4 888 MR. BROOKMAN: Alex Boesenburg. 1

MR. BOESENBURG: Alex Boesen burg, NEMA. 2

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

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

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

ask them. 6

MR. BROOKMAN: Joe Howley. 7

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

retrofits did not include dimming ballasts nationwide. 9

A typical lamp ballast retrofit is just with the 10

ballast, with whatever ballast factor they want to use 11

depending on the light level required, coupled with 12

the lamp. And sometimes we see controls wi th them, 13

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

retrofit. The DOE regulations in existence now cover 15

the efficiencies of those ballasts. 16

But in California there is some turmoil in 17

the retrofit market right now because of requirements 18

to go to a d imming ballast and much more advanced 19

controls. They're having discussions right now about 20

maybe if they want to adjust that because some 21

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

retrofit market because of all the advanced controls 23

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

be played out. There's some proposed solutions to 2526

Heritage Reporting Corporation (202) 628

- 4 888 that that actually just came out fairly recently. 1

MR. BROOKMAN: John Cymbalsky. 2

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

Can you define what you mean by negative effect? 4

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

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

relaying some of the comments I read

-- oh, maybe Alex 7

can talk about some comments. 8

MR. BOESENBURG: Alex Boesenburg, NEMA. I 9

read th rough the entire docket for that trying to find 10

a set of comments that were never logged that I 11

needed. But the issue is that the current code 12

requires that when light fixtures are replaced en 13

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

upgrade s, that they include lighting controls as part 15

of the requirement, which is also current code 16

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

install controls. They could just do lamp and ballast 18

replacement. Some folks argued at the time that that 19

wou ld impact their small, family business type stuff. 20

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

companies did go out of business. 22

And now the current code proposal is to 23

relax that with a mixture of either controls 24

requirements or that the luminaire s that go in must be 2527

Heritage Reporting Corporation (202) 628

- 4 888 X percent, you know, double digit percentages more 1

efficient than what came out. And as Joe Howley 2

noted, that's still being played out. 3

For what it's worth, NEMA supported controls 4

requirements, I mean, you know, promote controls s ales 5

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

And there were just as many comments in favor of 7

continuing controls requirements from contractors who 8

had invested in their expertise through training 9

programs and the like to understand how to do controls 10

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

competing mind set and business model in retrofitters 12

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

politically. 14

MR. BROOKMAN: Alex, when was that code 15

changed? 16

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

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

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

hair and gnashing of teeth over the subject and so 20

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

playing itself out. 22

MR. BROOKMAN: Pekka? 23

MR. HAKKARAINEN: Pekka Hakkarainen, Lutron. 24

A couple of points. The 15

- day language is now out 2528

Heritage Reporting Corporation (202) 628

- 4 888 for Title 24 and it seems that the retrofit 1

requirements have been relaxed in California, so not 2

clear what impact that is going to have to the 3

adoption of dimming ballasts in retrofit applications. 4

We'll have to see. 5

I also question whether DOE can take credit 6

for energy savings resulting from a federal dimming 7

ballast standard since California already has a 8

Title 20 dimming ballas t standard, so I'm suggesting 9

that DOE should only include energy saving projections 10

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

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

your name. 13

MR. TSAN: This is Bach Tsan from Southern 14

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

hearing on August 12 about the lighting alterations, 16

so the 15

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

August 12. 18

MR. BROOKMAN: Okay. Thanks for that. 19

Yeah. Okay. 20

MR. BOESENBURG: Alex Boesenburg. Just a 21

administ rative note. As an assistance to someone 22

who's not painfully familiar with these proceedings, 23

you're looking for changes to Section 141.0 of 24

Title 24

. 2529

Heritage Reporting Corporation (202) 628

- 4 888 MR. BROOKMAN: Thank you. Okay. That was a 1

useful conversation. Final comments here before we 2

move on? John, you're

-- no. Okay. Moving on. 3

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

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

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

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

Chris, you shoul d now be unmuted. 8

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

hear me? 10

MR. BROOKMAN: Yes. You sound good. 11

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

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

Chris Holstein with Universal Lighting. If I co uld go 14

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

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

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

the entire span of this content? 18

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

believe 3.1 talks about t he dimming in particular. 20

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

MR. HOLSTEIN: But then you also had some 22

conversation about California that I'd like to speak 23

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

noted in your document that in the research in the 2530

Heritage Reporting Corporation (202) 628

- 4 888 general service fluorescent lamp rule that I believe 1

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

of the lamps were using a dimming application. 3

I just want to caution you in that regard 4

the industry may determine that a dimmin g application 5

may not necessarily be something that is being 6

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

lot of occupancy sensors and vacancy sensors are 8

considered a controlled scenario and that is only run 9

on a standard program start ballast, whi ch is already 10

covered by the current rulemaking. 11

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

not going to speak of ours particularly on this phone 13

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

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

So specifically to California, there are regulations 16

there that push new construction to a set dim 17

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

the United States. Even though California is rather 19

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

available market. 21

And then, in reference to the retrofit 22

market in California, it did significantly decline 23

with the inclusion of the control scenario. A number 24

of retrofitters and contractors went out of business 2531

Heritage Reporting Corporation (202) 628

- 4 888 because of the increased cost of the co ntrols. 1

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

in the current Title 24 from what they consider a 3

modification in place where there is no

-- you do not 4

trigger the code if you just replace the lamps in 5

California, so a lot of retrofitters have gone to 6

strictly replacing the fluorescent lamps with a linear 7

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

retrofit market in California is significantly 9

different from what you may have imagined the last 10

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

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

Final comments right here before we move on? 13

Yes, Chris? 14

MR. GRANDA: Chris Granda, Appliance 15

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

hearing is that the future holds the distinct 17

possibility of increasing diversity in terms of types 18

of products and functionality in this product category 19

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

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

industry

- wide shift to solid state lighting as well. 22

And what we're concerned about is a 23

situation that could result where as the shift to the 24

new technology paradigm takes place with also higher 2532

Heritage Reporting Corporation (202) 628

- 4 888 cost drivers and light sources in the solid state 1

arena that we end up having a long

- lived sub

- product 2

categor y of fluorescent ballasts with enhanced 3

capability which may or may not get used but also 4

involves substantial standby losses and other energy 5

efficiencies more or less built in by the millions. 6

MR. BROOKMAN: Uh

- huh. 7

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

of this product category and hopefully the transition 9

away from fluorescent ballasts to solid

- state lighting 10

eventually because we believe that there will be 11

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

end up making it the lowest common denominator both in 13

terms of price and performance. 14

MR. BROOKMAN: Okay. Thank you. Final 15

comments here? 16

(No response.) 17

MR. BROOKMAN: Okay. 18

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

evaluate the justification for excluding from 20

standards low ballast factor 4

- foot T8 medium bi

- pin 21

program start fluorescent lamp ballasts. 22

In 2011 ballast rule, DOE found that some 23

low ballast factor program start ballasts operate 24

lamps at current below minimum ANSI standard levels, 2533

Heritage Reporting Corporation (202) 628

- 4 888 requiring cathode heating to maintain lamp life. DOE 1

found that none of the program start ballasts tested 2

during the previous rulemaking were able to meet the 3

max tech efficiency levels analyzed at the program 4

start product class. For these reasons, DOE exempted 5

these low ballast fa ctor program start ballasts from 6

standards in the previous rulemaking. 7

So we are welcoming comments on DOE's intent 8

to continue to exclude this ballast from standards and 9

would like to have any relevant shipment information. 10

MR. BROOKMAN: Yes, Chris? 11

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

one of the exemptions that particularly concerns us, 13

is the possibility for a loophole going forward for 14

one of these potentially low

- cost, durable market 15

niches for inefficient equipment. And we're very 16

interes ted to see what kind of market data might be 17

available and how the changes in sales of these 18

products happen over time. 19

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

to note. 21

Joe? Joe Howley. 22

MR. HOWLEY: It's something that industry 23

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

GE. We've supported this exemption in the past and 2534

Heritage Reporting Corporation (202) 628

- 4 888 perhaps we'll continue to do so. We need to have a 1

little more analysis on this at this point. 2

MR. BROOKMAN: Okay. Thanks, Joe. 3

Daniel? 4

MR. YOUNG: Daniel Youn g, California IOUs. 5

Just a comment here I think on the technological issue 6

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

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

that there may be some opportunity to work with data 9

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

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

using that perhaps to do something about these as 12

well. 13

MR. BROOKMAN: Okay. 14

MS. deBUTTS: Thank you. 15

MR. BROOKMAN: Thank you. 16

MS. deBUTTS: Okay. So next DOE is als o 17

considering evaluating energy conservation standards 18

for ballasts that operate at 480 volts. Currently, 19

only ballasts with input voltage at or between 120 and 20

277 volts are required to comply with standards. This 21

480 volt ballasts, including 4

- foot med ium bi

- pin T8 22

and 4

- foot standard output and high output T5, are 23

used primarily in the industrial sector. 24

So, with that, DOE welcomes comments on our 2535

Heritage Reporting Corporation (202) 628

- 4 888 proposal to set standard, analyze standards for the 1

ballasts that operate at 480 volts. 2

MR. BROOKMAN: Yes, Chris? 3

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

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

essentially a product for new construction in industry 6

at this point requiring specialized wiring I assume? 7

MR. BROOKMAN: Ernest o , please. 8

M R. E. MENDOZA: I just comment to your 9

question. This is required both in new construction 10

and also for replacement on all factories. But I 11

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

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

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

that is really small. 480 volts typically is 15

industrial where we have very big machines and other 16

things and lighting is not even a notch in what 17

matters. So I don't know. 18

MR. BROOKMAN: But you would confi rm it's 19

largely an industrial application? 20

MR. E. MENDOZA: Yeah. 21

MR. BROOKMAN: Yeah. Okay. Chris Holstein 22

has another comment. Chris, please. 23

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

back to the 140 milliamp exclusion really quickly? I 2536

Heritage Reporting Corporation (202) 628

- 4 888 just wa nted to address a comment that was made that 1

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

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

So, if you have to operate at the low 4

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

have to do from a techno logy perspective with the 6

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

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

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

things add cost to the product. 10

The market's fairly small and any increas e 11

in the efficiency that you would try to gain would 12

offset any energy savings you receive from that 13

ballast light composition. And with current resources 14

mostly devoted to solid

- state lighting, if you 15

increase the efficiency rating of those products, mos t 16

likely you'll have to compete those through the 17

market. 18

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

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

that would be helpful. 21

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

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

the current conversation

-- 24

MR. BROOKMAN: Why go ahead. Please. Yeah. 2537

Heritage Reporting Corporation (202) 628

- 4 888 Go. 1

MR. HOLSTEIN:

-- on the 480 volt. 2

MR. BROOKMAN: Uh

- huh. 3

MR. HOLSTEIN: The 480 volt market, once 4

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

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

in that environment. That environment is typically 7

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

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

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

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

the extra circuitry in order to be able to accommodate 12

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

that is small, that has added functionality within the 14

product to allow it to work in those environments and 15

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

further the increase in efficiencies. 17

And once again, this is Chris with Universal 18

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

the 140 milliamp and below low ballast factor would 20

not promote any efficiency movement on the 480 volt 21

market. 22

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

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

those in your written comments, that would be helpful. 2538

Heritage Reporting Corporation (202) 628

- 4 888 MR. HOLSTEIN: I wil l. 1

MR. BROOKMAN: Thank you. Additional 2

comments here on this subject? Joe Howley? 3

MR. HOWLEY: Yeah. Just we would support 4

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

segments that probably would not generate a lot of 6

energy savings and Chris's other point that the 7

industry is really working on solid

- state lighting 8

today. And given the nature of these products being 9

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

want to expend any time and effort redesigning these 11

types of product s for higher efficiency levels. 12

MR. BROOKMAN: Al Mendoza. 13

MR. A. MENDOZA: Al Mendoza with Southern 14

California Edison. Just wanted to make a general 15

comment in reference to NEMA's earlier comments about 16

how there is a belief that solid

- state technolo gy 17

might replace fluorescent ballast technology. 18

In California, there is at the moment a high 19

demand for LED tubes, but interestingly, customers 20

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

both non

- dim and dimming ballasts. And so that might 22

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

might actually extend, you know, the usability of 24

ballasts into the future. And so, with LED tubes 2539

Heritage Reporting Corporation (202) 628

- 4 888 being very good at dimming, then we should look at the 1

possibility of the dimming even below 50 percent. 2

MR. BROOKMAN: Okay. Joe Howley. 3

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

view that as a short

- term situation in the market 5

right now. It depends how you define short

- term. But 6

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

that are designe d for fluorescent. They're not 8

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

term being designed to try to operate on the 10

fluorescent systems. But long term we would expect 11

these systems to switch over to dedicated LED systems. 12

So what you're seeing I think is a short

- term 13

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

more years as the market transitions to LED. 15

MR. BROOKMAN: In the commercial sector you 16

presume there's this change

- out of lighting systems 17

every 10, 15 years? Yeah? Okay. 18

MR. HOWLEY: Exactly. So the next cycle 19

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

the meantime, though, you'll have this kind of short

21

term retrofitting going on. 22

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

MR. A. MENDOZA: Yeah. You're proba bly 24

right about that, but also what we're seeing is that 2540

Heritage Reporting Corporation (202) 628

- 4 888 customers, you know, they're looking for an 1

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

want to spend the money in replacing the entire 3

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

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

lamps. 6

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

Yes? Charlie Stephens? 8

MR. STEPHENS: Charlie Stephens. I think we 9

can

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

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

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

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

most of those products are magnetically ballasted 14

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

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

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

think we can count on these things being there for 18

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

economy supporting a lot of expensive retrofits 20

anytime soon. 21

MR. BROOKMAN: Charlie, are magnetic 22

ballasts available in the market? 23

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

you know, longer than the lamps typically. So, you 2541

Heritage Reporting Corporation (202) 628

- 4 888 know, you can change the lamps several times with one 1

ballast, unless it's in an environment that it t axes 2

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

of them still out there. 4

MR. BROOKMAN: Okay. 5

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

week. 7

MR. BROOKMAN: Okay. So final comments here 8

to Joe Howley. 9

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

electromagnetic ballasts in a typical operating 11

application probably has a 20

- year life. So 20 years 12

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

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

operate in cooler environments, so they last a little 15

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

trailing edge of those systems. They will eventually 17

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

MR. BROOKMAN: Pekka? 19

MR. HAKKARAINEN: Interesting discussion, 20

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

shows that fluorescent lamp shipments are declining at 22

an accelerating rate and DOE's regulations can only 23

affect shipments. 24

MR. BROOKMAN: Okay. Thank you. Final 2542

Heritage Reporting Corporation (202) 628

- 4 888 comments here? We're about to move on. 1

(No response.) 2

MR. BROOKMAN: Okay. 3

MS. deBUTTS: Well, since we started talking 4

about magnetic ballasts, so as we remember, the 5

electronic ballast technology was needed to meet the 6

standards for the 2011 final rule. However, DOE 7

exempted ballasts for EMI

- sensitive envir onments 8

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

best mitigated by the magnetic ballast technology. 10

These safety concerns still exist, and 11

therefore, DOE plans to continue excluding these 12

magnetic T8 fluorescent lamp ballasts from 13

considerat ion for standards in this rulemaking. We 14

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

MR. BROOKMAN: Chris? 16

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

extent that there continues to be concern about 18

electromagnetic interference from any technology , the 19

exclusion seems to make sense. I think our concern 20

is, one, how broadly EMI

- sensitive environments are 21

defined; first of all, where the administrative 22

authority to do that lies and whether the FCC has 23

regulatory jurisdiction there; and then finally, also 24

just the method of sales and shipments to try and 2543

Heritage Reporting Corporation (202) 628

- 4 888 restrict leakage of EMI

- labeled product into other 1

applications. 2

MS. deBUTTS: Okay. Thank you. 3

MR. BROOKMAN: Joe Howley. 4

MR. HOWLEY: Joe Howley. Just industry 5

would still strongly support t his exemption. It's 6

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

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

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

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

Thank you. 11

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

follow on? 13

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

say that this is exactly the kind of situation that 15

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

currently very low sales balloons into something much 17

larger to fill a deman d for a low cost, primarily 18

retrofit product. 19

MR. BROOKMAN: Okay. Ernest o ? 20

MR. E. MENDOZA: Two comments to address 21

Chris comments. One, for purposes of electromagnetic 22

sensitive areas, those are very specific customers, 23

nuclear power plants and mil itary bases. They make 24

very clear the statement in their request that they 2544

Heritage Reporting Corporation (202) 628

- 4 888 have EMI sensitivity that need to be addressed. 1

And surprising as it is, because all the 2

changes with LED and the cost of electronics, now 3

magnetics is not anymore a cheap soluti on. It tend s 4

to be more expensive as the production has been 5

dropping down. It is becoming actually a premium 6

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

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

happen because price. 9

MR. BROOKMAN: Yes, Chris? 10

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

a follow

- up question. My understanding was that the 12

characteristic of the ballasts that made it low EMI 13

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

solid

- state low frequency ballasts that are developed 15

to satisfy this market niche? 16

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

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

drivers today are accommodated power supplies anyway, 19

so for all of these markets the best solution today 20

remains t o be magnetic ballast. Future may change, 21

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

MR. BROOKMAN: Additional comments? 23

(No response.) 24

MR. BROOKMAN: Okay. 2545

Heritage Reporting Corporation (202) 628

- 4 888 MS. deBUTTS: And the last issue on the 1

scope of coverage

. W e would like to w elcome comments 2

on additional fluorescent lamp ballasts that we may 3

not have discussed here and, you know, market 4

information or shipment information that you can 5

provide that would contribute to the rulemaking. That 6

would be more than welcome. 7

MR. BROO KMAN: So this would be the catch

8

all category. Any other information that you think at 9

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

hear about that now. 11

MR. HOLSTEIN: This is Chris Holstein on the 12

phone from Universal Lighting Technologies. 13

MR. BROOKMAN: Yes, Chris? 14

MR. HOLSTEIN: I just wanted to state that 15

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

effort is on solid

- state lighting. After the last DOE 17

ruling on linear fluorescent lamp ballasts that was 18

just effective in November, that pretty much has 19

whittled the market down to where everybody is the 20

same. The efficiency levels were compressed so much 21

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

point everybody's going to use solid

- state lighting 23

from a manufacturer's persp ective, as well as the 24

customer's, so I don't see any reason to look for any 2546

Heritage Reporting Corporation (202) 628

- 4 888 other products in this particular category. Nothing 1

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

years trying to get our products in line with have 3

measured that. 4

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

Other comments? 6

(No response.) 7

MR. BROOKMAN: Nothing additional. 8

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

be Rachel Dickenson presenting market and technology 10

assessment and screening analysis. 11

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

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

discuss the market and technology assessment and 14

screening analysis. 15

So one of the main elements of the market 16

and technology assessment is establishing product 17

classes. DOE divides covered products into classes by 18

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

or any other performance related features that require 20

different standard levels, such as features affecting 21

consumer utility. DOE then establishes separate 22

en ergy conservation standards for each product class. 23

DOE is considering maintaining the product 24

classes for ballasts currently subject to standards. 2547

Heritage Reporting Corporation (202) 628

- 4 888 This table shows the current product classes for 1

fluorescent lamp ballasts. The product classes are 2

curr ently divided based on starting method, lumen 3

package, sign ballast, and residential versus 4

commercial. Additional product classes may be needed 5

if DOE considers standards for additional categories 6

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

consideri ng analyzing standards for additional dimming 8

fluorescent lamp ballasts given their market growth. 9

If standards are considered for these 10

additional dimming ballasts, DOE may consider 11

establishing separate product classes for them with 12

such factors as res idential versus commercial lamp 13

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

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

dimming control; or standardized control interfaces, 16

such as the digitally addressable lighting interface. 17

So DOE h as three requests for comment on the 18

fluorescent lamp ballast product classes. First, DOE 19

welcomes comment on the product class divisions it is 20

considering for fluorescent lamp ballasts. In 21

particular, DOE welcomes comment on appropriate class

22

setting fa ctors for the dimming ballasts, the low 23

ballast factor program start ballast, and the 480 volt 24

fluorescent lamp ballasts. 2548

Heritage Reporting Corporation (202) 628

- 4 888 MR. BROOKMAN: Let's deal with that one 1

first and see if we have any comments there. 2

Daniel? 3

MR. YOUNG: Daniel Young, Californi a IOUs

. 4

So just to comment on how California dealt with the 5

dimming ballasts. So essentially we set one single 6

product class for all dimming ballasts and defined a 7

standard based as a function of measured lamp arc 8

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

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

factors that might allow for more stringent standards 11

for certain products. 12

So, for instance, we tested some T5 ballasts 13

and found that generally they seemed to be a little 14

bit more effic ient than the T8 ballasts, so that might 15

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

digitally controlled ballast. We didn't see anything 17

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

limited by just time in getting the data together and 19

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

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

a little bit closer and perhaps find an opportunity 22

there as well. 23

MR. BROOKMAN: So the question here that you 24

see for two class setting factors, low ballast and 480 2549

Heritage Reporting Corporation (202) 628

- 4 888 volt fluorescent. Comments there? Any additional 1

comments? Pekka? 2

MR. HAKKARAINEN: Pekka Hakkarainen, Lutron. 3

Just a small comment that DALI is specifically 4

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

necessarily the only protoc ol that's implemented in 6

these ballasts that require some standby power 7

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

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

Alex? 10

MR. BOESENBURG: Alex Boesenburg, NEMA. 11

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

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

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

dive into the power requirements of networked products 15

I'll just call it, a catch

- all term, some of these 16

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

mean based on the commissioning or the specific 18

functionality built into that particular design, they 19

can have varying standby and full mode power 20

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

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

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

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

coming up with one number to fit because it can be 2550

Heritage Reporting Corporation (202) 628

- 4 888 situation dependent or set by the consumer and made to 1

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

to throw that out there for consideration. 3

MR. BROOKMAN: Thank you. Charlie Stephens? 4

MR. STEPHENS: Charlie Stephens. I think I 5

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

lumina i r e level lighting control has kind o f taught us 7

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

earlier of DOE about their intentions to look at 9

network standby, because if you decide to regulate 10

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

avoid that. 12

MS. deBUTTS: Thank you for your comments. 13

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

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

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

little later. 17

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

issue boxes, Rachel. 19

MS. DICKENSON: Okay. Next DOE welcomes 20

comment on any other class

- setting factors that should 21

be considered in the analysis. 22

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

guess a question and a comment. The initial division 24

between commercial and residential classes as I 2551

Heritage Reporting Corporation (202) 628

- 4 888 understand was driven by the lower number of hours of 1

use for residential. Was it correct that that 2

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

and the incremental cost that was involved with 4

achieving a higher BLE versus that lowe r number of 5

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

MR. WALKER: Yeah. This is Matthew Walker 7

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

difference in efficiency that drove the difference. 9

The efficiency of the two products was differe nt and 10

they were used for different purposes. They had a 11

different utility. A residential ballast meets 12

different FCC EMI requirements, for example. 13

MR. GRANDA: Okay. I guess we would 14

encourage DOE to look at the sort of underlying 15

rationale for hav ing a different classification for 16

residential ballasts, and given current price trends 17

and availability of technology and the functionality 18

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

having a lower efficiency standard for the residential 20

product s is still justified. 21

MR. BROOKMAN: Okay. Charlie Stephens? 22

MR. STEPHENS: Yeah. Charlie Stephens from 23

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

that's full of commercial ballasts and that work quite 2552

Heritage Reporting Corporation (202) 628

- 4 888 well and have no obvious impact on anythi ng in the 1

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

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

material difference in application in a building 4

between these two things quite frankly. 5

MR. BROOKMAN: Yes. I saw Ernest o first. 6

MR. E. MENDOZA: Just to mention residential 7

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

stringent, and some customers are very sensitive. 9

They may have radios at home, maybe radio stations 10

now. They may have different sensitive equipment that 11

requir e this extra protection. So unfortunately we 12

have to build our products for the two different 13

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

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

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

E ven though most customers may be satisfied with the 17

commercial product, we have to do the residential and 18

include additional filtering for EMI purposes. 19

MR. BROOKMAN: Pekka? 20

MR. HAKKARAINEN: Pekka Hakkarainen, Lutron. 21

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

MR. BROOKMAN: That's some discipline for 23

you. Alex? 24

MR. BOESENBURG: Alex Boesenburg, NEMA. I 2553

Heritage Reporting Corporation (202) 628

- 4 888 would add to what Ernesto said, expand on it. In 1

terms of as this rulemaking proceeds and we get into 2

other regulatory impacts, NEM A and our compatriots to 3

the north, Electrofed Canada, have been in discussions 4

with FCC and Industry Canada for the past 18 months 5

regarding revisions to emissions requirements for 6

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

conversation, but we expect to enter into binational 8

negotiations and study into what is the appropriate 9

emissions limit. It's mostly about factoring in 10

solid

- state lighting appropriately, but Industry 11

Canada for one want to revise all of the lighting 12

requirements or at leas t relook, and so we've been 13

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

binational atmosphere. 15

That will take a few years, but if this 16

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

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

what we kn ow about or what we expect to happen in 19

terms of North American emissions requirements. And 20

as Ernesto

-- my tie

- in to Ernesto's statement is if 21

emissions requirements become more stringent across 22

the board, that added functionality and filtering will 23

cau se impacts on price and also impacts on efficiency. 24

But we can't tell you where it's going yet today. 2554

Heritage Reporting Corporation (202) 628

- 4 888 MR. BROOKMAN: Okay. Let's queue market 1

assessment. 2

MS. DICKENSON: Okay. Now for this catch

3

all comment request, DOE welcomes information on the 4

sh ipments, product feature and efficiency trends, 5

distribution channels, and estimates of market shares 6

for ballasts considered in this rulemaking. 7

MR. BROOKMAN: Daniel? 8

MR. YOUNG: Daniel Young, California IOUs. 9

Again, a comment on dimming ballast eff iciency trends. 10

So I think maybe this goes without saying at this 11

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

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

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

that are similarly efficient at 10 0 percent, but when 15

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

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

anywhere in between 50 percent and 100 percent. They 18

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

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

so just to highlight the need to evaluate their 21

efficiency throughout the dimming range and not just 22

at 100 percent, which again would require a separate 23

test procedure or an amended test procedure. 24

MR. BROOKMAN: Okay. Tha nks. Yes? 2555

Heritage Reporting Corporation (202) 628

- 4 888 Rebecca? 1

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

would not want to go into details on shipments or 3

product features or distribution channels in this 4

meeting, but I would welcome a manufacturer's 5

interview at any of our facilities in the States. 6

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

as a natural follow

- on, please. 8

MR. BOESENBURG: Alex Boesenburg, NEMA. I 9

alluded to NEMA shipments information in my opening 10

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

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

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

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

We'll provide as much as we can. 15

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

MR. E. MENDOZA: Just seconding my 17

colle agues, just to make it very dramatic. We used to 18

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

MR. BROOKMAN: Thank you. Rebecca? 20

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

clarify something. My company does not manufacture 22

ballasts. We are a l uminaire manufacturer that 23

actually uses these components. 24

MR. BROOKMAN: Yeah. Thanks. 2556

Heritage Reporting Corporation (202) 628

- 4 888 MR. HOLSTEIN: Yes. This is Chris Holstein 1

on the line with Universal Lighting Technologies. 2

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

from the manuf acturer interviews that we've done in 4

the past, and I will include some shipment information 5

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

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

ballast factories, and today we operate one. 8

MR. BROOKMAN: Oka y. Thank you. 9

This is a catch

- all category. You can see 10

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

efficiency trends, distribution channels, estimates of 12

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

Any additional final comments befor e we move on? 14

(No response.) 15

MR. BROOKMAN: Okay. 16

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

discussing the technology options that improve the 18

energy efficiency of the product. So, in this 19

instance, options that improve the ballast luminous 20

efficiency or BLE. The table on this and the 21

following slide provides the preliminary list of 22

technology options DOE has identified. 23

For example, on this slide, an improved 24

circuit design, one technology option is to substitute 2557

Heritage Reporting Corporation (202) 628

- 4 888 discrete components with an integra ted circuit. 1

And on this slide for using improved 2

components, one technology option is using diodes with 3

lower losses. 4

It should be noted that DOE is aware that 5

moving from magnetic ballasts to electronic ballasts 6

or changing the starting method from r apid start to 7

instant start improves the BLE, but DOE does not 8

expect these changes to continue to be viable 9

technology options for this rulemaking given that due 10

to market trends and DOE energy conservation standards 11

the magnetic ballasts and rapid start ballasts are no 12

longer sold for the categories of ballasts under 13

consideration for standards. 14

So, in Issue 4.4, DOE welcomes comment on 15

the preliminary technology options identified in this 16

section and DOE welcomes comment on whether there are 17

additional technology options that it should consider. 18

MR. BROOKMAN: Daniel? 19

MR. YOUNG: Daniel Young, California IOUs. 20

So, again for dimming ballasts we found that cathode 21

cutout and I guess better performing cathode cutout 22

made a big difference on ballast eff iciency, and so 23

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

docket, but just stating that for the record. 2558

Heritage Reporting Corporation (202) 628

- 4 888 MR. BROOKMAN: Thank you. Ernesto? 1

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

comments in the document are well known by the 3

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

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

know about using cool transistors and lower impedance 6

values and capacitors. 7

I honestly believe that the fluorescent 8

ballast technology supplies maximum today. To g o to a 9

higher level of technology we need to reinvest in 10

completely different technology, and I think the 11

industry is invested in doing better LED lighting as 12

opposed to trying to redefine the use for fluorescent. 13

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

treatment of fluorescent lamps and therefore ballasts 15

is still decaying very fast. 16

MR. BROOKMAN: Okay. Alex? 17

MR. BOESENBURG: Alex Boesenburg, NEMA. I 18

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

cutout. As we commented to the California rulemaking 20

proceedings and will comment to the DOE proceeding, 21

cathode cutout is an intellectual property heavy area, 22

and one manufacturer took out a patent regarding their 23

treatment of cathode cutout, so someone else wanting 24

to also sell dimmi ng ballasts or a ballast that 2559

Heritage Reporting Corporation (202) 628

- 4 888 employs cathode cutout came up with a different way to 1

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

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

must exercise caution favoring one over another 4

inadvertently, a nd that's where the DOE's analysis 5

will want to be focused and carefully consider all 6

that. 7

Another point made in California and I'll 8

refer the DOE to is that filament heat sometimes is 9

done very conservatively on purpose to help prolong 10

lamp life, parti cularly in the field when you see 11

combinations between different manufacturers' 12

products. The manufacturer of the fluorescent lamps 13

differ from the manufacturer of the ballast. So some 14

ballast manufacturers who are targeting, who don't 15

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

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

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

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

additional performance features such as that, so to 20

focus strictl y on efficiency you lose sight of things 21

like that. 22

MR. BROOKMAN: Yes, Daniel? 23

MR. YOUNG: Daniel Young, California IOUs. 24

Just to briefly respond to that, I think, Alex, you're 2560

Heritage Reporting Corporation (202) 628

- 4 888 talking about the LL

- 9 document that kind of defines 1

the band of "accepta ble" cathode heating for lamps and 2

ballasts to work well together. 3

So we looked at that standard and made some 4

concerted assumptions and we came up with a band of 5

about 5.6 watts per lamp of kind of allowable cathode 6

heating between what you should be us ing and what you 7

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

full range I guess of achievable efficiency that's 9

defined within that document, certainly recognizing 10

that not all manufacturers have access to every piece 11

of technology that would allow you to get from the 12

best to the worst or vice versa rather. But 13

nonetheless there is quite some wiggle room there that 14

we think that can lead to significant savings. 15

And so just for a little bit of context, 16

when we developed the California standards, we did 17

come up with levels that all the major manufacturers 18

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

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

significant number of manufacturers to only allow the 21

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

And also just to highlight that the standard 23

in California rather is not

-- there's no prescriptive 24

requirement for cathode heating. That's just the one 2561

Heritage Reporting Corporation (202) 628

- 4 888 technology option that we saw as kind of an immediate 1

opportunity that had a pretty significant i mpact on 2

energy use. 3

MR. BROOKMAN: Okay. Ernesto? 4

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

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

limiting technologies. We have a ballast that the 7

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

gad get because the first thing that it do, the 9

ballast, is look at the filament impedance of the 10

specific lamp and then it adjusts the cathode heating 11

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

other factors. But of course to have this 13

intelligence bu ilt in there isn't energy consumption. 14

So this type of advanced technology will be actually 15

restricted because it consumes more energy than a 16

regular dimming ballast. So these are type of 17

considerations I guess when we go to the classes that 18

we may consi der into. 19

MR. BROOKMAN: Okay. Pekka? 20

MR. HAKKARAINEN: Pekka Hakkarainen, Lutron. 21

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

and look at the California building code requirement 23

for the use of dimming ballasts. That building code 24

require ment does not currently exist in the rest of 2562

Heritage Reporting Corporation (202) 628

- 4 888 the country, so if anything is going to drive dimming 1

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

and California already has adopted a dimming ballast 3

standard. So I question the need for having any o ther 4

standard, any stricter standard than that considered 5

because none of us are going to make just California 6

only dimming ballasts or rather specifically for the 7

California market and separate products for the rest 8

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

the overall declining fluorescent market. 10

MR. BROOKMAN: Okay. Okay. Additional 11

comments here? 12

(No response.) 13

MR. BROOKMAN: Okey doke. 14

MS. DICKENSON: So for the screening 15

analysis, DOE will screen out technology options based 16

on four criteria. DOE will look at first the 17

technological feasibility, that is, whether the 18

technology is commercially available or in a working 19

prototype; second, the practicability to manufacture, 20

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

achieve mass production and reliable installation and 22

servicing of a technology in commercial products on a 23

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

does not have adverse impacts on utility to consumers 2563

Heritage Reporting Corporation (202) 628

- 4 888 or availability; and four, that it does not have 1

adverse impacts on health or safety. 2

Those technology options not screened out by 3

these four criteria are called design options and are 4

considered as possible methods of improving efficiency 5

in the engineering analysis. 6

In the 2011 ballast rule, DOE sc reened out 7

using laminated sheets of amorphous steel to create 8

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

ballast failing to be practical to manufacture, 10

install, and service and has adverse impacts on 11

product utility. DOE will consider screen ing out the 12

use of laminate sheets of amorphous steel in this 13

rulemaking, consistent with the screening analysis of 14

the 2011 ballast rule. 15

And in Issue 5.1, DOE welcomes comment on 16

the applicability of the four screening criteria to 17

the technology option s described in this section, 18

including whether it will still be appropriate to 19

screen out the use of laminated sheets of amorphous 20

steel. 21

MR. BROOKMAN: And 5.2? 22

MS. DICKENSON: In 5.2, DOE welcomes comment 23

on how the screening criteria will apply to a ny 24

additional technology options. 2564

Heritage Reporting Corporation (202) 628

- 4 888 (Pause.) 1

MR. BROOKMAN: We need a comment on 2

amorphous steel for sure. 3

(Laughter.) 4

MR. BROOKMAN: Ernesto? 5

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

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

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

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

stick with amorphous for magnetic ballasts. 10

For electronic ballasts, kind of a moot 11

discussion I guess. 12

MR. BROOKMAN: Okay. Additional comments, 13

screening factor s and applicability to technology 14

options? Joe? Joe Howley. 15

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

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

specific question to screen out amorphous steel for 18

these products. 19

MR. BROOKMAN: Thanks for the clarity. 20

MR. HOWLEY: Sure. 21

MR. BROOKMAN: Yeah. Okay. Final comments 22

here on these two? 23

(No response.) 24

MR. BROOKMAN: Let's take a break. We're 2565

Heritage Reporting Corporation (202) 628

- 4 888 really making good progress here. I really appreciate 1

the quality of the comment, really excellent

. 2

Everybody's really on their game today. Much 3

appreciated on a Friday morning. 4

Ten twenty now by the clock on the wall. 5

Let's take a 15

- minute break. 6

(Whereupon, a brief recess was taken.) 7

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

from Rachel. 9

M S. DICKENSON: Okay. Now we will discuss 10

the engineering analysis. And this slide shows step 11

by step the general methodology DOE plans to use for 12

the engineering analysis. 13

The first step is to choose the 14

representative product classes. DOE then select s 15

baseline ballasts for each representative product 16

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

baseline ballast DOE identifies more efficient 18

substitutes based on design options determined in the 19

screening analysis. DOE then develops efficiency 20

levels that range from the baseline to the maximum 21

technologically feasible efficiencies. DOE scales 22

these results to the non

- representative product 23

classes, which are the product classes that were not 24

directly analyzed. Finally, DOE determines the 2566

Heritage Reporting Corporation (202) 628

- 4 888 relat ionship between BLE and end user price. The 1

results of these analyses are also used downstream for 2

the life

- cycle cost analysis, the national impact 3

analysis, and the manufacturer impact analysis. 4

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

little more de tail. So, as mentioned, DOE will not 6

analyze every product class. Instead it will choose 7

representative product classes on which it will focus 8

its analytical efforts, and these are typically chosen 9

based on high market volume. 10

The next step is selectin g a baseline 11

ballast for each representative product class. The 12

baseline ballast is what DOE believes to be the most 13

common, least efficient ballast within each 14

representative product class. For products that do 15

not have existing standards, DOE plans to select the 16

most common least efficient ballast. For products 17

that have standards, DOE plans to select the most 18

common, least efficient ballast that just meets those 19

standards. 20

So, in Issue 6.1, DOE welcomes comment on 21

the appropriate baseline for ballas ts already subject 22

to standards. 23

MR. BROOKMAN: Ernesto? 24

MR. E. MENDOZA: Maybe just to say the 2567

Heritage Reporting Corporation (202) 628

- 4 888 obvious. If there is a rule, it cannot exceed the 1

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

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

think that's correct. 4

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

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

assumed in a record establishing matter like this. 7

Joe Howley? 8

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

thing maybe as we're statin g obvious points is that 10

the last ballast rulemaking was very aggressive. So 11

for the ballasts that are regulated right now, they 12

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

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

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

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

everything to LED technology. So your regulated 17

product technologies are sort of your minimum and 18

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

regulated catego ry right now. 20

MR. BROOKMAN: Anything additional here? 21

(No response.) 22

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

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

DOE analyze standards for the new categories of 2568

Heritage Reporting Corporation (202) 628

- 4 888 ballasts, including the additional dimming, t he low 1

ballast factor program start, or the 480 volt 2

fluorescent lamp ballast? DOE welcomes comment on the 3

appropriate baseline ballast types and efficiency 4

values in those categories. 5

MR. BROOKMAN: Charlie Stephens. 6

MR. STEPHENS: To go with Joe's o bvious 7

comments again. 8

MR. BROOKMAN: You understand what I'm 9

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

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

going. 12

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

going to consider looking at dimm ing ballasts, the 14

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

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

decide how efficient they are. So I would suggest 17

that early on you need to make the decision about 18

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

ballasts. 20

MR. BROOKMAN: Okay. Additional comments? 21

Yes, Daniel. 22

MR. YOUNG: Daniel Young, California IOUs. 23

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

from there if you do decide to take a serious look at 2569

Heritage Reporting Corporation (202) 628

- 4 888 dimming ball asts is to take a serious look at what 1

California did on dimming ballasts and consider that 2

not just for the test procedure but also perhaps as 3

the baseline product. 4

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

move on I think. 6

MS. DICKENSON: So DOE wi ll select a higher 7

efficiency replacement for each baseline ballast by 8

considering technologies not eliminated in the 9

screening analysis. DOE plans to consider the lamp 10

and ballast system to account for total system energy 11

consumption and system light out put. To identify 12

replacements, DOE plans to utilize a database of 13

commercially available ballasts and BLE compliance 14

data in the Compliance Certification Management 15

System. 16

After identifying the more efficient 17

substitutes for each baseline ballast, DOE develops 18

efficiency levels based on three factors: first, the 19

design options associated with the specific ballast; 20

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

efficiency level of a given product class across 22

wattages; and three, the maximum techn ologically 23

feasible efficiency level or max tech. 24

DOE anticipates developing efficiency levels 2570

Heritage Reporting Corporation (202) 628

- 4 888 using an equation that relates the total lamp arc 1

power operated by a ballast to the BLE. 2

So, in Issue 6.3, DOE welcomes comment on 3

the methodology it is con sidering to select the higher 4

efficiency ballast designs. 5

And Issue 6.4, DOE welcomes comment on its 6

proposed methodology of establishing efficiency 7

levels, including the form of an equation that relates 8

the average total lamp arc power to the BLE. 9

And Issue 6.5, DOE welcomes comment on the 10

use of compliance data when establishing the 11

efficiency levels. 12

MR. HOLSTEIN: Yeah. This is Chris Holstein 13

from Universal Lighting Technologies. Just quickly, 14

in your framework document, this is relevant to Issu e 15

6

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

modeling, and we would like to caution against turning 17

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

in the magnetic HIB ruling as well where the 19

efficiency levels were modeled into an 20

unmanufact urable product. So we know from experience 21

that this does not always equate to something that can 22

be manufactured at a high quality manufacturing 23

facility. I just want to caution against that. 24

MR. BROOKMAN: Chris, if you could put those 2571

Heritage Reporting Corporation (202) 628

- 4 888 comments in wr iting, particularly the limitations 1

lessons that came from that earlier modeling 2

experience, I think that would be useful. 3

Okay. Additional? Yes. Chris? 4

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

technical question I guess. With the point that DOE 6

an alyzes lamp and ballast system to account for total 7

system energy consumption, system light output, is 8

that with a referenced lamp or with the ballast 9

manufacturer's specified lamp? Particularly if the 10

ballast manufacturer is also a lamp manufacturer. 11

M R. WALKER: This is Matthew Walker of 12

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

be based

-- this is not based on any one particular 14

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

reference lamp. You know, if the ballast has a 0 .88 16

ballast fa ctor, then the lamp watts would be changed 17

accordingly. It really just means that in this 18

rulemaking we're going to account for the ballast 19

losses associated with the ballast as well as the 20

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

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

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

talking about the way the energy will be accounted 24

for. 2572

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- 4 888 MR. GRANDA: We would encourage the use of 1

reference lamp. 2

MR. BROOKMAN: Okay. Daniel? 3

MR. YOUNG: Daniel Young, California IOUs. 4

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

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

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

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

one

- lamp T8 ballasts, 15 two

- lamp T8 ballasts, 10 9

three

- lamp ballasts; 4 four

- lamp ballasts, and seven 10

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

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

is basically tests from 100 percent full light output 13

down to the minimum dimming level where the lamp was 14

still producing light. 15

And as another comment just on our approach, 16

you know, basically again this is highlighting that we 17

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

that's where we think the o pportunity for savings is 19

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

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

have mentioned, none according to the test procedure 22

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

performance below 100 perce nt which we think is again 24

important. And so we started with the CEE list of 2573

Heritage Reporting Corporation (202) 628

- 4 888 ballasts, which has 180 I think dimming ballasts, and 1

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

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

so you'll have t hat to look at. 4

MR. BROOKMAN: Okay. Thank you. 5

You see the three comment boxes there. 6

Additional comments related to these boxes? 7

(No response.) 8

MR. BROOKMAN: Nothing additional here? 9

Alex Boesenburg. 10

MR. BOESENBURG: I'll just make one 11

obser vation. The CEE list is also the NEMA premium 12

qualification list because we were allied with CEE at 13

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

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

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

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

encourage DOE to evaluate a more broad range of 18

product. 19

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

you. Okay. 21

MS. DICKENSON: All right. DOE will next 22

develop efficiency levels for the product classes not 23

directly analyzed by scaling from the levels 24

determined for the representative product classes. To 2574

Heritage Reporting Corporation (202) 628

- 4 888 do so, DOE plans to develop scaling factors by 1

comparing the BLE of ballasts in representative 2

product classes to the BLE of ballasts in non

3

representative product classes. 4

In Issue 6.7, DOE welcomes comment on the 5

methodology to scale energy conservation standards to 6

product classes not directly analyzed. 7

(No response.) 8

MR. BROOKMAN: No comments on scaling? 9

Okay. 10

MS. DICKENSON: Okay. In the pricing 11

analysis, DOE establishes a relationship between BLE 12

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

conduct a pricing analysis through a product tear

- down 14

cost assessment to identify the manufacturer 15

production cost. The manufactu rer production cost 16

would be marked up to the manufacturer's selling 17

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

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

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

the end user retail pri cing directly. 21

In Issue 6.6, DOE welcomes comment on the 22

pricing methodology and in particular the feasibility 23

of using product tear downs to develop the pricing. 24

MR. BROOKMAN: Daniel? 2575

Heritage Reporting Corporation (202) 628

- 4 888 MR. YOUNG: Daniel Young, California IOUs. 1

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

note that the California Energy Commission and the 3

IOUs actually used a slightly different method for 4

understanding cost

- effectiveness, both of which, you 5

know, ended up being very cost

- effective for dimming 6

ballasts. So j ust encouraging you to review both the 7

CEC methodology or the developed kind of, more similar 8

to this kind of tear down approach and the IOU 9

approach, which is more of a statistical analysis of 10

ballast price in the market. 11

MR. BROOKMAN: Okay. Good. Th anks. 12

MR. HOLSTEIN: Yeah. This is Chris Holstein 13

at Universal Lighting. We would just recommend that a 14

lot of this conversation happen in the manufacturing 15

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

open with Navigant in these conversations as well as 17

the other manufacturers in the room. 18

Tear down here, you get caught with still 19

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

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

understanding of what the costs are related to the 22

product. 23

MR. BROOKMAN: Okay. Thanks, Chris. 24

Moving on. 2576

Heritage Reporting Corporation (202) 628

- 4 888 MS. DICKENSON: Okay. In Issue 6.8, DOE 1

welcomes comment on proprietary designs it should be 2

aware of for the fluorescent lamp ballasts that are 3

subject to this rulemaking. 4

MR. BROOKMAN: Alex alread y mentioned one 5

group of these. Joe Howley, please? 6

MR. HOWLEY: Just a similar comment to 7

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

better provided during the manufacturing interviews, 9

not during this forum. 10

MR. BROOKMAN: Okay. 11

MS. DICKEN SON: In Issue 6.9, DOE welcomes 12

comment on the regulatory burdens or changes that 13

should be considered in the engineering analysis. 14

MR. BROOKMAN: Anything additional that DOE 15

is not anticipating that you see add any additional 16

burden? 17

(No response.) 18

MR. BROOKMAN: Nothing? Okay. 19

MS. DICKENSON: All right. And the final 20

issue. DOE welcomes comment on any other issues that 21

could affect the engineering analysis. 22

MR. BROOKMAN: Okay. 23

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

over to Michael Myer

. 2577

Heritage Reporting Corporation (202) 628

- 4 888 MR. MYER: Good morning. I'm Michael Myer. 1

I'm with Pacific Northwest National Laboratory, and 2

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

analyses that we will be doing using engineering 4

inputs. First up will be energy use and market 5

marku ps analysis. 6

The purpose of the energy use analysis is to 7

determine the annual energy use for all efficiency 8

levels by product class. It's a pretty 9

straightforward process, taking the input power to the 10

ballast times the operating hours and you get the 11

energy usage. We of course develop operating hours by 12

sector, whether it be residential, commercial, or 13

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

lighting market characterization, residential energy 15

consumption survey, the commercial building energy 16

consumption survey, as well as the manufacturing 17

energy consumption survey. The table below shows 18

sample operating hours for both the 2000 and the 2011 19

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

done in many other rules. 21

In addition to the energy use analysis, the 22

input power is also related to such things as reduced 23

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

second asking about the prevalence of those lamps. 2578

Heritage Reporting Corporation (202) 628

- 4 888 We've also discussed today TLEDs or tubular LEDs and 1

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

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

The first two questions or issues. Issue 4

7

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

comment on the approach DOE has taken to determine the 6

operating profiles for f luorescent lamp ballasts in 7

this rule. Further, DOE welcomes comment on whether 8

the end use operating profiles are different for the 9

various types of fluorescent ballasts under 10

consideration for standards and, if so, how. 11

MR. BROOKMAN: Joe Howley? 12

MR . HOWLEY: I think for your reduced power 13

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

pretty similar to the types of operating hours you 15

have here. 16

I think when you enter the realm of dimming 17

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

You probably have additional questions asking about 19

dimming ballasts, but dimming ballasts would most 20

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

using them, and they probably would have more frequent 22

on

- off control, operating at lower energy mode 23

c ontrol. And so it wouldn't be as straightforward as 24

just the input power times the operating hours to get 2579

Heritage Reporting Corporation (202) 628

- 4 888 energy use. It's going to be a lower energy use 1

profile, which is probably going to be difficult to 2

determine exactly, but it will be lower than ful l 3

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

these other ballast types. 5

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

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

about dimming ballasts. Thank you. 8

MR. BROOKMAN: Pekka? 9

MR. HAKKARAINEN: Nothing at the moment. 10

MR. BROOKMAN: Okay. Then the next issue 11

box? 12

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

DOE welcomes comment on the wattage of reduced wattage 14

fluorescent lamps typically installed as well as what 15

proportion of reduce wattage lamps are installed. DOE 16

also welcomes comment on the prevalence of tubular 17

LEDs operating on fluorescent lamp ballasts. 18

MR. BROOKMAN: Charlie Stephens. 19

MR. STEPHENS: Charlie Stephens from NEEA. 20

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

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

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

we have on various lamp wattages and types in the 24

course of the rulemaking. 2580

Heritage Reporting Corporation (202) 628

- 4 888 MR. BROOKMAN: Thank you. Joe Howley? 1

MR. HOWLEY: Yes. I mean, NE MA can discuss 2

this as well in terms of reduced wattage versus full 3

wattage lamps. I will mention that on dimming systems 4

often full wattage lamps are used because they dim the 5

best due to various technical reasons, and it provides 6

a more fuller range fro m high light output to low 7

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

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

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

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

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

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

The reduced current ballasts may or may not 14

be paired with a reduced wattage lamp. It just 15

depends on exactly what the light output is that 16

they're trying to achie ve with that system. 17

And then tubular LEDs I guess is your last 18

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

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

mentioned by a few others just recently here in the 21

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

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

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

is increasing at this time. 2581

Heritage Reporting Corporation (202) 628

- 4 888 MR. BROOKMAN: Okay. Thank you. 1

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

10 percent, less than 5 pe rcent? 3

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

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

range at this point. 6

MR. MYER: And then this goes back to 7

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

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

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

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

speculate on what the typical wattage of the tubular 12

LEDs or anyone else submitting data. It would be 13

appreciated. 14

MR. BROO KMAN: Al Mendoza? 15

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

collecting data on LED tubes on fluorescent ballasts. 17

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

happy to share the data when it comes. 19

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

availabl e? 21

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

available later this year. 23

MR. BROOKMAN: Okay. 24

MR. A. MENDOZA: But we can take a look at 2582

Heritage Reporting Corporation (202) 628

- 4 888 the

-- we can analyze the current data we have and 1

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

this. 3

MR. BROOKMAN: Great. Ernesto? 4

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

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

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

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

LEDs are still evo lving, so for the same light output 9

package we just keep reducing wattage almost every 10

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

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

are dropping down very fast. 13

MR. BROOKMAN: Okay. 14

MR. HOL STEIN: Yeah. This is Chris Holstein 15

with Universal Lighting on the phone. 16

MR. BROOKMAN: Yeah. 17

MR. HOLSTEIN: Just to address both of these 18

as well. Back to the comments of the other 19

manufacturers, to bring this back to the ballast part 20

of the rulem aking, the usage of reduced wattage lamps, 21

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

dimming range, but these are the first and easiest 23

step from an energy efficiency move in the market. 24

Be aware that the ballasts that are in these 2583

Heritage Reporting Corporation (202) 628

- 4 888 lamps have to have added circuitry to be able to run 1

them successfully. They have to be able to correct 2

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

shaking I guess from a light perspective. OCVs are 4

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

be adde d to the ballasts allowed to run these lamps 6

on. 7

And then in the market of TLEDs, the tubular 8

LEDs, be aware that the ballasts were never designed 9

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

by UL for the lamp manufacturers to certify the 11

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

what the primary application is relevant to the UL 13

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

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

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

mind as well. 17

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

Ernesto? 19

MR. E. MENDOZA: One practical comment or 20

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

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

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

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

difficult for us to report. We will be able to report 2584

Heritage Reporting Corporation (202) 628

- 4 888 for the 32 watt T8, which is what we design, but we 1

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

if so, which ones you want us t o report. 3

I think for practical purposes even though 4

something is happening in the marketplace, we not 5

necessarily recommend a fluorescent ballast to be 6

paired with TLEDs. So practically, for reporting, 7

will be a difficulty. 8

MR. BROOKMAN: Yes. Pekka ? 9

MR. HAKKARAINEN: Pekka Hakkarainen from 10

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

understanding the relevance of this point for the 12

rulemaking because TLEDs would normally be used with 13

ballasts that are already installed, which the 14

rulemaking can not affect. So other than trying to 15

figure out some market share of products that are 16

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

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

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

fluorescent ballast in a new system. They would be 20

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

sure that I understand this whole point. 22

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

comment's useful. 24

Final comments here? 2585

Heritage Reporting Corporation (202) 628

- 4 888 (No response.) 1

MR. MYER: Moving on. The previous 2011 2

rule also included a portion for occupancy sensors. 3

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

rule. So the idea is that occupancy sensors reduce 5

the overall operating hours of the fluorescent 6

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

assigned that they were only used in the commercial 8

application and it reduced them from roughly about 9

3700 hours to in this case about 2700 hours. 10

At this time, for Issue 7.3, DOE welcomes 11

comment on the typical space types operat ed by 12

occupancy sensors. Also DOE welcomes any data on the 13

energy savings related to the use of occupancy 14

sensors. DOE welcomes data on the proportion of 15

fluorescent ballasts used with occupancy sensors. And 16

DOE welcomes any data on the effects of occup ancy 17

sensor use on the operating profiles for fluorescent 18

lamp ballasts in this rule. 19

(No response.) 20

MR. BROOKMAN: Nothing here. Okay. 21

MR. MYER: Continuing on to the issues. 22

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

welcomes comment o n the use of dimming ballasts, the 24

types of ballasts and the type of lamps typically 2586

Heritage Reporting Corporation (202) 628

- 4 888 dimmed, applications in which dimming occurs, and the 1

output setting of the dim ballasts when in use, 2

typical energy savings for dimming ballasts, and 3

market share of dimm ing ballasts in use. 4

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

Daniel. 6

MR. YOUNG: Daniel Young, California IOUs. 7

Again, for dimming ballasts, we would recommend that 8

you review the documents that the California IOUs have 9

docketed with the Energy Commi ssion when developing 10

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

assumptions on duty cycles for dimming ballasts that 12

are

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

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

24 standards in Ca lifornia, but we do have assumed 15

duty cycles for different operating modes, and that is 16

ultimately what was used to develop the weighted BLE 17

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

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

request that DOE review those documents which we'll 20

docket. 21

MR. BROOKMAN: Okay. Joe? 22

MR. HOWLEY: Just a comment that you may 23

already be aware of, that Lawrence Berkeley Labs did 24

like a meta study a few years ago that looked at all 2587

Heritage Reporting Corporation (202) 628

- 4 888 kinds of controls and dimming applications that might 1

be useful to look at to see where the various 2

applications came out. Every one is different, so 3

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

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

those studies. 6

MR. BROO KMAN: Pekka? 7

MR. HAKKARAINEN: Pekka Hakkarainen, Lutron. 8

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

studies, both published peer reviewed studies as well 10

as manufacturer case studies, covering commercial 11

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

much for residential applications, however. 13

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

Stephens? 15

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

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

by room, by type, by wattage, and DOE alre ady has that 18

data. 19

MR. BROOKMAN: Excellent. Okay. Yes. 20

MR. MYER: Finally, 7.6 seems to be 21

addressed a little bit already. DOE welcomes comment 22

on any data sources used to calculate the operating 23

hours of fluorescent ballasts and energy savings 24

rel ated to the use of dimming ballasts. 2588

Heritage Reporting Corporation (202) 628

- 4 888 MR. BROOKMAN: Any additional data sources 1

comment here? No? Okay. 2

MR. HAKKARAINEN: Pekka Hakkarainen, Lutron. 3

Just to comment that we will provide some references 4

in written comments. 5

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

End use profiles. 7

MR. MYER: Issue 7

- 5. DOE welcomes comment 8

on the use of operating hours profile for fluorescent 9

ballasts in this rule. Further, DOE welcomes comment 10

on whether the end use operating profiles are 11

different for t he various types of fluorescent lamp 12

ballasts under consideration for standards in this 13

rulemaking and, if so, how. 14

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

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

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

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

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

be pretty static and similar to the other ballast 20

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

industrial application. I'd j ust make comment there, 22

that would be more geared towards industrial operating 23

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

different operating use profile. They're typically 2589

Heritage Reporting Corporation (202) 628

- 4 888 put in more advanced systems that have controls on 1

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

going on, including fewer operating hours or operating 3

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

MR. BROOKMAN: Okay. Yes. Daniel? 5

MR. YOUNG: Daniel Young, California IOUs. 6

Just to echo that, certainly with the dimming ballasts 7

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

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

that again highlights kind of the importance of 10

understanding how they perform when they're dimmed 11

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

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

considering doing ballasts again, we would highly 14

suggest that the test procedure be revisited as well. 15

MR. BROOKMAN: Okay. Yes. Chris? 16

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

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

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

ballasts may be available from some of the larger 20

commercial energy efficiency programs which have to 21

develop that in order to do their cost/benefit 22

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

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

and Efficiency Vermont does as well. 2590

Heritage Reporting Corporation (202) 628

- 4 888 MR. BROOKMAN: Okay. Great. Final comments 1

here? 2

(No response.) 3

MR. BROOKMAN: Okay. 4

MR. MYER: Moving on , the next analysis 5

would be the markup analysis. The purpose is to 6

estimate actual user purchase price for manufacturer 7

selling price of baseline and higher efficiency 8

product designs. 9

Method. We're going to identify different 10

distribution channels an d estimate the share of said 11

distribution channels. Also we're going to estimate 12

markup values for each level in the identified 13

distribution channel. 14

This slide shows the graph from the 2000 and 15

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

dif ferent channels, one being a ballast shipped with a 17

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

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

essentially assumed that about 63 percent of ballasts 20

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

the replacement market. We will of course conduct new 22

research to verify these values, but this is a 23

historical marker. 24

Essentially markup is applied at each arrow 2591

Heritage Reporting Corporation (202) 628

- 4 888 in the process and the markups analysis would develop 1

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

Issue 8

- 1, DOE seeks comment on the 3

distribution channels and each share for distribution 4

channel described in this document as it applies to 5

the fluorescent lamp ballasts under consideration for 6

standards. 7

MR. BROOKMAN: Joe How ley? 8

MR. HOWLEY: Joe Howley. The channels 9

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

ballast rulemaking. 11

The mix of fixture ballasts versus 12

replacement ballasts may not be the same. There 13

appears to be a slow

- down in the amount of pure l amp 14

and ballast retrofits that are going on these days as 15

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

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

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

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

wondering if California has data on this. 20

MR. HOLSTEIN: This is Chris Holstein. 21

MR. BROOKMAN: Chris, go ahead. 22

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

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

the same because they were in the last bal last rule. 2592

Heritage Reporting Corporation (202) 628

- 4 888 They're significantly different from what's 1

publicized. 2

MR. BROOKMAN: That will be very helpful. 3

Thanks, Chris. 4

Okay. Additional comments here? 5

(No response.) 6

MR. BROOKMAN: Okay. Nothing. 7

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

would move into the life

- cycle cost analysis and the 9

payback period analysis. The purpose is to assess the 10

economic inputs of different efficiency levels on the 11

consumers of fluorescent lamp ballasts. The method is 12

the life

- cycle cost is equal to the in stall cost plus 13

your operating costs. Results are expressed in LCC 14

savings and payback period, which is expressed in a 15

period of years. 16

Inputs are broken down in calculation 17

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

series of different things , such as the product 19

purchase price, which is taking the manufacturer's 20

selling price and adding on markups; the installation 21

costs, labor and materials to actually install said 22

products; maintenance costs incurred by the consumer 23

for preventative mainten ance of the products; any 24

potential repair or replace damaging of manufacturing 2593

Heritage Reporting Corporation (202) 628

- 4 888 component costs. Obviously the energy costs 1

associated with operating the product. The discount 2

rate, which is essentially the cost of capital or 3

finance costs for residentia l sectors. And then 4

finally the product lifetime, which will be borne out 5

of catalogs and literature sources, technical reports 6

and industry inputs. 7

We would also look at a no

- new

- standards 8

case efficiency distribution. No

- new

- standards 9

distribution is the distribution of the market share 10

for each efficiency level for product classes in the 11

absence of an amended DOE standard. If market share 12

data is not available by efficiency level, DOE may 13

develop no

- new

- standards efficiency distributions 14

based on av ailable models. 15

We're also going to conduct a Monte Carlo 16

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

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

different parameters are modified to see the end 19

results. 20

The LCC, LCC savings and pa yback period, are 21

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

the LCC results are also presented in the form of 23

estimated percentage of consumers that are adversely 24

affected by amended standards. 2594

Heritage Reporting Corporation (202) 628

- 4 888 That brings us to the next set of issues, 1

Issue 9

- 1. DOE welcomes input on the electricity 2

prices to be used in this analysis. 3

MR. BROOKMAN: Chris. 4

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

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

period of potentially greater uncertainty with regards 7

to electricity prices due to things like the Clean 8

Power program and the rapidly developing market for 9

distributed generation. And so an analysis method 10

that takes that uncertainty into account, whether 11

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

different prices or what have you, would be 13

appropriate. 14

MR. BROOKMAN: Okay. Thanks. 15

MR. MYER: Issue 9

- 2, discount rates. DOE 16

welcomes input on the planned approaches for 17

estimating discount rates for consumers of fluorescent 18

ballasts under consideration. 19

(No response.) 20

MR. BROOKMAN: No additional comments on 21

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

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

Nothing additional. 24

MR. MYER: Continuing into Issue 9

- 3, cost 2595

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- 4 888 input. DOE welcomes com ment on how to develop 1

installation, maintenance and, if applicable, repair 2

costs for fluorescent ballasts. In particular, DOE 3

will

-- energy conservation standards affect useful 4

lifetimes of the ballasts and/or the fluorescent lamps 5

operated by those bal lasts. If the lamps operated by 6

the more efficient ballasts would be affected, then 7

DOE invites comments from interested parties on 8

whether relamping practices would change as a result. 9

MR. BROOKMAN: Nothing here? Joe. 10

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

mention

-- this is Joe Howley from GE

-- is that while 12

generally when you dim incandescent systems you do 13

greatly increase the lamp life, that generally is not 14

the case with fluorescent systems. You don't 15

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

not dimmed properly, you could actually reduce the 17

lamp life depending on how the cathodes are treated in 18

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

increase in lamp life to be factored in. 20

MR. BROOKMAN: Okay. Yes? Ernesto? 21

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

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

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

repair ballasts nowadays. 2596

Heritage Reporting Corporation (202) 628

- 4 888 MR. MYER: Michael Myer, PNNL. Echoing Joe 1

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

assumed nobody repaired ballasts. That was the 3

previous assumption, and we will at this point, 4

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

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

repair cost is for the ballasts. The maint enance cost 7

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

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

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

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

MR. BROOKMAN: Did we do l ifetimes yet or 12

no? 13

MR. MYER: No. 14

MR. HOLSTEIN: This is Chris with Universal 15

Lighting Technologies. 16

MR. BROOKMAN: Yes. 17

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

that is some of the technology suggestions. If 19

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

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

significantly change the maintenance costs. 22

MR. MYER: So keep in

-- Chris, Michael 23

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

of the ballast changed, that could then result in a 2597

Heritage Reporting Corporation (202) 628

- 4 888 change in maintenance costs? 1

MR. HOLSTEIN: Yes, sir. 2

MR. MYER: Thank you for clarifying. 3

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

I mean, the little screw mounts won't

-- right

-- the 5

little

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

MR. MYER: Th ank you very much. Moving into 7

Issue 9

- 4, ballast lifetimes. DOE welcomes comment on 8

the appropriate fluorescent ballast lifetimes for the 9

ballasts under consideration. 10

MR. BROOKMAN: Any difference in lifetimes 11

looking ahead? 12

(No response.) 13

MR. BR OOKMAN: No comment here. Okay. 14

MR. MYER: Okay. Building on the life

- cycle 15

cost analysis and the payback period analysis, we 16

would then conduct a shipments analysis and national 17

impact analysis. The shipments analysis, the purpose 18

is to project futur e shipments by product class. DOE 19

typically projects based on a 30

- year period, starting 20

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

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

be calculating it on historical shipments, retirements 23

of previously installed ballasts, as well as other 24

appropriate data sources. DOE may use different 2598

Heritage Reporting Corporation (202) 628

- 4 888 shipment projections in the standards case and the no

1

new

- standards case depending on information available. 2

Part of the shipment analysis, we would look 3

at three different scenarios, one being new 4

construction. That means essentially the ballast is a 5

part of a new fixture going into construction. We 6

would potentially use growth projections to determine 7

commercial and industrial equipment sectors. Again, 8

t his is done in a 30

- year compliance period. 9

The other thing we would look at is 10

replacements. This refers to new ballasts that are 11

installed each year to replace ballasts that have 12

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

mean the ballasts r eplace existing during renovation. 14

The retrofit replacement may occur before the actual 15

ballast has failed. 16

Issue 10

- 1, data on source for shipments. 17

DOE welcomes recommendations on sources of data that 18

would provide information on shipments of fluores cent 19

ballasts by product class. In addition, DOE welcomes 20

comment on recommendations on how it might 21

characterize long

- term trends and efficiency of 22

fluorescent ballasts for the no

- new

- standards case 23

projection. 24

MR. BROOKMAN: Charlie. 2599

Heritage Reporting Corporation (202) 628

- 4 888 MR. STEPHENS: Charlie Stephens, NEEA. 1

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

all discussed in all the lighting rulemakings, when it 3

comes to the displacement rate of this technology with 4

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

marketplace is that th e LED replacements tend to be 6

something maybe not quite an order of magnitude more 7

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

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

remain the case. The prices will come down 10

eventually. 11

But it seem s to me that to some extent early 12

on in the market your relative shipment rates of the 13

different technologies will depend on their price 14

relationship and the price elasticity I guess you 15

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

do you have som e means for testing alternative 17

scenarios here depending on how the prices of LED 18

products evolve over time? 19

MR. MYER: At this time we are just 20

collecting data. But it is a fluorescent lamp 21

ballast. And while we understand other technologies 22

might pla y a role in how fluorescent ballasts are 23

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

the efficiency of the fluorescent ballasts, the 25100

Heritage Reporting Corporation (202) 628

- 4 888 projection of fluorescent ballast efficiency over 1

time. 2

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

you have the m laid out as new construction and 4

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

numbers of ballasts going into new construction will 6

be impacted by

-- since you're not looking at all of 7

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

numbers will change depending on how the price of LEDs 9

change because in new construction people would prefer 10

to use the LEDs in many cases if they're cheap enough. 11

MR. MYER: Yes. 12

MR. STEPHENS: But if they're not, maybe 13

they won't. So I'm wondering how you' re going to 14

account for, you know, how that's going to shift 15

depending on how the alternative technology comes out 16

in these various sectors. 17

MR. MYER: Michael Myer, Pacific Northwest 18

National Laboratory. Yes. We have in the past and I 19

believe in this previous fluorescent ballast rule, for 20

example, looked at different shipment profiles. So we 21

will look at different things and take into account 22

how we develop those profiles. It might be the price 23

relation to LEDs as well as other factors. So we can 24

lo ok at different growth cycles for new construction. 25101

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- 4 888 MR. BROOKMAN: Yes, Charlie. Oh, Joe. Go 1

ahead. 2

MR. HOWLEY: Yes. Well, Joe Howley, GE. I 3

was looking at I think the other side of that, 4

Charlie, where if this produced a very expensive 5

fluorescen t dimming ballast it is just going to 6

accelerate new construction to go to LED if they want 7

a dimmed system. They simply will just give up on 8

fluorescent dimming ballasts. So it would be an 9

equation where if the standard produced very high 10

cost, there wo uld be no savings from it because the 11

product would simply shift almost immediately to LED 12

dimming. So that should be factored somehow into the 13

analysis. 14

MR. BROOKMAN: Okay. You want to follow on, 15

Pekka? 16

MR. HAKKARAINEN: Pekka Hakkarainen, Lutron. 17

What Joe is describing is a theoretical scenario that 18

will never take place anyway because no one is going 19

to make the higher

- cost dimming ballast. 20

MR. BROOKMAN: Charlie. 21

MR. STEPHENS: Yeah. Charlie Stephens. I 22

was just looking at the existing sce nario that 23

California looked at essentially. They looked at a 24

range of dimming ballasts that exist. They can be 25102

Heritage Reporting Corporation (202) 628

- 4 888 tested. Some of them are more efficient than others. 1

They have a price. We know what the price is today. 2

What we don't know is we don't kn ow what the price of 3

LEDs is going to be next week or next year or in five 4

years, so that's the much bigger variable. 5

I think if DOE were to, for instance, set a 6

standard for dimming ballasts that eliminated half of 7

them, well, the other half are still o ut there. We 8

know what the prices are. People are buying them. 9

But we still don't know what the prices of the LEDs 10

are going to be. So it's a bit of a crapshoot really 11

in trying to figure out what the future looks like in 12

this circumstance. I don't en vy DOE the task of 13

trying to figure this out, but there ought to be some 14

sort of a scenario look at this that has

-- not that 15

it's just a scenario that says, yeah, shipments could 16

be this or this. It's why would shipments do this or 17

this, because these th ings are all related. 18

MR. BROOKMAN: Yeah. Ernesto. 19

MR. E. MENDOZA: Yeah, I agree with you. 20

It's very difficult to see the future. But our 21

experience is the first LED lamps came out at about 22

$40. Today they are $2 . So the only thing I'm unsure 23

is it will be lower cost in the future. So that's for 24

sure. And I echo also Pekka's scenario. I don't 25103

Heritage Reporting Corporation (202) 628

- 4 888 think we're going to pre

- design ballasts for higher 1

efficiency. The rule requires for higher efficiency. 2

Most probably those ballasts will not exist. 3

MR. BROOKMAN: Rebecca? 4

MS. RAINER: Yeah. I think some of these 5

questions really would be better answered in the 6

manufacturers'

-- 7

MR. BROOKMAN: Okay. Yeah. 8

MS. RAINER:

-- visits, and we can share our 9

data and what we see the future to be. 10

MR . BROOKMAN: Great. Thank you for 11

reiterating that. Daniel? 12

MR. YOUNG: Daniel Young, California IOUs. 13

So a question for DOE. If the situation that Joe 14

describes happens where the rule makes products more 15

expensive, can DOE look at savings that occur through 16

kind of this market shift to the more efficient LEDs? 17

MR. MYER: Michael Myer, PNNL. DOE tends to 18

focus the analysis on what are the results of 19

improving one technology, not as a result of other 20

interactions of different technologies. 21

MR. YOU NG: Right. But I guess by improving 22

this one technology you're

-- I mean, really it's

-- 23

you're looking at the application for commercial 24

lighting say. And if you've reduced commercial 25104

Heritage Reporting Corporation (202) 628

- 4 888 lighting energy use, you know, isn't that a good 1

thing, and wouldn't you want to take credit for those 2

savings? 3

MR. MYER: I'm going to defer to our written 4

comments in the next phase rule. I don't want to 5

assume how DOE likes to take credit for different 6

actions. 7

MR. BROOKMAN: Pekka. 8

MR. HAKKARAINEN: Pekka Hakkar ainen, Lutron. 9

I think it would be prudent for DOE to assume that 10

all the dimming ballasts that are going to be 11

available after the rule becomes effective are already 12

in the market. 13

MR. BROOKMAN: Okay. Chris, you had a 14

question, comment? 15

MR. GRANDA: No. 16

MR. BROOKMAN: Okay. We're about to move 17

on. Are we ready? 18

MR. MYER: Yeah. Issue 10

- 2, accounting 19

methodology. DOE welcomes comment on the accounting 20

methodology described in the framework document for 21

each of the fluorescent ballasts under consideration. 22

MR. BROOKMAN: Nothing here? 23

MR. HOLSTEIN: This is Chris Holstein, 24

Universal Lighting Technologies. I just wanted to 25105

Heritage Reporting Corporation (202) 628

- 4 888 bring out on the framework document there's some 1

things there that I believe are flawed that talk about 2

the increasing retrofit market, it talks about the 3

increasing rebate market. That is not what we see 4

today. I know in the framework document it does say 5

that you're using information from the last ruling to 6

do that. 7

But from industry numbers, which will be 8

prepared by me in the written comments as well as for 9

manufacturers, there's no indication of any product 10

category here. Every segment in the ballast market we 11

have new construction converted into solid stage 12

lighting, and by the time this rulemaking is 13

implemente d in 2017, I would say that nearly 90 to 95 14

percent of this market will receive solid

- state 15

lighting. Replacement market and offense load, I'm 16

not aware of any rebate today on the 4X side after the 17

efficiency ruling and the efficiency levels that you 18

have today, which would be for all new solid

- state 19

lighting. 20

And you've already talked about retrofits. 21

I mean, the retrofit market today doesn't

-- I mean, 22

there's very, very little fluorescent retrofitting 23

going on. Someone one is making a change. Every 24

manufacturer has a retrofit kit with LED. That is 25106

Heritage Reporting Corporation (202) 628

- 4 888 what we see in the market and that's where it's going. 1

So everybody who uses LED, don't go in with the 2

assumption that all systems are created equally 3

because it's not. 4

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

Daniel. 6

MR. YOUNG: Daniel Young, California IOUs. 7

Just a note on there. So, you know, while I'm not 8

going to, you know, try to predict the future for all 9

fluorescent shipments, I will just caution that the 10

percentage of dimming ballasts in the fluorescent 11

market, we expect that to increase, and due to very 12

recent standards, such as the Title 24 standard that 13

just went into effect last July. So a lot of those, 14

you know, market effects maybe haven't been felt yet, 15

but we do expect, again, relativ e to where they are 16

today and where they have been, the number of 17

shipments or the percentage of shipments that are 18

dimming ballasts, we expect that to go up. 19

MR. BROOKMAN: Okay. Thanks. 20

MR. MYER: Issue 10

- 3, standards affecting 21

shipments. DOE welc omes comment on how any potential 22

new or amended concentration standards for fluorescent 23

ballasts might affect shipments. DOE also invites 24

information about market pull programs that currently 25107

Heritage Reporting Corporation (202) 628

- 4 888 exist to promote the adoption of more efficient 1

ballasts. 2

MR . BROOKMAN: I think we've received some 3

comment on this. Do we have anything additional at 4

this point? Mary? 5

MS. ANDERSON: So California is looking at 6

our programs to try to see if there are additional 7

things we can do help support the market push

- pu ll. 8

And nothing public, but in the next month or so I 9

should have information on potentially additional 10

items that we will be doing to support these 11

rulemakings. 12

MR. BROOKMAN: I'm not sure I understood 13

you, Mary. In a month you might have what? 14

MS. ANDERSON: We will have

-- I think we 15

may have a new potential rebate program

-- 16

MR. BROOKMAN: I see. 17

MS. ANDERSON:

-- that could help to do 18

that. But we're still under development. 19

MR. BROOKMAN: Got you. Chris? 20

MR. GRANDA: Chris Granda, ASAP . After 21

residential lighting, commercial lighting programs of 22

all type are the largest energy efficiency program 23

category in terms of savings, have been historically, 24

and for many utilities or program providers they are 25108

Heritage Reporting Corporation (202) 628

- 4 888 the breadwinner, if you will. 1

MR. BROOKMAN: Or the easiest. 2

MR. GRANDA: And the easiest, yeah, in a lot 3

of cases. So there's, you know, rich sources of 4

information available at the utilities that run these 5

programs. They all involve some kind of reporting 6

obviously. But I think the overall comment that ASAP 7

would like to make is that, you know, in the dynamic 8

situation that we're in, as standards take effect, but 9

also as the technology paradigm for this market sector 10

changes, legacy market niches for obsolete 11

technologies can have b ig energy efficiency costs 12

associated with them, and understanding even when they 13

end up being relatively small percentages of the 14

overall market, they can have large numbers of 15

kilowatt hours associated with them if they endure for 16

a long period of time i n the marketplace. And there's 17

definitely some

-- we've had some experience with that 18

in other product categories. 19

MR. BROOKMAN: Okay. Charlie? 20

MR. STEPHENS: Yeah. Charlie Stephens. 21

We're reevaluating all of our commercial lighting 22

programs and c ommercial building programs in the 23

Northwest right now, and we're struggling in a lot of 24

places with cost

- effectiveness, our own cost

- 25109

Heritage Reporting Corporation (202) 628

- 4 888 effectiveness criteria. When you don't need power 1

because things aren't growing, you know, cost

2

effectiveness becomes a b it of a challenge. So we're 3

going to have to achieve whatever savings there are at 4

lower cost in a lot of cases and be more clever and 5

sometimes more targeted in what we go after. 6

As Chris just mentioned, there are some 7

older legacy systems out there th at while the market 8

is small, if you can figure out how to get at it, the 9

savings can be large per building or per project. But 10

to a great extent we're struggling a little bit with 11

the costs that we see. Controls, for instance, have 12

become very costly, a nd they don't always work. So 13

we're having

-- our own spaces are an example of that. 14

But we're struggling a little bit with what to do and 15

how to make it cost

- effective. So I can't 16

unfortunately say right now what directions we may be 17

going in. We'll d o something, but we don't know what 18

it is yet. 19

MR. BROOKMAN: Okay. Yes, please, your 20

name. 21

MR. TSAN: This is Bach Tsan from Southern 22

California Edison. I'm just looking at our solutions 23

directory for programs, and there is not necessarily 24

for energ y efficiency, but there are some rebates for 25110

Heritage Reporting Corporation (202) 628

- 4 888 demand response in regards to dimming ballasts. I'll 1

share through Daniel that particular program. 2

MR. BROOKMAN: Okay. Thank you. Next? 3

MR. MYER: The next would be national impact 4

analysis. National im pact analysis looks at the 5

overall effects at the national level in the form of 6

an NES, which is National Energy Savings, and net 7

present value is the total cost across the country. 8

It takes into account inputs and outputs from the LCC 9

as well as shipment s to develop an annual series of 10

national energy and economic effects. 11

It aggregates the cost of energy use in 12

years in the analysis period. It's reported in 13

primary and full

- fuel cycle savings, and the NPV is in 14

billions of dollars. It accounts for ti me, value, 15

money through defined discount rates. 16

Inputs for calculating the NPV are the 17

installed and operating costs, as I mentioned, that 18

were garnered in the LCC: projected shipments; 19

electricity price projections; HVAC, heating, 20

ventilation, and air conditioning price 21

projections

-- interactions, I'm sorry, I should say; 22

a fixed discount rate of 3 and 7 percent; and any 23

potential rebound effect. 24

Issue 11

- 1, data sources for NIA. DOE 25111

Heritage Reporting Corporation (202) 628

- 4 888 welcomes data on sources it anticipates using to 1

develop inputs f or the National Impact Analysis. 2

MR. BROOKMAN: Anything additional here or 3

anything that might be novel? 4

(No response.) 5

MR. BROOKMAN: Nothing additional, okay. 6

MR. MYER: Issue 11

- 2, the NIA model. DOE 7

welcomes comments on the NIA spreadsheet mo dels it 8

plans to use for estimating national impacts for 9

fluorescent ballasts. 10

MR. BROOKMAN: Yes, Daniel. 11

MR. YOUNG: Daniel Young, California IOUs. 12

So actually just a question. Can we ask DOE to 13

provide certain kind of interim values, like maybe 14

st atewide savings or perhaps unit savings in their 15

spreadsheet models? 16

MR. MYER: I'm sorry. Statewide savings? 17

Michael Myer, PNNL. And what was the second one? 18

MR. YOUNG: Like unit savings. Sometimes 19

it's there, sometimes it's there but hard to fin d. 20

You know, it makes things a lot easier for us 21

sometimes when we want to analyze things either just 22

for our own, you know, statewide understanding of the 23

impacts or just kind of checking the various 24

calculations or proposed levels. So just kind of 25112

Heritage Reporting Corporation (202) 628

- 4 888 aski ng for some interim results presented or 1

highlighted in the spreadsheet models that makes it 2

easier for us to find what we're looking for I guess. 3

Can we, you know, provide a set of requests I guess 4

and then ask you to do that? 5

MS. deBUTTS: We can look into it. If you 6

send us the information of what you're actually 7

looking for, we can just analyze and see if we can 8

actually do that. 9

MR. YOUNG: Great. Thank you. 10

MR. MYER: And Michael Myer. When you say 11

interim, you're not suggesting between phas es. It's 12

more just subset of the total data. 13

MR. YOUNG: Right. 14

MR. MYER: Just putting it down differently. 15

MR. YOUNG: Right. 16

MR. MYER: And unit meaning if 30 million 17

units are shipped, what is it per piece. 18

MR. YOUNG: Exactly. 19

MR. MYER: Great. I just wanted to make 20

sure I understood everything. Thank you. 21

MR. BROOKMAN: Okay. Additional thoughts, 22

comments here? Let's go ahead, Mike. 23

MR. MYER: We addressed 11

- 2

-- 24

MR. BROOKMAN: Yeah. 25113

Heritage Reporting Corporation (202) 628

- 4 888 MR. MYER:

-- with Daniel's comment. At 1

t his point, I will turn the presentation to my 2

colleague, Rachel Dickenson, to discuss the future 3

NOPR analyses. 4

MS. DICKENSON: Okay. I'll just briefly 5

discuss some of the analyses that DOE plans on 6

conducting in the NOPR stage of the rulemaking. 7

The manufacturer impact analysis serves 8

three main functions. First, it assesses the impacts 9

of standards on manufacturers. Second, it identifies 10

and estimates impacts on manufacturer subgroups that 11

may be more severely affected than the industry as a 12

whole. And third, it examines the direct employment 13

impacts, manufacturing capacity, and cumulative 14

regulatory impact on the industry. 15

To do this, DOE will analyze industry cash 16

flow and industry net present value through a 17

quantitative model called the GRIM. DOE will also 18

interview manufacturers to refine inputs to this model 19

and address qualitative issues. All data and 20

information shared is aggregated prior to the use in 21

the rulemaking analysis. 22

So manufacturer impact consists of three 23

phases. The first starts during the preliminary 24

analysis in which DOE will create a basic industry 25114

Heritage Reporting Corporation (202) 628

- 4 888 profile and conduct the initial interviews. Then 1

during the NOPR DOE develops a strawman GRIM in phase 2

two, followed by interviews and assessment of direct 3

employment compet ition in the field of regulatory 4

burden in phase three. 5

And here are some of the other analyses the 6

DOE will conduct in the NOPR stage. They include the 7

consumer subgroup analysis where DOE analyzes the 8

consumer effects on various national consumer 9

subg roups that might be adversely affected by 10

potential standards; the utility impact analysis, 11

which determines the impact on the general capacity of 12

utilities as a result of potential standards; the 13

employment impact analysis, which covers indirect 14

employmen t impacts resulting from shifts in costs or 15

changes in income due to potential standards. And 16

this is different from the employment impact analysis 17

conducted in the manufacturer impact analysis, which 18

assesses the direct employment, which are the changes 19

in the employment numbers as plants that produce the 20

covered products. 21

The emissions analysis is where DOE will 22

estimate the reduction in power sector emissions of 23

carbon dioxide, nitrogen oxide, sulfur dioxide, and 24

mercury due to the potential standards . And DOE also 25115

Heritage Reporting Corporation (202) 628

- 4 888 assesses the monetary benefits of reducing carbon 1

dioxide and nitrogen oxide emissions due to potential 2

standards. 3

The regulatory impact analysis looks at the 4

impacts of non

- regulatory alternatives that could 5

improve the energy efficiency or reduce the energy 6

consumption of the products covered in this 7

rulemaking. 8

So first, DOE welcomes comment on what, if 9

any, consumer subgroups are appropriate in considering 10

standards for the fluorescent lamp ballasts. 11

(No response.) 12

MS. DICKENSON: DOE also welcomes input from 13

interested parties on its plan to use the NEMS

- BT to 14

conduct the utility impact analysis. 15

(No response.) 16

MS. DICKENSON: Okay. And DOE welcomes 17

feedback on its planned approach for assessing the 18

national employment impac ts, both direct and indirect. 19

(No response.) 20

MS. DICKENSON: Finishing up, DOE seeks 21

comment on its approach to conduct the emissions 22

analysis for the products that would be under 23

consideration for standards in this rulemaking. 24

(No response.) 25116

Heritage Reporting Corporation (202) 628

- 4 888 MS. D ICKENSON: And DOE requests comment 1

about the approach it plans to use for estimating the 2

monetary benefits associated with the emissions 3

reductions. 4

(No response.) 5

MR. BROOKMAN: We went through those kind of 6

rapidly. These are downstream significant ly. Any 7

additional comments, thoughts on any of these 8

consumer, utility, employment, emissions, and 9

monetizing, and globally regulatory impact analysis 10

generally? Alex Boesenburg. 11

MR. BOESENBURG: Alex Boesenburg, NEMA. I 12

have a general comment about the impact analysis. In 13

the past, usually the way we get to see the results of 14

the analysis is in the TSD spreadsheets. However, 15

when we attempt to understand the dynamics of the 16

impacts and how they're felt, since most of the 17

spreadsheet is locked, we r eally

-- we can adjust a 18

few fields here and there for discount rates or 19

whatever, but it doesn't actually help us understand 20

in a way that we can therefore substantively and 21

productively and constructively comment on how we 22

think an analysis or an impact might

-- its assessment 23

could be improved or something. 24

You know, we just

-- it's very hard to

-- 25117

Heritage Reporting Corporation (202) 628

- 4 888 there's a lot of data there, but we can't actually do 1

much with it. So we'd like to, you know, ask the DOE 2

to consider or come up with a more proactive way to 3

discuss analysis. And as more of a real world example 4

of this is often when we have TSD or NOPR analysis, 5

someone from Navigant or LBNL or PNNL is up there and 6

they say that, well, it looks like the impact is going 7

to be kind of like this. And one of the manufacturers 8

will ask, well, why is that? Did you talk about 9

the

-- did you look at this way. So, oh, no, no, we 10

assume that would never happen. And the manufacturer 11

says, no, no, no, we always do it that way. What are 12

you talking about? 13

These assumptions aren't documented, and so 14

we never know if someone went ahead to make a decision 15

to go left or right and made the right one. And so 16

that's just one example. We turn this stuff over 17

occasionally, but only Easter eggs when we happen to 18

stumble across one, and I think we can do something 19

different, something better, and we'd like to ask you 20

to consider that. 21

MS. deBUTTS: Thanks, Alex. Lucy deButts 22

with DOE. I understand the concern. There are 23

certain rules that we have to abide by when we p lace 24

documents in a docket. So, you know, I don't know 25118

Heritage Reporting Corporation (202) 628

- 4 888 exactly if that's the issue there as well. We'll have 1

to check. But also that's why it's useful to have the 2

meetings like that when we actually have the 3

conversation with the manufacturers to discus s our 4

TSDs and analysis that's presented there. But we'll 5

see what we can do as well. 6

MR. BROOKMAN: Yeah. It sounds like you're 7

seeking a tool that's more flexible or more 8

transparent or something. 9

MR. BOESENBURG: Yes. That's a good way to 10

sum it up. 11

MR. BROOKMAN: But it may be hard to do. 12

MS. deBUTTS: In some cases, it is, but, you 13

know, again, we'll try. We'll see what we can do. 14

MR. BOESENBURG: We're sensitive that one of 15

the reasons some of this stuff is locked is because 16

you're prote cting the data, and we applaud that. But 17

at the same time, there is

-- you know, there is

-- if 18

there is a way to protect the manufacturers' 19

confidentiality and the data, which I am obliged to do 20

myself, but still help understand the machinations of 21

the m odel, it would be very helpful. 22

MS. deBUTTS: Okay. Thanks. 23

MR. BROOKMAN: Okay. So, as we promised 24

this morning, yet another opportunity for closing 25119

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- 4 888 remarks or any other material that we haven't covered 1

sufficiently by your thoughts to date. Ernest o. 2

MR. E. MENDOZA: Ernesto Mendoza from 3

Philips Lighting. On the case, specific case of 4

dimming ballasts, the use is different than the fixed 5

output ballasts. They are always part of a system. 6

You may have a very simple control, or you may have a 7

mor e compressed control, but it's always a system. So 8

I don't know if it need to include in the model from 9

the DOE the systems approach, the total efficiency 10

that the system will achieve as opposed to only the 11

ballast. 12

The concern I have is we can start li miting 13

the energy use of the ballast. Then if we need to do 14

additional control information and communications, 15

we're just going to put an extender box to the ballast 16

that would consume power than if all this intelligence 17

would be inside of the ballast. S o the total 18

efficiency will go down in the system where we will 19

have a higher ballast efficiency. So my suggestion is 20

to consider in the modeling the systems approach as 21

opposed as only the ballast efficiency. 22

MR. BROOKMAN: Okay. Additional comments 23

h ere as we move toward closure, final comments on the 24

day? 25120

Heritage Reporting Corporation (202) 628

- 4 888 (No response.) 1

MR. BROOKMAN: Nothing additional at this 2

time. So then back to Lucy, Lucy deButts, for closing 3

remarks. 4

MS. deBUTTS: Well, again, thank you, 5

everyone, for coming. And it see ms like we're going 6

to get a lot of data that could be useful for our 7

rulemaking. This is again the slide on how to submit 8

the comments. We are looking forward to them, and 9

with that, thanks again. 10

(Whereupon, at 11:48 a.m., the meeting in 11

the above

- en titled matter was concluded.) 12121

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- 4 888 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 t he 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

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